The "Regulatory Trifecta": Mining Safety Act, Management Structure and Critical Control Management

How RS22 fits into Critical Control Management Compliance

To all our Queensland Coal Mine clients who received the Chief Inspector’s request for PHMP and Critical Control data:-

Your response to the Inspector, your BBRA, and your Management Structure must all tell the same story. If they don't, you aren't just failing a paperwork exercise - you’re failing your legislative obligations.

The Chief Inspector’s recent request for PHMP and Critical Control data isn't just a data-gathering exercise - it’s a test of your site’s internal consistency.
If you’re filling out that table, you need to understand how the "Regulatory Trifecta" connects:

The CMSHA (The Law): Defines your Principal Hazards and MUEs. If your BBRA says an event exceeds the threshold set by your CMO, it’s an MUE. Period.

RS22 (The People): Every MUE you list must be listed in your s.55 Management Structure Document. It needs a senior "Risk Owner" with documented competencies. If you list an MUE in your response that isn't in your Management Structure document, you’ve just flagged a compliance breach.

QGN35 (The Process): This is how you prove those MUEs are actually under control. It links your PHMPs to the specific Critical Controls that keep your people safe.

Check your MUEs. Check your Risk Owners. Check your consistency.

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The Human-Performance Gap