Governance of Competence – an evolution of Critical Control Management

S.Amor FAusIMM(CP)

1.  Director, My Competency Expert, Brisbane, Queensland, 4000. Email: steve@disruptivemining.tech www.disruptivemining.tech

Keywords: Critical Control Management (CCM), Critical Risk Control Effectiveness, Human-Performance Assurance, Capability Assurance. 

Abstract

Mining operations are increasingly adopting Critical Control Management (CCM) as a key mechanism for preventing Material Unwanted Events (MUEs). While CCM programs focus on identifying critical controls, defining performance standards, and establishing verification processes, operations still experience control failures. 

CCM is a strong model, but it largely assumes that managers and superintendents are competent to design and sustain these systems - and importantly, this is rarely examined or assured.

Preliminary feedback from domain experts (e.g. Pitzer, personal communication, 2026) indicates the most catastrophic failures are not simply operator errors; they stem from (amongst others) inadequate verification processes, or flawed governance decisions.

The CCM framework recognises this human dimension but is vague: 

• Emphasises the importance of organisational readiness, stating an organisation undertaking CCM should have the right skills, experience, and resources to implement at a whole-of-program level.

• Acknowledges that many controls are people‑based and therefore rely on the skills, knowledge, and experience of individuals or groups - a recognition that human capability materially affects control reliability. 

• Explicitly advises practitioners to exclude “competent operator” or “training” controls from bowties because almost every control relies on competent people to operate, inspect, or maintain it - adding that such requirements would overwhelm bowties and are assumed to be managed through existing organisational systems. 


These points create a paradoxical situation where competence is essential and universally assumed - yet structurally unmanaged within the framework: in particular, there is no weight placed on the competence of those who design, approve, verify, and govern critical controls.

By reframing human capability and competence as a core element of CCM, distinct from and complementary to, performance standards and verification activities, this approach would address a common blind spot in critical control programs. Integrating capability with verification closes the human‑performance gap, enhances the reliability of critical controls, and improves operational risk.

In summary, competence can be thought of as the reliability multiplier that determines whether controls are designed and function as needed. Is competence governance the next evolution of CCM?