Social License to Operate – Skating on the Razor’s Edge

Introduction – Social License to Operate

There have been several community related Occupational Health related scandals in Western Australia: reference the Lead Contamination problems at the Port of Esperance around 2006/2007 and the more recent issue of lead contamination experienced at the newly opened Perth Children’s Hospital.

The initial response and management of community health related issues is critical in enabling a rapid and professional response.

More critical – is the early and sincere engagement of interested parties for changes and new ventures.

In this case – early engagement was conducted – but it appeared to be a Public Relations exercise.

As the Community crisis evolved – the company appeared to be incompetent at best  or at worst , telling lies.

In both cases referenced above – the outcomes could be classified as an expensive and unmitigated community relations disaster which brought into disrepute Western Australian Government Agencies, Operating Companies and Contractors where the tax payer ends up paying a substantial part of the costs and where companies social licence to operate comes under enormous pressure.

The Crisis Event

We had commissioned our storage and loadout facility at a Western Australian Port and loaded our first copper gold concentrate shipment to a Japanese customer. The news was reported on the front page in the Local WA Town Community Newspaper – something you would normally welcome – but in this case it was a damming article.

Key points of the front page newspaper article:

  • Major spillage of concentrate into the harbour – a dead turtle was seen in the harbour.
  • Large dust emissions during ship loading entering the local community
  • The concentrate had a foul odour – it stank and could be smelt throughout the community
  • Dust and smell posed significant health issues for pregnant women.
  • Women had received advice from their Doctor to avoid becoming pregnant because they thought that the concentrate dust/smell may affect the foetus.

Other compounding issues

  • This was the first shipment of copper gold concentrate and went to a long serving Japanese customer port facility based at Saganoseki which was also a fishing village Port.
  • A State Election campaign was underway
  • The incident had been reported by the local Green Party member to the Western Australian parliament and questions asked of the responsible Government Minister. This person was also the Chair of the local town Environmental Care Committee and worked for the local shire.
  • The Mines Department had raised a formal letter to the Mining company requiring a response to the complaints
  • The responsible Legal Entity – The Port Authority; was subject to relentless pressure from many parties to take affirmative and immediate action.
  • Construction was being undertaken to extend the Port Authority wharf with significant union involvement.
  • There had been previous complaints about the odour when the concentrate was being delivered to the concentrate storage shed.
  • A public community meeting had been held by the company in the previous month to address any issues raised and assure the community that there all issues had been addressed prior to the first Shiploading event.

It was a Public Relations, political and technical disaster and had the potential to shut down the Port Stockpiling and Shiploading operations.

At the time I was located at the mine site which contained the processing plant which produced the concentrate and shipped it by truck to the port.

The mine and processing plant had recently been constructed and commissioned with the overall cost outlay exceeding $1.2 billion.

I had a solid background in Occupational Hygiene being the Ventilation Officer at Tom Price for 11 years and had lived in Pilbara communities for over 23 years, had been a shire councillor for one three-year term, was familiar with the Port and the Town and the “Pilbara Culture”.

Because of the emerging Public Relations crisis, I volunteered to be based at the Port Town to analyse and sort the issues out.

Concentrate Production, Transport, Stockpiling and Ship Loading

  • A copper gold concentrate was produced at the mine, stored on open air concrete loadout pad, loaded by a front-end loader into a triple side tipper road train and transported some hundreds of kilometres to the Port Facility (Classified as a Mine when handling concentrates) which was operated by the Port Authority.
  • The loaded trucks entered the Concentrate Holding Shed and tipped the concentrate into the bunker – where it was picked up by a front end loader and stockpiled in the shed.
  • The shed doors were shut during truck unloading and Shiploading operations. There was a high volume dust extraction and filtering system in the shed which put the shed under negative pressure and prevented dust escape to the outside environment.
  • The Shiploading consisted of a front-end loader loading concentrate from the stockpile into hoppers at end of the shed and onto the Port Facility conveyors and into the ship’s hold via the Port Facility Ship loader.
  • The shed also contained overhead water sprays to maintain correct moisture levels to reduce dust levels and to reduce the potential for a “Concentrate Fire” when it was drying out and exposed to atmospheric oxygen.

The Ever Evolving Plan

The first issue to address was to be as open and honest with the town community on the plan to investigate and solve the issues raised by various parties.

The first meeting was held with the newspaper editorial staff where we met at the local coffee shop. The meeting was interesting for me when the newspaper editor asked if she could bring along other journalists No issue for me, but I ended up meeting with seven staff members who were all women and it had the potential to be a bit intimidating if it was not handled correctly and worse still be reported in the local press again in an adverse manner.

  • It was an open an honest conversation where the staff were advised that the company was investigating the issues and would solve the issues of dust, spillage and odour
  • I was the company technical representative, to live in the town until the issues were resolved.
  • My direct report was named as the official company representative for all press releases, this meeting and other updates I issued to the newspaper were for information only and could not be published. They were assured that they would be updated by me on progress.

The second meeting was with the local community environmental representative. She was also a Greens candidate for the up-coming Western Australia State Government election and worked for the local shire council.

  • I outlined my plan to address the technical issues of dust, spillage and odour. It was received very well where I assured her that she would be updated on progress.

I also met with the Port Authority representatives to outline the plan to address the issues.

The Port Authority was the Legal Entity for the Port Operations which included all our company concentrate handling activities. They had the power to direct the company to cease operations if the need arose.

During this time at the Port, I received a call from our Perth office, that our prime Japanese customer had unloaded the first shipment of concentrate at the Port of Saganoseki, which had an obnoxious smell and stank out the local town. This customer advised they would not buy any more concentrate if the smell problem was not solved and were sending an inspector to Australia to investigate.

I met the inspector at the local airport – and he wanted to go straight to the concentrate shed – which I had predicted as I had worked with Japanese previously when stationed at Dampier Western Australia.

The representative walked along-side the copper concentrate stock pile and requested me to dig out small samples every 10 metres or so, for him to smell. He had smelt about 5 samples and rejected all of them – then came across one sample that did not smell.

I immediately said – “We will provide you with this type of concentrate in the future” and had no idea how to achieve this. This was a “Ballsy” decision – but “He who Dares Wins” most of the time.

Problem Validation and Solving

It was evident that the plant metallurgists at the mine processing plant did not understand why the concentrate was producing the noxious smell and why the concentrate appeared to be reacting and heating up when stored in the stockpile.

We needed to expedite the process – and fast smart decisions were required – to override any opposition.

Carte Blanche authority was given to proceed and make the necessary decisions by the Mine Registered Manager, the Mine Process Plant Manager and the Chief Executive Manager of the Company (based in Melbourne).

I had one direct report – The company WA Commercial Manager.

I needed to engage two well respected and external experts to assist.

The first was an Occupational Hygiene Specialist company who were familiar with copper/nickel / gold concentrates to undertake an Occupational Hygiene Risk Assessment for copper concentrate operations at the Port Facility including trucking, unloading and stockpiling and loading onto ships.

The second was a respected and well-known Doctor who specialised in Occupational Hygiene health issues and again was familiar with copper/nickel gold concentrates and related health issues.

Occupational Hygiene Study – Storage Shed & Wharf


  • High sulphur dioxide concentrations
  • Strong odours of organic decomposition products
  • Very high heat stress conditions
  • High concentrations of diesel combustion products of carbon monoxide, carbon dioxide, nitrogen oxides
  • Moderate to high dust concentrations
  • Obnoxious odour caused by sulphurous compounds

Immediate Conclusions

  • Shed ventilation System is not designed to reduce  odours
  • Insufficient Fresh Air Intake
  • Need to wear respiratory protection in the Shed
  • The upper walkway of the Storage Facility should be a permit only area due to high temperatures which were recorded at 61 degrees Celsius.

Technical Solutions

Dust, Odour and Temperature Reduction

  • Increase concentrate pH by adding slaked lime at the mine
  • Reduce and optimise the use of reagents at the mine process plant
  • Manage water content of the concentrate at the mine.
  • Manage top-up water addition at the Port Concentrate Shed
  • Pick up all spillage on the wharf using a road sweeper vacuum truck for each Shiploading event.
  • Repair faulty shed load out chutes and assist the Port Authority to identify and repair wharf conveyor and ship loading spillage points.

The odours were vastly reduced.

Hearts – Regaining Trust – Social License to Operate

We had solved the technical issues but needed to win over the local doctors and influence them to change their opinion on the health affects of the concentrate and associated smell.

The local doctors (mainly males) were regarded as very high up in the town “pecking order” and this also included their wives.

We decided to take out the doctors and their wives and our Occupational Physician to a very lavish dinner at a local restaurant – money was no object.

But in this case the company paid for the dinner, but the invitations were sent out by the CEO of the Port Authority – they were set up to be the “Hero of the Hour” and our company was not to be invited or mentioned “Ever” at all as part of the deal.

I believe that everyone had a very enjoyable time . We  were forgiven.

The doctors changed their mind, the Japanese customer received low odour concentrate and all other parties were satisfied and placated.

It was an amazing “Alice in Wonderland” Adventure, where we were continuously skating on the Razors Edge . It was full of twists and turns, where we were ambushed on several occasions but were able to safely navigate through and solve the issues and did not lose any production.