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Dalrymple Bay Coal Terminal (DBCT) is a key player in the world’s global coal export market and is critical to the economic prosperity of Queensland and Australia. With an uncompromising dedication to ensuring the safety of its people and the surrounding community, coupled with an unparalleled persistence to achieve operational excellence, DBCT has been reliably exporting coal to at least 30 countries for more than 25 years.
Given the size and nature of the business, delivering a healthy and safe workplace and ensuring compliance with all obligations is an onerous task. Failure to do so could result in death, prosecution and significant damage to reputation. With this in mind DBCT's drivers for establishing a risk and compliance management system for their safety, health and environment (SH&E) obligations were:
- Their capacity to determine and keep obligations current
- Having an appropriate procedure for each obligation to facilitate health and safety and ensure compliance
- Addressing management concern about SH&E
- Ability to drive ownership of SH&E obligations and tasks down to the site level
- Adequately and easily remain informed of SH&E compliance status
- Ensuring that the process is efficient and effective
Achieving the ‘Closed Loop’
To have the confidence that everything is being done to deliver the desired outcomes, DBCT recognized that they needed to develop a ‘closed loop system’ for SH&E compliance.
Determining their key objective as ensuring site level staff are aware of their SH&E compliance obligations and 'own' the tasks associated with effectively managing these risks resulted in the following process.
1. Establish and maintain a SH&E compliance obligations register
2. Develop task, workflow and escalations for each obligation
3. Automate workflow and reporting through governance, risk and compliance (GRC) software 4. Audit procedures against obligations to assess the gaps
5. Align and develop procedures for each obligation
6. Incorporate procedures into workflow solution.
This approach allows DBCT to ensure they are aware of all their SH&E compliance obligations and effectively communicate and monitor the tasks from site to senior staff, generating effective reporting on SH&E compliance for management.
A key driver in choosing this process was DBCT’s need to quickly know, communicate, act and report on their compliance with SH&E obligations.
Download the SHE Closed Loop Diagram
Establishing a complete SH&E Obligations Register
Previously DBCT maintained a ‘Legislative Register’ document with links to various acts and regulations. Manual updating presented the risk of the register being out-of-date and incomplete, while legislation updates distributed in legal prose increased the risk of misinterpretation.
Company lawyers deemed the register inadequate, not confident it demonstrated they had determined their applicable statutory and regulatory obligations. SAI Global was engaged to develop a SH&E Compliance Obligations Register for DBCT.
The SH&E Compliance Obligations Register lists and summarizes DBCT’s legal obligations based on relevant Queensland and Commonwealth Acts, Regulations, Codes of Practice and Australian Standards; and comprises:
- Up to 145 Obligations Registers based upon well defined business processes
- Navigation and Access Framework to acts and regulations, cited codes of practice, cited AS/NZS Standards and sites of regulators and industry bodies and other guidance materials.
DBCT also sought legal advice to assist with risk rating their obligations for each business process to support prioritization for addressing these.
Keeping the Register current and up to date
With up to 1,500 SH&E compliance obligation changes to keep track of annually (averaging approximately 30 per week) it was logical for DBCT to outsource the responsibility of updating their SH&E Compliance Obligations Registers. SAI Global now provides an updated register to DBCT each month to maintain currency and accuracy, ensuring they are always up to date with their latest SH&E compliance obligation requirements.
Systemizing what was previously an in-house, manual process and entrusting the responsibility to experts at SAI Global who are regularly monitoring relevant jurisdictions and regulators gives DBCT the confidence that their register is complete and up to date. A major benefit of the SAI Global approach is the mapping of each obligation to 145 business processes and 20 job roles, allowing DBCT to quickly determine what needs to be done and by whom to assure compliance. Legal lingo becomes actionable tasks at site level so staff can take ownership of obligations and risks, delivering effective compliance throughout the organization.
Risk ownership and reporting
A need to map obligations to tasks at site level and assign ownership, while ensuring that tasks are updated when there are new or changed obligations drove DBCT to choose SAI Global’s GRC software. SAI Global’s GRC Platform provides a comprehensive, enterprise wide tool for monitoring and reporting their compliance status and delivers a structured repository of obligations, policies, internal controls and tasks, enabling DBCT to establish a single integrated compliance framework.
With inbuilt workflow and risk assessment capabilities DBCT can now:
- Assign actions to individuals in the form of tasks
- Track actions and automatically escalate upon the lapse of due dates
- Access a complete SH&E obligations compliance audit trail, on demand
- Drive a risk focused compliance process, incorporating control self assessments, compliance tasks and remediation of compliance breaches and issues
- Have real-time oversight of their compliance position and emerging ‘hot spots’
- Provide readily available, intuitive dashboards and reports to executives and the Board
Where are we now?
DBCT are now working with a complete, current SH&E Compliance Obligations Register that is updated regularly by SH&E compliance experts. Each obligation is mapped to relevant business processes and job roles, with actions and responsibilities easily defined for staff at all levels of the business. Integrating this with SAI Global’s GRC Platform enables DBCT to assign these actions and responsibilities as tasks to the relevant staff; while workflow triggers, escalations, tracking and reporting allows management to stay on top of their compliance status and identify any emerging issues promptly. Most importantly, a culture of compliance and responsibility for SH&E obligations is established throughout DBCT, with all employees, from site level to senior management, playing an important part in DBCT’s SH&E compliance and risk management program.
Download the Dalrymple Bay Coal Terminal Case Study now