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Critical control management

Many mining companies have radically improved their health and safety performance in recent years, as measured by injury frequency rates and other lagging and leading measures.

However, material unwanted events (MUEs) such as underground fires, coal dust explosions, fall of ground and overexposure to harmful substances still occur. Incidents that can lead to debilitating injuries, fatalities or rarer catastrophic events that impact on people and the environment.

Investigations of MUEs, after the fact, typically show that controls for known risks were not effectively implemented. Often because of dense and complex safety management systems and hazard management plans or procedures with long risk registers that prove to be difficult to implement or lack clarity as to which controls are most important.

To simplify systems, focus on what matters, and prevent fatal and catastrophic events from occurring, the critical controls must be clearly defined and understood, with clarity as to who is responsible for implementation. A critical control management approach is an effective way of achieving this, by focusing risk management on those controls that are most critical for health and safety.

The critical control management approach requires:

  • Clarity on which controls really matter (ie critical controls).
  • Understanding of what these controls need to do to prevent an undesired event from happening.
  • Decisions on what checks are needed to ensure that controls are working as intended.
  • Accountability for the implementation of the controls (ie who is responsible for making it work?)
  • Reporting on the performance of all critical controls.

ICMM’s Health and Safety Critical Control Management: Good Practice Guide and Critical Control Management: Implementation guide outline a nine-step process for critical control management that should include planning, implementation, performance evaluation and remedy, with a number of feedback loops integrated to improve robustness.

It is important to note that the guidance does not specify which controls to implement – as these can vary from project to project – but it does lay out the process for identifying the controls, and what elements need to be in place to ensure they are effective.