South Sister St. Marys, Tasmania

South Sister

workplace health and safety

From: David Clement
To: Mr. Steve Manson
Cc: Mr. Graham Wilkinson, EDO, Ms. F. Daily, Mr. M. Polley
Sent: Sunday, February 13, 2005 5:42 PM
[Email addresses redacted]

Subject: Workplace health and safety - Landslide risk at Coupe NI114A - South Sister

Dear Mr Manson,

I would like to confirm that you have been provided with a professional opinion regarding the landslide risk at South Sister, in and around the proposed pulpwood logging coupe NI114A at South Sister, St Marys.

I would like to further confirm that the planning for this coupe recognises the dangers of roading and logging operations near coal mine workings, and that, as a result of the risks associated with such operations, an area of the coupe has been excluded from forest operations over and around the Cardiff Mine workings to the NE of the coupe. This conforms to the requirements of the Forest Practices Code (page 52) that forest practices should 'not result in a significant deviation from natural rates of landslide'.

I also note that Mr Paul Rosevears, Planning Coordinator, Forestry Tasmania, acknowledged on Friday 11th February that in the planning of this coupe Forestry Tasmania had failed to become aware of the existence of another coal mine underlying the coupe, the Jubilee Mine. This failure to obtain basic site information relating to the physical characteristics of the coupe and failing as a consequence to undertake any risk assessment or make provision for the safety of contractors and employees is not only a breach of the Forest Practices Code but is a failure of Duty of Care of such proportions as to constitute negligence.

The Jubilee Mine extends underneath the coupe, and comprises an area of up to 300 acres of abandoned mine workings, full of water, closed due to landslides, roof falls, faulting, and continuous water infiltration, within the context of a geological zone characterised by faults and past landslips, within a rainfall regime of severe rainfall events. Forestry Tasmania intend to carry out road construction and maintenance and logging activities above these workings, involving blasting, ground disturbance, tree felling, heavy machinery, and heavy truck movement, all involving vibration, ground disturbance and ground pressure. The risk of unforeseeable subsidence and landslide is not negligible.

I draw this matter to your attention, in the belief that you should be advising your contractors and employees of the failure of Forestry Tasmania to be aware of this risk, to assess the risk, or to take appropriate steps to address the risks, in the interests of their health and safety.

I look forward to your response.

David Clement