The Shift: From Risk Management to Control Management

Traditionally, mining safety was based on a risk-based approach, where hazards were assessed, and strategies were implemented to mitigate risks before incidents occurred. Over time, however, there has been an increasing emphasis on control-based safety management, where the focus is on enforcing specific controls rather than understanding and mitigating the root risks.

Where This Shift Has Gone Wrong

1. Over-Reliance on Administrative Controls & Compliance

• The industry has increasingly relied on prescriptive measures such as checklists, policies, and procedures.

• While controls (such as PPE requirements or documented procedures) are necessary, they often do not address the underlying risks or human factors contributing to incidents.

  
  

  Example: Instead of assessing why a hazard exists and eliminating it at the source, workers are often given more rules to follow—rules that might not always be practical in real-life mining conditions.

2. Loss of Critical Thinking & Risk Awareness

• Over-reliance on control management discourages workers from thinking critically about risks. Instead, they are trained to simply follow procedures, assuming that if they comply, they are safe.

  
  

  Example: A worker might assume that because they are wearing a harness (control), they are safe, without considering whether the anchorage point is actually strong enough to hold them (risk assessment).

3. Controls Can Create a False Sense of Security

• Implementing controls without continually assessing their effectiveness can lead to a false sense of security.

• Many mining companies rely heavily on hierarchical safety processes, assuming that if a control exists on paper, it is working in practice.

  
  

  Example: Ventilation systems may be in place (a control), but if they are not maintained or adapted for changes in working conditions, they may not actually mitigate the risk of gas exposure effectively.

4. Shift Away from Engineering Solutions

• The Hierarchy of Controls prioritises elimination and engineering controls over administrative and PPE controls. However, in practice, mining operations often default to procedural and PPE-based solutions rather than investing in permanent engineering fixes.

  
  

  Example: Instead of redesigning a system to remove workers from hazardous zones, the response is often to introduce more PPE and more paperwork to "control" the exposure.

5. Failure to Adapt to Emerging Risks

• A risk-based approach allows flexibility to identify and respond to new and evolving risks (e.g. automation risks, mental health risks, climate change hazards).

• A control-based approach tends to be static—focused on enforcing pre-existing measures, even if they no longer address the most pressing hazards.

How the Coal Industry Can Re-balance

1. Return to a Risk-Based Approach – Encourage site leaders and workers to think critically about hazards instead of blindly following checklists.

2. Integrate Risk and Control Management – Use controls as a tool to mitigate risks, but ensure they are regularly reviewed and improved based on risk assessments.

3. Empower Workers to Identify and Manage Risks – Encourage workers to speak up when they see ineffective controls and engage in real-time risk assessment.

4. Invest in Higher-Level Controls – Focus on elimination and engineering solutions rather than defaulting to administrative and PPE-based controls.

5. Make Risk Management a Continuous Process – Regularly review controls for effectiveness and update risk assessments dynamically, not just as a compliance exercise.

While control management is essential, the mining industry must not lose sight of risk management principles. A balance between understanding risks and applying effective controls is necessary to truly reduce incidents rather than just ticking compliance boxes.