Removing scrap from a mine site is not the same as collecting material from a workshop or construction project.
Mine sites are high-risk environments, and mining waste is high-risk material. Not every scrap collector is qualified to step foot on site – let alone handle hazardous materials or transport controlled waste.
Engaging an unlicensed contractor can have serious consequences for safety, compliance, cost and reputation. And as the mine operator, you remain legally responsible for safety on site.
So, is your scrap collector licensed for mine sites? It’s not a question to take lightly.
Why a Scrap Collector’s Licenses Matter for Mine Operators
Under the Work Health and Safety Act 2020 and the Work Health and Safety (Mines) Regulations 2022, the Person Conducting a Business or Undertaking (PCBU) bears the ultimate responsibility for health and safety.
Contractors and mining companies share the workspace, and therefore the responsibility.
- The contractor is a PCBU for its work and workers
- The mine operator is also a PCBU with duties specific to the site
The mining company is not automatically responsible for every detail of the contractor’s specialist work, but it remains responsible for:
- Managing site risks
- Establishing and implementing the mine safety management system (MSMS)
- Integrating contractor work into the MSMS
- Assessing and monitoring contractor arrangements
A PCBU cannot “contract out” of their responsibility, and a duty cannot be transferred to another person. Engaging a contractor does not shift the operator’s obligation onto them or vice versa.
Important Credentials in Mine Demolition and Scrap Collection
Mine decommissioning and demolition are complex projects. Heavy machinery, restricted areas, moving vehicles, isolation zones, fatigue risks and permit systems all need to be managed properly.
That means when you ask whether a scrap collector is licensed for mine sites, you’re checking a stack of credentials rather than a single ticket.
Site Access
A collector can’t work your site until its crews can demonstrate they’ll operate inside your documented safety systems.
A standardised induction such as MARCSTA is a good start, supplemented by site-specific safety training.
Our tip: Keep detailed induction records and ask the scrap collector to send the same crew back, so you don’t need to induct new people for every project.
Fatigue Compliance
Fatigue is a recognised psychosocial hazard under WA law, and PCBUs have a duty to control it.
A reputable contractor will have a fatigue management policy and workers who take responsibility and show up fit for work.
Your role as the mine operator is to manage fatigue site-wide:
- Designing rosters with enough rest between shifts
- Scheduling sufficient breaks throughout the shift
- Providing adequate on-site rest areas
- Training crews to manage fatigue
- Rostering enough staff to avoid understaffing
- Setting manageable, realistic deadlines
Collaboratively, you will develop a Fatigue Risk Management System (FRMS) that covers all workers on site, including contractors.
Our tip: Seek proactive input on an FRMS to ensure all risks are addressed.
Transport and Dangerous Goods
Heavy or awkward loads may need oversize or overmass approvals and certified load restraints.
The moment batteries, hydrocarbon-contaminated steel, or other hazardous material enters the load, a Dangerous Goods licence is mandatory. The consignment must be classified, packaged and documented correctly.
A collector without DG capability either can’t take those streams or moves them non-compliantly. Both expose you as the mine operator to compliance risks.
Our tip: Request proof of Main Roads WA approvals. Some are single-trip, so you may need to ask each time.
Controlled Waste Handling
Contaminated and hazardous streams can only be transported by a carrier holding DWER (Department of Water and Environmental Regulation) controlled waste handling authorisation.
Downstream, controlled waste like batteries, oily components and contaminated metals must be handled through EPA-approved recycling or disposal pathways.
Failing to meet these requirements – or not retaining proof – could put you at risk of an illegal dumping allegation.
Our tip: Keep detailed chain-of-custody records and copies of Controlled Waste licenses to support traceability and Scope 3 reporting.
ISO Certification
ISO certification isn’t legally mandatory, but it’s a clear sign of a collector that runs disciplined systems. Look for:
- 45001 (Safety)
- 14001 (Environment)
- 9001 (Quality)
JAS-ANZ accreditation is an additional mark of confidence. It confirms that those ISO certificates were issued by an independent, recognised body.
Our tip: Ask to see current certificates and check the scope covers mine site and hazardous material work, not just yard operations.
Insurance
Public liability, workers’ compensation and environmental damage cover should all be current and verifiable before a vehicle reaches your gate.
Environmental damage cover is the one most often missing and the one that matters most on a mine site.
Our tip: Before work begins, ask for certificates of currency and confirm the cover is suitable for the scope, site and materials being handled.
How to Verify Your Scrap Collector’s Credentials
Don’t take “we’re fully compliant” at face value. Ask for the paperwork to prove it:
- Licence numbers and tickets: Waste transport permits, mine-access inductions, DG licensing.
- Safety documentation: Safe Work Method Statements (SWMS), Standard Operating Procedures (SOPs) and project-specific risk assessments.
- Chain-of-custody reporting: Weight dockets, recycling certificates and proof of downstream processing at accredited facilities.
- On-site capability: PPE standards, lifting equipment and vehicle condition.
In many cases, you will need to keep documents handy in case of an audit or incident.
The Risks of Getting It Wrong
Using an unlicensed or underqualified scrap collector can expose operators to compounding risks.
Issue |
Risks |
|
|
|
|
|
|
The chain-of-custody gap is the one most scrap collectors on mine sites will miss. Even if the metal is genuinely recycled, without weight dockets, recycling certificates and documented downstream processing, the recovery is unreportable. There is no Scope 3 emissions value regardless of where the material actually ends up.
Scrap Metal Is Not Just Waste
Scrap metal is often treated as a disposal problem. In reality, it can be a valuable recovery opportunity.
Steel, copper, aluminium, stainless steel, batteries and cabling can all carry commercial value:
- Revenue to offset clean-up costs
- ESG and Scope 3 reporting data
- Advance towards rehabilitation milestones
- Contribute to WA’s circular economy
Of course, all of this depends on proper sorting, collection, transport and processing.
Why C.D. Dodd Is the Safe Choice in Mine Site Scrap Collection
C.D. Dodd has spent more than 50 years recovering material from mining, industrial and offshore oil and gas environments.
When you partner with us, you never need to ask, “Is our scrap collector licensed for mine sites?”
We continuously invest in our mine site clean-up and recycling services to support operators around the state. All our work is backed by industry-leading certifications and standards:
- ISO 45001, 14001, and 9001 certification
- DWER Controlled Waste transport licensing and Dangerous Goods capability
- Fully qualified crews
- Multiple processing facilities in WA (Perth, Kalgoorlie, Karratha and Port Hedland)
- Specialist equipment and vehicles for controlled waste transport and mine site decommissioning
From hazardous waste removal in active operations to mine site decommissioning and demolition, scrap metal and battery recycling, hazardous waste handling and chain-of-custody reporting, we help mining companies reduce risk, recover value and meet their compliance obligations.
Contact C.D. Dodd to discuss your scrap collection challenge or mine site decommissioning project.