MHSA Maintenance Requirements: A Guide for South African Mines

Maintenance managers at South African mines carry a dual burden: keeping equipment running and ensuring every inspection, service, and record satisfies the Mine Health and Safety Act. Miss a statutory due date or lose a certificate, and the consequences extend far beyond downtime. Understanding MHSA maintenance requirements is not optional; it is the baseline for operating legally and safely.

This guide sets out what the MHSA and its regulations require of employers in relation to equipment, machinery, rescue preparedness, and record-keeping. It is written for maintenance and safety personnel at gold operations in Gauteng, platinum mines in Limpopo and the North West, coal operations in Mpumalanga, and other mineral sectors. Whether you are tightening existing processes or building compliance from scratch, the following sections give you a clear reference and a path to audit-ready maintenance.

Overview of the Mine Health and Safety Act 29 of 1996

The Mine Health and Safety Act (Act 29 of 1996), as amended, is the primary legislation governing health and safety at mines in South Africa. It applies to all mines and works as defined in the Act, including underground and surface operations, and places broad duties on employers, employees, and other duty holders.

The Act is supported by regulations that spell out detailed requirements. These cover machinery and equipment, explosives, ventilation, emergency preparedness and rescue, personal protective equipment, and the maintenance of systems that affect health and safety. For maintenance teams, the most relevant areas are those that impose statutory maintenance — work that must be done at defined intervals or to a defined standard, with evidence kept for inspection.

Compliance is enforced by the Department of Mineral Resources and Energy (DMRE), formerly the Department of Mineral Resources (DMR). Inspectors may visit at any time, request records, and examine equipment. Non-compliance can result in improvement notices, fines, and in serious cases prosecution. For maintenance managers, the takeaway is simple: the Act does not distinguish between “safety maintenance” and “production maintenance” when it comes to obligations. If it is safety-critical or legally required, it must be scheduled, executed, and recorded.

The Act also establishes a tripartite framework involving the employer, the state (DMRE), and organised labour. Health and safety committees and representatives have the right to access information and to participate in risk assessment and compliance reviews. Maintenance records and statutory registers are therefore not only for the inspectorate; they support internal oversight and worker representation. Keeping MHSA maintenance requirements visible and up to date is part of the duty of care and of the collaborative safety culture the Act envisages.

Employer Obligations for Equipment and Machinery

Under the MHSA, the employer (the mine owner or the holder of the right to mine) has a general duty to ensure that the mine is designed, constructed, and operated so that employees are not exposed to undue risk. This duty extends directly to machinery and equipment.

Employers must ensure that:

All machinery and equipment used at the mine are suitable for the purpose and maintained in a safe working condition.
Machinery and equipment are inspected, tested, and maintained in accordance with the manufacturer’s specifications or an equivalent standard, and in line with any regulatory requirements.
Defects that could affect health or safety are identified and rectified before the equipment is used, or the equipment is taken out of service until repaired.
Only competent persons perform maintenance, repairs, and inspections where the work could affect safety.

What “maintained in a safe working condition” means in practice is often defined in the regulations and in mine-specific codes of practice. For example, winding equipment, conveyor systems, ventilation fans, and electrical installations typically have prescribed inspection and testing frequencies. Employers must not only do the work but also keep records that demonstrate it was done, by whom, and when.

Statutory Maintenance Requirements Under the MHSA

Statutory maintenance under the MHSA and its regulations is maintenance that is required by law at a set frequency or to a set standard. It is non-negotiable. Common areas include:

Winding and rope systems: Regular examination and testing of winding ropes, conveyance equipment, and braking systems as per the applicable regulations.
Pressure equipment and boilers: Inspection and certification by approved bodies at intervals specified in the regulations.
Electrical installations: Testing and inspection of earthing, protection, and hazardous-area installations in line with mine electrical standards.
Ventilation systems: Inspection and maintenance of fans, doors, and controls to ensure adequate airflow and gas management underground.
Firefighting and emergency equipment: Servicing of fire suppression systems, fire doors, and emergency escape equipment.

Mines often maintain a statutory register or equivalent that lists every item subject to statutory maintenance, the required frequency, the last completion date, and the next due date. This register is one of the first things inspectors ask to see. Missing or overdue items are a red flag and can lead to enforcement action.

The exact frequencies and standards depend on the type of equipment and the applicable regulation. For winding ropes, for example, regulations typically require regular measurement and examination, with discard criteria based on wear, broken wires, and loss of diameter. For boilers and pressure vessels, periodic examination by an approved inspection authority is standard. Electrical installations in hazardous areas may require periodic insulation and earth-fault testing. Gold mines in Gauteng with deep-level winding systems, platinum operations in Limpopo and the Bushveld, and coal mines in Mpumalanga each have site-specific risk profiles, but the principle is the same: identify every statutory task, schedule it, complete it, and record it. A single overdue statutory item can be enough for an inspector to question the adequacy of the mine’s maintenance management system.

Self-Contained Self-Rescuer (SCSR) Maintenance and Testing Requirements

Self-contained self-rescuers (SCSRs) are critical life-saving devices carried by underground workers. They provide breathable air for a limited time during an emergency such as fire or smoke. The MHSA and regulations impose strict requirements on their supply, storage, maintenance, and testing.

Employers must ensure that:

Every person who may need to use an SCSR has access to one that is in date and in good working order.
SCSRs are stored and maintained in accordance with the manufacturer’s instructions and any regulatory requirements.
Regular inspections and tests are carried out at the intervals specified (often monthly visual checks and periodic functional or bench tests).
Expired or defective units are removed from service and replaced; they must not be issued or carried underground.

Record-keeping for SCSRs is especially important. Inspectors will expect to see evidence of issue and return, inspection dates, test results, and replacement of units that have reached the end of their service life. Many mines track SCSRs by serial number and due date. Letting even a small number of units go past their inspection or expiry date can put lives at risk and expose the mine to serious liability and prosecution.

Chapter 16 Rescue Requirements (Including March 2025 Amendments)

Chapter 16 of the MHSA regulations deals with emergency preparedness and rescue. It requires mines to have rescue teams capable of responding to incidents underground. In March 2025, amendments to the rescue provisions came into effect, tightening team composition and availability.

Key requirements under the updated Chapter 16 include:

Rescue team size: A minimum eight-member rescue team per mine (or per shaft/area as specified in the regulations).
Readiness: At least six members of the team must be readily available to respond at any time. This means they are on site or can reach the mine within the time set in the mine’s emergency plan.
Blasting competency: At least two members of the rescue team must hold the required blasting certificates so that the team can safely deal with explosives-related emergencies or barriers.
Scaling by underground headcount: The number of rescue teams and/or members may need to scale with the number of persons ordinarily underground. Larger operations must ensure sufficient rescue capacity to cover all working areas within the required response times.

These changes place a direct burden on mine management to roster, train, and maintain enough qualified rescue personnel. “Readily available” is typically defined in the mine’s emergency preparedness plan: it may mean on site during production shifts or within a defined response time (e.g. 30 to 60 minutes) for call-out teams. Mines with multiple shafts or large underground headcounts must scale rescue capacity accordingly so that every working area can be reached within the required time. From a maintenance perspective, the equipment used by rescue teams — breathing apparatus, communication devices, first-aid and rescue kits — must also be maintained and certified. Rescue team equipment is often included in the same statutory or compliance register as other safety-critical assets so that servicing and expiry dates are never missed.

Record-Keeping Obligations

The MHSA and regulations require employers to keep records that prove compliance. For maintenance, this typically includes:

Inspection and test records: What was inspected, when, by whom, and what was found (defects and corrective actions).
Maintenance and repair records: Work done on machinery and equipment, including parts replaced and approvals where required.
Certificates and reports: Certificates from approved inspection bodies (e.g. for pressure equipment, ropes) and any reports required by regulation.
Training and competency records: Evidence that persons performing safety-critical maintenance are trained and deemed competent.
SCSR and rescue equipment records: As noted above, issue/return, inspection, testing, and replacement.

Records must be readily available for inspection by the DMRE and by health and safety representatives. They are usually required to be kept for a minimum period (often several years) after the activity. Poor or missing records are treated as evidence that the work was not done. In the event of an incident, the absence of maintenance records can be used against the mine in enforcement or civil proceedings.

The regulations do not generally prescribe a specific format: records may be kept on paper or in electronic form, provided they are legible, retrievable, and retained for the required period. Many mines have moved to electronic maintenance and compliance systems to avoid lost or illegible paperwork and to simplify reporting. Whatever the format, the content must support an audit: who did what, when, and what was the outcome. Sign-offs, dates, and unique identifiers (e.g. work order or inspection reference) make it easier to satisfy an inspector and to defend the mine if a claim or prosecution arises.

DMR Inspections and What Inspectors Look For

The DMRE (historically the DMR) conducts routine and incident-driven inspections at mines. Inspectors have the power to enter the mine, examine documents, and inspect equipment and working places.

During an inspection, they commonly:

Request the statutory maintenance register or equivalent and check that due dates are being met.
Ask for maintenance and inspection records for specific items (winders, ropes, SCSRs, ventilation, electrical).
Verify that certificates (e.g. for pressure equipment, lifting equipment) are current and that no expired or defective equipment is in use.
Check that rescue teams meet the Chapter 16 requirements (number, availability, blasting competency, scaling).
Look for defects or unsafe conditions that suggest inadequate maintenance or inspection.

Inspectors may issue improvement notices requiring the mine to remedy non-compliance within a set time, or prohibition notices stopping certain activities until the risk is controlled. They can also gather evidence for prosecution. A typical inspection may start with a request for the statutory register and recent maintenance records; the inspector may then cross-check by asking to see specific assets or certificates. Follow-up inspections are common after improvement notices to verify that corrective actions were completed. Preparation is therefore essential: knowing your next due dates, having records in one place, and being able to produce them quickly reduces friction and demonstrates a serious approach to compliance.

Penalties for Non-Compliance

Non-compliance with the MHSA and its regulations can result in:

Administrative enforcement: Improvement and prohibition notices, with possible closure of part or all of the mine until compliance is achieved.
Fines: The Act provides for substantial fines for contraventions. Amounts can be significant for corporate employers.
Imprisonment: Certain serious contraventions can result in imprisonment for responsible individuals, including managers and directors where negligence or recklessness is shown.
Reputational and operational impact: Incidents linked to poor maintenance attract media and stakeholder attention and can affect licensing, insurance, and community relations.

Maintenance managers who ensure that statutory work is scheduled, completed on time, and properly recorded help protect both workers and the organisation from these outcomes. Mine safety compliance in South Africa has come under increased scrutiny in recent years, and the DMRE has emphasised the link between disciplined maintenance and incident prevention. Treating MHSA maintenance requirements as a core business process, not an administrative afterthought, is the foundation of a defensible position in the event of an inspection or incident.

How a CMMS Helps Mines Stay MHSA-Compliant

A Computerised Maintenance Management System (CMMS) built for South African mining can centralise MHSA-related maintenance and records, reducing the risk of missed due dates and lost certificates.

Automated scheduling: Statutory and compliance tasks can be set up as recurring work orders with fixed frequencies (e.g. monthly SCSR checks, quarterly rope examinations). The system generates work orders in advance so that nothing falls through the cracks when shifts and workloads change.

Inspection templates: Standardised checklists for SCSRs, rescue equipment, ventilation, and other safety-critical assets ensure that every inspection covers the same points and that results are captured in a consistent format. This supports both quality and auditability.

Certificate and expiry tracking: Certificates for pressure equipment, lifting equipment, SCSR service life, and similar can be recorded with expiry dates. The CMMS can trigger expiry alerts (e.g. 30 or 60 days before due) so that recertification or replacement is planned in time.

Audit-ready reports: When an inspector asks for the statutory register or for records of inspections and tests, reports can be generated from the CMMS showing due dates, completion dates, and responsible persons. This avoids last-minute searches through spreadsheets or paper files.

Offline capability for underground operations: Many mines have limited or no connectivity in working areas. A CMMS that supports offline use allows technicians to capture inspections and work done underground and sync when back on the surface, so that compliance data is complete and up to date even where connectivity is poor.

Integrating the CMMS with existing mine systems (e.g. asset registers, HR for competency, or procurement for spares) can further reduce duplication and ensure that statutory and compliance tasks are aligned with the same asset and person data that the rest of the operation uses.

Lungisa is an industrial CMMS designed for South African operations, including mining. It supports work orders, asset and spare-parts management, compliance tracking, and offline capability. For mines aligning maintenance with MHSA maintenance requirements, Lungisa offers mining-focused maintenance templates and workflows that can be tailored to statutory schedules, SCSR tracking, and rescue-equipment maintenance. If you would like to see how a structured CMMS can help your mine meet MHSA maintenance requirements and prepare for DMR inspections, you can contact the Skynode team or explore Lungisa’s mining maintenance templates to get started.