
Inspectors Target RS22 Compliance: Are Your Risk Owners Covered?
30 April 2025
Queensland coal mines are under increasing scrutiny, with Resources Safety and Health Queensland (RSHQ) inspectors intensifying their focus on compliance with Recognised Standard 22 (RS22). During April, several sites were issued Substandard Condition or Practice (SCP) notices, and in some cases, Directives—highlighting the urgent need for compliance around management structures and Risk Owner competencies.
What's Driving Enforcement?
Inspectors are zeroing in on the accuracy and appropriateness of Management Structure documents, with specific focus on:
Whether listed senior personnel match those actually in position.
The suitability of stated competencies for Risk Owners.
The existence of documented Competency Gap Plans where required competencies are not yet held.
One coal mine was recently directed to cease operations in a key area until it could demonstrate that the Risk Owner held appropriate qualifications—underscoring the serious consequences of non-compliance.
How My Competency Expert Can Help
My Competency Expert provides tailored support to help coal mines meet RS22 obligations with confidence. Our solutions align with the Coal Mining Safety and Health Act (CMSHA), including:
Keeping your Management Structure up to date and compliant with RS22, s.65/66 requirements for notification..
Identifying and verifying RII-based competencies at AQF Level 6 relevant to Material Unwanted Events.
Developing and documenting Competency Gap Plans for Risk Owners who need additional qualifications or experience.
Take Action Now
We recommend all Site Senior Executives (SSEs) and delegated Risk Owners:
Review their current Management Structure documentation.
Ensure all updates are reflected in the Mine Record and submitted within the required timeframes.
Confirm that Risk Owners possess the right competencies—or have an actionable gap plan in place.
Competency doesn't always come from formal training alone. We suggest SSEs consider on-the-job experience, mentoring, and SME delegation as valid components of a well-rounded Competency Gap Plan.
Don’t risk non-compliance—contact My Competency Expert today for help to ensure your site meets RS22 requirements with clarity and confidence.