Competence - a crucial but unspoken aspect of Critical Controls!
Benefits of Highly Competent People in Your Management Structure
Author’s note:
I can’t believe I’m writing this, but this is what it’s come down to: Why do I need to tell people how crucial it is to have COMPETENT people involved in your Critical Control Management system and Mine Management Structure? And following on from that - the verification / governance that goes into your Management Structure. At Zen Meerkat, we’ve spent an extraordinary amount of time developing a system that ensures full compliance of your mine to Management Structure obligations - and if you’re in Qld that’s s.55 or s.50 (depending if you’re a coal or metals mine).
No matter where you operate, here’s the blog article I never thought I needed to write - The Benefits of Highly Competent People!
Steve
1. Defining the MUE Threshold
Although this decision sits with the Mine Operator or Coal Mine Operator - and may therefore be outside your direct control - it should be of critical importance to any site SSE or HST Manager. Setting the threshold is a judgement call with major downstream consequences. Set it too high and you miss genuine catastrophic scenarios; set it too low and you dilute the system with excessive MUEs that can't be practically managed. You should try to guide your Mine Operator when the MUE threshold is set or reviewed.
The MUE threshold must be deliberate, defensible, and matched to the organisation's capacity to manage critical controls effectively. That requires someone who understands both the technical hazard landscape and the operational capacity of the site - a combination of hazard expertise and organisational knowledge that is distinctly competence-dependent. An inexperienced person is likely to default to generic thresholds rather than site-specific, defensible ones.
2. Identifying MUEs
MUE identification should consider site-specific hazards, historical incidents, high-potential incidents, and foreseeable low-probability events - including known fatality events from the site or similar operations, and relevant data from other industries. This demands technical domain expertise: a geotechnical engineer who can recognise a novel failure mode, a ventilation specialist who can identify an emerging gas outburst scenario. Incompetent identification means MUEs are missed entirely, leaving the entire CCM framework with a blind spot where real catastrophic risk exists but no controls are managed.
3. Conducting Risk Assessments per MUE (Bowtie Analysis)
The design of the bowtie diagram is secondary to conducting an accurate and comprehensive risk analysis - this enables a thorough assessment of the effectiveness of existing critical controls and helps pinpoint where vital controls are missing. Bowtie quality is entirely a function of the knowledge and experience of those conducting it. A poorly constructed bowtie identifies the wrong threats, draws incorrect causal pathways, and misses consequence escalation routes.
Competent people produce bowties that are predictive. In many cases, an incident pathway should have been predicted in the bowtie analysis previously developed for the MUE, and past bowties should form part of the investigator's toolkit when an incident occurs. A bowtie that fails to predict the actual incident pathway is evidence of insufficient competence in its construction.
4. Identifying the Critical Few Controls
The criticality of any individual control is relative to a specific MUE - a roof bolting program critical for preventing ground fall in an underground operation may have no relevance to the tailings facility integrity MUE at the same site. This context-dependency is one of the most frequently misunderstood aspects of the CCM approach.
Getting this wrong has two failure modes. Over-identify controls and critical risks - defined as low-probability, extreme-consequence events - can get overlooked, buried under a long list of "critical" items that aren't truly critical. Under-identify and a genuinely critical control is absent from the register entirely, receiving no performance standard, no verification, and no accountability. Only competent people with deep domain knowledge can reliably distinguish the critical few from the important many.
5. Defining Performance Standards
Critical controls require clear performance standards and defined ownership. Writing a performance standard that is specific, observable, and measurable - rather than vague and unverifiable - requires the author to understand how the control actually prevents the MUE in physical, mechanical, or procedural terms. A competent engineer knows what parameters matter for a bund wall; a competent ventilation officer knows what airflow rate represents the actual threshold. Incompetent performance standards produce controls that appear managed but are never meaningfully verified.
6. Verification
Verification must confirm the control is performing as intended in the field. The absence of incidents must not be relied upon as evidence that controls are effective. This is where front-line competence is most visible - the verifier must understand what "performing as intended" actually looks like in practice, recognise degradation before it becomes failure, and know when to escalate. An incompetent verifier ticks boxes without understanding what they're confirming, creating a false assurance that the control is intact when it isn't -which is arguably more dangerous than no verification at all.
7. Acting on Defective Controls
If monitoring or verification identifies that a critical control is not performing as required, action must be taken, and work may need to be modified or stopped until the critical control is restored. The decision to stop or modify work carries significant operational and commercial pressure. Only a competent person - one who truly understands the risk consequence of an absent control - has both the knowledge and the confidence to make that call and hold it under pressure.
Critical Controls - and your Management Structure - Need Competent People
The Critical Control framework signals that the persistence of mining fatalities is not an unsolvable technical problem, but an organisational execution challenge that improved governance and accountability structures can address. Competence is what converts governance structures from paper obligations into operational reality. A CCM program is only as good as the people executing it at every stage - from the Mine Operator setting the threshold to the frontline worker checking the control in the field.
This is precisely where My Competency Expert excels. The CCM framework is the structure, but competence is the mechanism that determines whether it actually functions. Documented controls with incompetent owners don't prevent MUEs - they just create the appearance of management.
(Photo by Mukovhe Mavhungu on Unsplash)