Management at the Port Kembla Coal Terminal were warned of "possible fatalities" almost a year before a truck driver died after beign injured at the plant, according the South Coast Labour Council.
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This led the council secretary Arthur Rorris to call for the removal of the PKCT operations manager and the chairman.
On March 26, truck driver Mark Roberts died, four days after losing a leg when his truck rolled over it while unloading coal at the terminal.
Since then, safety breaches have been identified by SafeWork NSW and health and safety officers from the CFMEU.
One SafeWork breach notice sighted by the Mercury found the location of Mr Roberts' accident put those working "alone and unsupervised" and risk of trips, falls or being hit by moving equipment.
During industrial action in June last year Mr Rorris said a terminal worker who was the health and safety representative emailed PKCT over safety concerns from having "alternate labour" run the site.
"During these periods there were a number of incidents that occurred, some of which could have ended up as possible fatalities," the email supplied by the labour council stated.
If any other worker had done this they would have been summarily dismissed.
- South Coast Labour Council secretary Arthur Rorris
Mr Rorris said this was "disturbing" news that showed workers "forecast the risks very early in the piece".
"This was last year," Mr Rorris said.
"This was ignored by the manager of this workplace. It was also not acted upon by the chair of the board."
Mr Rorris suggested the lack of "appropriate supervision" and maintenance of safety standards led to an increased risk of injury or fatality within the Port Kembla Coal Terminal.
The labour council secretary said this meant those in management needed to go.
"If any other worker had done this they would have been summarily dismissed - we have no doubt about this," he said.
"We say the same standard should apply to the boss.
"Today we are calling for the dismissal, the resignation or the sacking of the general manager of the Port Kembla Coal Terminal Kurt Baumgart and the chair of the Port Kembla Coal Terminal board Mark Smith."
A Port Kembla Coal Terminal spokesperson said "we are continuing to cooperate with SafeWork NSW in relation to the incident. That investigation should be allowed to run its proper course".