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Mining Safety 9 min read Published 16 June 2026

MHSA 8.10.1 collision prevention for trackless mobile machinery

By Frank Guo · Technology & Product Leadership, addanode

TL;DR — Under Mine Health and Safety Act regulation 8.10, South African mines must prevent collisions between trackless mobile machinery (TMM) and between TMM and pedestrians. The key sub-regulations (8.10.1.2(b) and 8.10.2.1(b)) requiring automatic machine intervention came into force on 21 December 2022, and the benchmark is the EMESRT Level 9 control: a system must detect a person or vehicle, warn both operator and pedestrian, and — if no one acts — intervene on the machine itself to slow and brake it. Compliance is a proximity detection system (PDS) integrated into the TMM controls, plus monitoring and reporting. Choose detection technology proven for your environment (underground dust, curves, metal), integrate the intervention layer, and log every event for the inspectorate.

What the regulation actually requires

Regulation 8.10 of the Mine Health and Safety Regulations places a duty on every mine to take reasonably practicable measures to prevent persons being injured by collisions — TMM-to-TMM and TMM-to-pedestrian. The step that changed the market is the requirement for automatic machine intervention: sub-regulations 8.10.1.2(b) and 8.10.2.1(b) became effective on 21 December 2022. For underground diesel-powered TMM, the machine must automatically detect a pedestrian in its vicinity, warn both the operator and the pedestrian, and — critically — if no action is taken, provide further means to retard the machine to a safe speed and then automatically apply the brakes.

That last clause is the whole game. A system that only beeps is no longer enough. The law now expects the machine to act when a human doesn't.

The bar in one line: detect → warn → intervene. If a vendor's system stops at "warn" (lights and alarms), it does not meet the EMESRT Level 9 intervention requirement that regulation 8.10 is built around. Insist on the machine-intervention layer.

EMESRT Level 9 — the standard behind the law

The regulation is underpinned by the Earth Moving Equipment Safety Round Table (EMESRT) nine-level control hierarchy. Levels 1–8 cover site design, training, operating procedures, awareness and warning. Level 9 is the intervention control: an automated machine response that prevents the unsafe interaction when every prior control has failed. South Africa's adoption of Level 9 into law is what obliges mines to fit a proximity detection system (PDS) capable of actually controlling the machine, not just alerting the operator.

Understanding the hierarchy matters because compliance isn't only a box of electronics — it's the full stack: good traffic management and training (the lower levels) plus a working PDS intervention (Level 9). A mine that buys the hardware but neglects the procedures around it is exposed; so is one with great procedures and no intervention layer.

The sub-regulations, side by side

Sub-regulationInteractionRequired responseIn force
8.10.1.2Underground diesel TMM ↔ pedestrianAutomatic detection; effective warning to both operator and pedestrian21 Dec 2022 (sub-para (b))
8.10.2.1Diesel TMM ↔ diesel TMMAutomatic detection; if no action, automatic retard to safe speed then brakes applied — fail-safe, no human intervention21 Dec 2022 (sub-para (b))
EMESRT Levels 1–8All interactionsSite design, traffic management, segregation, training, procedures, awareness, warningOngoing — the lower levels the regulation assumes are in place
EMESRT Level 9Machine ↔ person / machineIntervention: the machine itself acts when earlier controls have failedThe bar 8.10.2.1 is written to
A warning is not an intervention The cheapest proximity product warns and stops there, which is the response one sub-regulation asks for. The sub-regulation written to EMESRT Level 9 asks for something else: when earlier controls have failed and nobody reacts, the machine itself acts. That requirement is what forces integration with the vehicle's controls, and it is where projects most often underestimate the work. A warning-only system A system written to Level 9 What happens when nobody reacts Nothing further. The warning was the whole function The machine retards to a safe speed, and then the brakes are applied Which sub-regulation it can satisfy 8.10.1.2, where the required response is an effective warning to both parties 8.10.2.1, where the response must be fail-safe and require no human intervention What it has to be connected to An alarm, a light, a buzzer The machine's own controls — the engineering most projects underestimate What the lower EMESRT levels are for Still required: the regulation assumes they are already in place The same, and this sits on top of them rather than instead of them What the log has to show A detection Every detection and every intervention, reportable to the inspectorate What a drifting calibration means A missed warning A compliance failure and a safety failure at the same time
A warning is not an intervention One warns and stops there; the other acts when nobody reacts. What happens when nobody reacts Warning only Nothing further. The warning was the whole function Written to Level 9 The machine retards to a safe speed, and then the brakes are applied Which sub-regulation it can satisfy Warning only 8.10.1.2, where the required response is an effective warning to both parties Written to Level 9 8.10.2.1, where the response must be fail-safe and require no human intervention What it has to be connected to Warning only An alarm, a light, a buzzer Written to Level 9 The machine's own controls — the engineering most projects underestimate What the lower EMESRT levels are for Warning only Still required: the regulation assumes they are already in place Written to Level 9 The same, and this sits on top of them rather than instead of them What the log has to show Warning only A detection Written to Level 9 Every detection and every intervention, reportable to the inspectorate What a drifting calibration means Warning only A missed warning Written to Level 9 A compliance failure and a safety failure at the same time
The two rows of the table above, read as products rather than as clauses. A warning-only box satisfies one sub-regulation and not the other — and the difference is an integration into the machine's own controls, which is the part most often underestimated.

The compliance path (step by step)

  1. Risk-assess your TMM interactions. Map every place machines and people meet — tips, loading bays, ramps, intersections, travelways — and rank the collision risk, surface and underground.
  2. Specify to EMESRT Level 9. Write the detect–warn–intervene requirement into your specification so vendors are measured against the law, not against the cheapest "warning-only" box.
  3. Choose detection proven for your environment. Underground is brutal on sensing — dust, water, curves, dips, and metal that reflects and confuses signals. Detection that works on a clean open-pit haul road may misbehave in a stope. Demand evidence from comparable conditions.
  4. Integrate the machine-intervention layer. The PDS has to talk to the TMM's controls so it can retard and brake the machine. This integration with the vehicle is where many projects underestimate the engineering — plan for it.
  5. Add monitoring, logging and reporting. Every detection and intervention event should be logged and reportable — both to prove compliance to the inspectorate and to learn where your real risk hotspots are.
  6. Train, trial and maintain. Run a trial section, train operators and pedestrians (false confidence is its own hazard), then maintain and audit the system. A PDS that drifts out of calibration is a compliance and safety failure waiting to happen.

How to choose a system that actually works

  • Does it intervene, or only warn? Level 9 means the machine acts. This is the single most important question.
  • Is it proven in your conditions? Underground dust and geometry break naive detection. Ask for results from a mine like yours, not a brochure render.
  • Does it produce compliance evidence? You need event logs and reports, not just an in-cab buzzer, to demonstrate due diligence.
  • Can it integrate with your fleet and your other safety/monitoring systems? A PDS that feeds the same platform as your person-location and occupational-hygiene monitoring gives you one safety picture, not three silos.
  • Is it supported locally? A safety-critical system needs fast local support and maintenance — not a vendor a continent away.

This is core to how addanode approaches mining operations optimisation: MHSA-aligned collision prevention and proximity detection, integrated with the machine and feeding a monitoring layer that logs every event for compliance and risk analysis. Because we build both the hardware and the addaNet platform in-house and support it locally, collision prevention can sit alongside person-location and occupational-hygiene data in one picture — and it's engineered for real South African underground conditions, not imported assumptions.

This guide summarises the regulatory framework for orientation; always confirm current requirements and effective dates against the latest Mine Health and Safety Regulations and your appointed legal and safety advisers.

Frequently asked questions

What does MHSA regulation 8.10 require for collision prevention?

It requires mines to take reasonably practicable measures to prevent collisions between trackless mobile machinery and between TMM and pedestrians. For underground diesel TMM, the system must automatically detect a pedestrian, warn both operator and pedestrian, and — if no action is taken — slow the machine and apply the brakes automatically. The intervention sub-regulations became effective on 21 December 2022.

What is EMESRT Level 9 and why does it matter?

EMESRT defines a nine-level control hierarchy for vehicle interactions. Level 9 is the intervention control — an automated machine response that prevents an unsafe interaction when all earlier controls have failed. South Africa's adoption of Level 9 is what obliges mines to fit a proximity detection system that can control the machine, not just alert the operator.

Is a warning-only system enough to comply?

No. A system that only sounds an alarm or flashes a light meets the lower EMESRT levels but not the Level 9 intervention requirement underpinning regulation 8.10 for underground TMM. The machine must be able to retard and brake automatically if no one acts. Always confirm the intervention capability before buying.

Why is underground detection harder than surface?

Underground conditions — dust, water, tight curves, dips and reflective metal surfaces — confuse detection that works fine on an open-pit haul road. Choose proximity detection with proven performance in conditions comparable to your own workings, and trial it in a section before fleet-wide rollout.

Does collision prevention connect to our other safety systems?

It should. Integrating the PDS with a monitoring platform that also handles person-location and occupational-hygiene data gives you one safety picture and one set of compliance reports, rather than three disconnected systems. That also makes it easier to find and act on your real risk hotspots.

Working toward 8.10 compliance?

Tell us your fleet and whether you're surface, underground or both. We'll help you specify a collision-prevention system to the EMESRT Level 9 standard — proven for your conditions and built to produce the compliance evidence you need.

Talk to our Mining Team See the solution →

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