Health and Safety

  • Health and Safety
  • Appendix

There are a variety of safety and health hazards and risks associated with mining operations. If not managed effectively, such risks can have significant consequences for our employees, contractors, communities and our business as a whole.

The health and safety of our people is the highest priority at all our operating sites and across our entire company. Safety leadership development is helping to improve competencies that are important to safety performance management. Our commitments are based on a belief that all workers should go home safely after every shift as captured in our safety vision "Safe for Life".

The mandate of our Safety and Sustainability Committee is to monitor the health, safety, security, environmental, and community relations performance of the company, as well as to assess the effectiveness of associated policies and practices on behalf of the Board.

We have an enterprise-level Safety and Health Policy that guides us in advancing the values and standards for our health and safety systems as well as to comply with all applicable health and safety laws, rules, and regulations. The policy is applicable to all our employees and contractors and across all of our operations, and is available on our public website at

In 2009, we implemented an enterprise-level safety and health management system (SHMS) at our Pirquitas mine. This was done voluntarily as best practice rather than due to formal legal requirements. In 2018, we conducted a comprehensive review of the enterprise-level system, and we will begin implementing revisions to the systems across our operations in 2019. Currently, our operations are developing or revising individual systems based on the enterprise-level model.

Safe for Life logo

The revised enterprise-level SHMS conforms to Occupational Health and Safety Assessment Series (OHSAS) 18001 and International Standards Organization (ISO) 45001. The system is applicable to all operating sites as well as all employees and contractors.

Management review and continuous improvement form one of the core elements of the system. We will conduct reviews of the system at defined intervals once our individual systems are revised. Our Safety and Sustainability Committee of our Board of Directors has responsibility for reviewing and monitoring our health and safety systems, policies, and activities on behalf of the Board.

Throughout 2019, we will begin the implementation of our revised enterprise-level SHMS across the company. We will conduct an internal assessment of the implementation of the system at all our operating sites. Within the system, the major focus in 2019 is risk management.

In addition, we will implement our revised enterprise-level Safety and Health Policy in conjunction with our Safety and Sustainability Committee. We will provide training to our employees on any changes to the policy and coordinate an annual attestation of the policy by all directors, officers, and employees.

In line with our corporate objectives, we set a target of improving our total recordable incident frequency rate (TRIFR) by 10% over our 2018 performance, 90% compliance with critical risk control protocols, and to improve the timeliness of action item implementation resulting from the analysis of High Potential Incidents.

More detailed disclosures related to health and safety can be found in the Health and Safety Appendix. Additional health and safety data can be found in the GRI Index of this report.

Hazard Identification

We apply two parallel strategies to identify hazards and assess and control risks, namely:

1. Complying with applicable jurisdiction-specific regulatory requirements; and,

2. Applying a company-specific risk management process.

We identify hazards through a variety of formal and informal mechanisms including workplace inspections; audits; observations by workers and management; review of injury and illness records including near miss incidents; worker suggestions; regulatory inspections; and input from second- and third-party subject matter experts.

We assess risks using a variety of formal and informal techniques and tools, including: brainstorming; job hazard analysis; bow tie analysis; and field-level risk assessments. We focus on the control of all relevant risks with special emphasis on critical risks. Routine tasks are generally accompanied by a standard operating procedure, which is typically based on a job hazard analysis. We train workers against standard operating procedures and base critical risk control protocols on the hierarchy of control.

We ensure the quality of the risk management process through incident investigations, audits of field-level risk assessment records, field interactions between workers, line managers and safety and health professionals, quarterly reviews of each site’s risk register, and as part of the formal review element of the system. We train individuals who participate in risk assessment activities commensurate to the risk of their work to ensure competency. Generally, individuals with a higher level of competency assess competency requirements.

As risk management is a key element of our SHMS, we regularly evaluate its effectiveness, with an emphasis on the effectiveness of critical risk controls. We use a number of inputs to determine how to continuously improve the system, including root cause analysis, system audits, and management reviews.

All of our workers have both the opportunity and the responsibility to report workplace hazards and to modify or stop work if any situation presents an unacceptable degree of risk. We inform all workers of their right to refuse or discontinue work judged to be too hazardous or for which changing conditions will render it unsafe while undertaking the work. The process involves notification to the relevant line manager and/or safety professional and securing the area and equipment (or access to either).

All workers have both jurisdictional legal protections against reprisal and discrimination in reporting work-related hazards and risks, as well as protection under our Whistleblower Policy.

We investigate work-related incidents through established incident investigation and root cause analysis techniques, depending on the circumstances of each incident. Investigation teams may consist of managers and workers. We formally track findings and recommendations – once approved – for compliance. For corrective actions that have significant financial requirements, there is a corporate authorization for expenditure approval process.

Lastly, we conduct trend analysis at both the operations and corporate level to facilitate changes required to safety management systems.

Occupational Health Services

Occupational health services are divided between internal and external resources. We employ full-time safety and health professionals at the corporate office and operations as well as at development projects as required. The number of safety and health professional employees is proportional to both the number of employees and the maturity of risk management at each location.

We also rely on occupational health services in the form of nurses and physicians for both preventative and treatment of injuries or health-related issues. The Seabee Gold Operation mine and Puna Operations have on-site medical clinics and utilize off-site medical clinics while the Marigold mine has access to multiple occupational health clinics in communities proximate to the mine. The Seabee Gold Operation and Puna Operations are fly-in/fly-out and drive-in/drive-out operations, respectively.

Where required, we commission third-party subject matter experts in ergonomics, risk management, and occupational hygiene to support site and corporate occupational health and safety services.

We maintain quality control of internal occupational health and safety services through hiring standards, including educational requirements, professional certification, and experience standards for position descriptions. In addition, we ensure quality through maintaining legal and regulatory compliance, regular safety audits, and peer / industry benchmarking. We also encourage professional development related to safety for our employees. We inform workers of these services through new employee orientation, safety and health system review, written notifications and postings, and procedures that integrate occupational safety and health services.

Worker participation, consultation, and communication

We frequently require our workers to participate in risk assessments involving their work, including job hazard analysis and field-level risk assessments. We believe this improves the accuracy and quality of these tools independent of or in conjunction with internal subject matter expert risk assessment work.

Puna Operations and the Seabee Gold Operation have a joint worker-management safety committee that meets monthly or as defined by applicable regulations. The Marigold mine is rebuilding its committee structure to be more effective and collaborative. The committees provide input to hazard identification, review of regulatory compliance issues, and provide suggestions for safety and health management improvements. These committees are based either on collective-bargaining agreements – or where no agreement exists – through mechanisms that ensure worker representation.


Health and safety training needs are defined through applicable regulatory requirements and assessed through nonregulatory position- or task-specific demands, outcomes of risk assessments, original equipment manufacturer recommendations, and findings from incident investigations.

We conduct most occupational health and safety training and education in-person by qualified and competent internal personnel. For special topics or equipment-specific needs, we utilize second- and third-party subject matter experts to deliver the training. In specific instances, we leverage special technology to enhance in-person training, such as virtual reality and equipment simulators. Some operations conduct some training using self-guided, computer technology.

Topics include a wide range of occupational health and safety issues, but generally follow a risk management perspective. Key issues include the following: work-related hazards; the nature of the related risks; appropriate controls, including both prevention and mitigation; emergencies; company-specific requirements; and worker rights.

We provide all training at no cost to employees and contractors. We compensate employees for training conducted outside of non-assigned work hours. We provide training in the primary dominant language of the country of operations and base the frequency of training on applicable regulatory requirements, which typically means baseline or ‘new miner’ training followed by annual refresher training. This is in addition to discretionary training conducted as a baseline, followed by different re-training intervals to ensure individual performance effectiveness.

We evaluate the effectiveness of training using a combination of methods, including those specified by jurisdictional regulations, mastery tests, practical competency verification, line management observation, and field interaction between management and workers.

Non-occupational health services

We recognize the importance of general health and wellness for both employee quality of life as well as the ancillary benefits to occupational safety and health. Workers and contractors at our three operating mines can access nonoccupational health services through at least three mechanisms:

1. Workers and contractors use the national healthcare system in Canada;

2. Workers in the United States can use company-supported health insurance coverage, while contractors can use their company’s health insurance coverage (if provided); and,

3. Workers and contractors have private (company-sponsored) insurance coverage from their respective employer in Argentina.

We sponsor voluntary wellness health assessments at two of our three operating mines that include monitoring for a range of health metrics, such as blood pressure, body mass, and blood sugar. Targeted programs include information on smoking cessation, health and nutrition initiatives, and the provision of fitness facilities at the Seabee Gold Operation and Puna Operations.

Impacts related to products

As an organization involved in the production of precious metals, we address product risk that may affect non-company personnel through the dissemination of accurate and thorough safety data sheets and responding to inquiries from governments, transporters, and end-use customer inquiries.