Protecting workers and local communities through effective critical control management 

By Sarah Bell, Director – Health, Safety and Product Stewardship, ICMM.

Health and safety is at the heart of every responsible mining company. For ICMM members, this manifests through the Mining Principles as a commitment to continual improvement in health and safety towards an ultimate goal of zero harm. Members focus on the implementation of robust health and safety systems and have worked in collaboration to produce ICMM’s good practice guidance on ‘critical control management’. This is central to the effective management of all health and safety risks and goes well beyond protecting employees from COVID-19, also taking into consideration the risks presented from the use of vehicles and working in underground environments.

A robust systems approach to health and safety

Mining has inherent material risks that need to be managed and controlled effectively. This process is called ‘critical control management’ – which is about knowing what your material unwanted events are, and how they could lead to serious harm for your people, your community, the environment, or business, and implementing the ‘critical few’ controls (the ones that really matter) to prevent them.

ICMM produced good practice guidance on critical control management in 2015 and it is common place across ICMM’s company members’ operations. This approach has led to significant reductions in fatalities in areas such as vehicle related incidents (46% reduction) and underground rockfall events (66% reduction) as reported in the ICMM 2019 safety data benchmarking report. Despite the significant gains made by industry in applying the critical control framework to support the path towards zero fatalities, there is much work still to be done.

Applying Critical Controls to Covid-19

Now, with a new and previously unknown ‘material unwanted event’ in COVID-19, we have seen extraordinarily quick implementation of critical controls by ICMM members. In practice, the critical controls for preventing COVID-19 at mine sites rely on a balance of measures. For example:

• The physical removal of vulnerable workers from operations
• Minimising the numbers of people on site by setting people up to work from home
• Separation and protection of workers who remain on site
• Rigorous testing and screening protocols to identify new cases, particularly those that may be asymptomatic.

We talk about success of critical controls in terms of their ‘conformance level’. In the case of social distancing, some evidence suggests that you need to sustain around 80-90% conformance for measures to be effective. In practical terms, where you have high conformance to social distancing, the spread of COVID-19 on site, even via asymptomatic carriers, is minimised.

In many of the companies I have spoken to, where these critical controls have been implemented well, workers have quickly reached conformance levels of up to 97.5%. This is interesting because of the challenge to implement and sustain the effectiveness of critical controls that rely on human behaviour compared to applying technology or engineering based controls that allow physical removal or separation of a person from the exposure.

What can we learn from those companies that reached high conformance so quickly?

Whilst we are still learning about COVID-19, below are five initial insights about why the mining and metals industry has been effective in building conformance quickly on critical controls, and what this may mean looking forward:  

1. Humans are motivated to act based on a real or perceived threat or reward. COVID-19 presents a threat that feels real and imminent for everyone. Therefore, acting quickly to implement critical controls could reasonably be rewarded by not contracting the virus.  
2. COVID-19 provides a ‘burning platform’ that forces this quick change in behaviour. It reminds us that people are capable of quickly creating and maintaining a mindset that, should their life be in danger they must not become complacent. However, we know that change management is hard and requires sustained leadership effort.
3. Focus on what matters. COVID-19 presents leaders with unprecedented clarity on what matters – protecting employees and surrounding communities - and without knowing all the answers immediately on how to address this threat - it has driven a unique collective leadership focus unlike any other crisis event before it.
4. Strong and clear communication from senior leaders is vital. Those mining companies that have demonstrated effective management of COVID-19 have clearly seen the benefits of decisive and caring communication from the top.
5. COVID-19 will accelerate technological advancements in mining, but in the short-term it has also identified new ways of working safely. This is hardly a revelation as I sit at home writing this blog. However, for the mining industry these more immediate and new ways of working have disrupted the ‘norms’ of carrying out a task and could actually result in overall improved safety performance on site. The repetition of tasks can result in complacency and incidents, but right now workers are hyper aware, and taking care as they consciously relearn how to operate safely in this new environment.

As a global industry, we are learning new things about COVID-19 daily and adjusting in order to live and work safely. The virus is a material unwanted event for the mining industry, which for many responsible companies has validated the strength, flexibility and scalability of the critical control framework. It will be important to share the lessons learned generously to help others prepare for future waves and for the next pandemic. The challenge will be taking all of these learnings and sustaining an operating environment in which leaders and workers maintain a “healthy level of discomfort” to prevent complacency creeping back in.

The way I have seen the industry respond to the threat from COVID-19 reassures me that sound health and safety systems matter and will help us to transform and take the next step change towards zero fatalities more broadly.