MSMS Explained: What WA Mine Operators Must Have in Place
Every mining operator in Western Australia has a legal duty to establish and implement a mine safety management (MSMS). That obligation is outlined in the Work Health and Safety (Mines) Regulations 2022 – and it’s not an optional decision.
WorkSafe WA extended its compliance deadline to March 2024 after finding that a significant number of mines had failed to properly develop or develop an MSMS. Many operators thought they had one in place, but upon inspection, they did not.
This guide explores what an MSMS actually is, what it needs to contain, how it differs from a standard safety management system and when yours needs to be reviewed.
What Is a Mine Safety Management System (MSMS)?
An MSMS is not a safety manual. It is the overarching framework that pulls together every safety-related policy, plan, procedure and control at a mine into one coordinated system.
Under the WHS Mines Regulations, the MSMS is the primary means of providing processes and methods to ensure safe operations at a mine. It does not sit alongside your other safety documents – it ties them together so there are no gaps in how health and safety risks are identified, controlled and monitored.
The MSMS applies to all mine operators, not just large open-cut operations. It covers underground mines, surface mines, quarries and exploration sites. If you are commencing a new mining operation, the MSMS must be in place before any work begins.
Another point worth clarifying early is that a group or corporate MSMS does not satisfy the requirement on its own. Each individual site must have its own system that reflects the specific conditions, risks and hazards present at that location.
What Are the Legal Requirements for an MSMS in Western Australia?
The legal duty to establish and implement a mine safety management system comes from the Work Health and Safety (Mines) Regulations 2022, which operate under the WHS Act 2020.
The WHS Act 2020 requires all persons conducting a business or undertaking, including mine operators, to ensure the healthy and safety of their workers so far as is reasonably practicable. The MSMS is the mechanism through which mine operators meet that duty in a structured, documented and auditable manner.
WorkSafe WA has published a Code of Practice: Mine Safety Management Systems to assist mine operators in understanding and meeting these obligations. The code is not legislation, but compliance with it is taken as evidence that an operator is meeting the requirements of the regulations.
Western Australian mines were originally required to have a fully developed MSMS in place by March of 2023. That deadline was later extended to March 2024 after WorkSafe identified a pattern of operators having inadequate systems in place, or no genuine system at all. The mines inspectorate operating under the Department of Local Government, Industry Regulation and Safety is actively checking and non-compliance isn’t a paperwork issue – it is a direct breach of the WHS Act 2020.
H3: Does A Generic Safety Management System Count?
No. This is one of the most common compliance gaps WorkSafe WA has identified.
A generic safety management system, including a group-level or corporate SMS, does not satisfy the requirement for an MSMS unless it has been adapted to the specific hazards, risks, operations and statutory appointments at each individual mine site.
A system written for a construction company or borrowed from a template without site-specific content is not suitable as an MSMS. WorkSafe WA inspectors have found this to be a recurring issue – where the document might exist, but in a legal sense, the MSMS does not meet the mark.
H2: What Must Be Included in a Mine Safety Management System?
The minimum content requirements for an MSMS are set out in the WHS Mines Regulations. The level of detail required is proportionate to the scale, complexity and risk profile of the operation. A small quarry will not need the same depth of documentation as a large underground mine. That being said, every MSMS must address the same core areas.
Those areas include:
- A health and safety policy, developed in consultation with workers and communicated to everyone at the mine
- A management structure that clearly sets out roles, responsibilities, competency requirements and arrangements for filling vacancies
- Hazard identification and risk management procedures covering all workplaces, processes, plant and equipment
- A Health Management Plan (HMP) that identifies health hazards and their potential effects on workers
- An emergency plan covering roles, evacuation procedures and conditions for withdrawing personnel
- Arrangements for worker consultation and contractor management
- Performance standards against which the MSMS can be measured
- An audit system that documents the methods, frequency and results of audits
One of the most frequently misunderstood components is the Principal Mining Hazard Management Plan. It’s worth examining the requirements of this plan separately.
H3: What Are Principal Mining Hazard Management Plans (PMHMPs)?
Every MSMS must include a Principal Mining Hazard Management Plan (PMHMP) for each principal mining hazard identified at the site.
Principal mining hazards are defined under the WHS Mines Regulations as hazards with the reasonable potential to cause multiple deaths in a single incident, or through recurring incidents. That definition covers a specific list of risk categories, which may include ground instability, inrush of water or gas, spontaneous combustion, mine shafts and winding systems, mobile plant interactions, airborne contaminants and isolated working conditions.
Each PMHMP must be developed in consultation with workers. It must document the identified hazard, the risk assessment, the critical controls selected and the performance indicators used to monitor whether those controls are actually working. Checklists and routine testing must be used to confirm controls remain in place and effective.
In July 2025, WorkSafe WA released a new PMHMP Guide and self-assessment template to help mine operators develop compliant plans and assess existing ones. If your PMHMPs predate this guidance, it is worth reviewing them against the new material.
H2: When Does an MSMS Need to Be Reviewed or Updated?
An MSMS has a defined review cycle under Western Australian regulations, as well as a set of triggers that require review outside of that cycle.
For new mines, the MSMS must be reviewed within 12 months of commencing operations. For all mines, a full review must be completed at least once every three years.
Outside of scheduled reviews, a review is required when:
- Operations, technology or working conditions have changed
- A significant incident or near miss has occurred at the mine
- WorkSafe WA directs a review following an inspection or audit
- Audit findings identify gaps in the system
- New hazards are identified that are not covered by existing plans
Your MSMS must also include a procedure for measuring how the system is performing against its own performance standards. The audit system must document the methods used, how frequently audits are conducted and what the results show.
An MSMS that was adequate when it was written may not be adequate now. Changes in site conditions, new equipment or updated regulations can all create gaps that a document review would catch.
Do You Need a Specialist to Build or Review Your MSMS?
Not every mine operator has the internal capacity to develop, implement and audit a compliant MSMS. This is particularly true for smaller operators, new mines and businesses transitioning from an older SMS framework predating the 2022 regulations.
Specialist support is typically required when:
- You are opening a new mine and need a compliant MSMS before operations start
- A WorkSafe inspection or audit is approaching and you are not confident in your current system
- An incident has occurred and your MSMS is under scrutiny
- Your existing system was not built to the WHS (Mines) Regulations 2022 standard
- You have PMHMPs that have not been reviewed against the July 2025 WorkSafe WA guidance
A specialist should assess what you have, identify the gaps, update or develop the documentation and then help you put it into practice on site. A document that sits in a folder is not a functioning MSMS.
If you’re not sure whether your current system meets the requirements of Western Australian legislation, a gap assessment is the right place to start. Safetec Group’s mining WHSEQ consultants work alongside your team on site, not just on paper. Get in touch to book an initial consultation.
Frequently Asked Questions
What Is The Difference Between An SMS & An MSMS?
A safety management system (SMS) is a general workplace safety framework that can apply to any industry. An MSMS is a mine-specific version required by the WHS (Mines) Regulations 2022. The key difference is that an MSMS must include mining-specific components, including Principal Mining Hazard Management Plans, that a generic SMS is not designed to address. A standard SMS cannot be a substitute for an MSMS, even if it’s well developed.
Is An MSMS Required For Exploration Sites In WA?
Yes. The WHS (Mines) Regulations 2022 apply to all mining operations in WA, including exploration sites. The duty to establish and implement an MSMS is not limited to active production mines. If your operation involves exploring for minerals, you need an MSMS in place before work commences.
How Often Does A Mine Safety Management System Need To Be Reviewed?
At minimum, a full review is required every three years. New mines must complete a review within 12 months of commencing operations. Outside of these scheduled reviews, the MSMS must also be reviewed following significant incidents, changes in operations or technology, regulator direction or when new hazards are identified.
What Happens If A WA Mine Doesn’t Have A Compliant MSMS?
Non-compliance with the WHS (Mines) Regulations 2022 is a breach of the WHS Act 2020. WorkSafe WA has the authority to issue improvement notices, prohibition notices and to commence prosecution under the Act. The pattern of non-compliance identified ahead of the March 2024 deadline made clear that WorkSafe is actively inspecting mine sites and taking compliance seriously.
Next Steps
An MSMS is a legal requirement, not a best-practice aspiration. Generic documents do not satisfy the obligation under current Work Health and Safety legislation.
The most common failure is not the absence of a document. It is a document that was never properly deployed on site, or one that no longer reflects the actual hazards and operations at the mine.
If your system has not been reviewed recently, or if it was developed before the WHS (Mines) Regulations 2022 came into force, now is the right time to address it. Safetec Group works with mine operators across Western Australia to develop, implement and audit compliant MSMS frameworks. To book a gap assessment for your site, contact the WHSEQ specialists at Safetec today.
