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Hard truths about your critical controls

Wed, 13 May 2026 07:19:18 GMT

Hard truths about critical controls

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Most critical control frameworks I have seen assume humans will behave consistently and infallibly. The science says they won't.

Ron McLeod's 2017 paper titled "�� : �� " lays out four "hard truths" of human performance and shows how each one routinely defeats well-designed critical control strategies.

Shout out to Ben Hutchinson (PhD) for originally alerting me to this paper.

The strongest insights from this excellent paper are in the carousel. Here's what stood out to me:

Most "human controls" in our bowties are actually ��, not �� (barriers). They support the real critical controls as they aren't reliable enough on their own to be one.

Competence and training don't override System 1 thinking (Daniel Kahneman). A trained rail lookout walked in front of an oncoming train he'd already acknowledged. He had no doubt. System 1 doesn't experience doubt.

Operators under pressure to make work easier will defeat your critical controls without ever recognising they're doing it.

If your CCM framework relies on "��, �� ", you don't have a critical control. You have an unrealistic expectation.

For officers of coal mines and metal mines & quarries, this connects directly to s47A and s44A, respectively. Due diligence isn't about whether you have critical controls listed. It's about whether the controls actually do what you're relying on them to do, under real human performance conditions.

The link to the full paper here: Human factors in barrier management

Check out my thoughts here: Hard truths

Happy to discuss what good looks like in practice.

Scott Graham

Founder and Managing Director, Mineplex

0400 820 250

sgraham@mineplex.com.au

Are your near misses telling you the truth?

Wed, 13 May 2026 05:15:19 GMT

��% �� -�� .

That's the headline finding from new research by J. Lezdkalne, and perfectly summarised (as always) by Ben Hutchinson (PhD), that I've been chewing on for a few days.

The study reanalysed 62 incident investigation reports using a bespoke tool that combines energy-based thinking, barrier analysis, and human factors analysis (HFACS).

Here's what stood out to me.

�� (��%) �� . Twenty-five (40%) were under-classified, originally recorded as minor accidents or near misses despite involving credible fatal potential. Fourteen (23%) were over-classified.
�� -�� . They were characterised by degraded, bypassed, or human-dependent controls, with frequent procedure-to-practice gaps. The barriers were there in the paperwork. They weren't there in the work.
�� : misclassification is "�� ". The way investigators handle human and organisational factors during classification is a big part of why.

Now connect that to the Qld mining context.

Since 2000, we've had �� in Qld mines and quarries as single-fatality events. Each of those events almost certainly had precursors that walked through the system as near misses or minor incidents first. If 40% of those precursors were under-classified, then officers, SSEs, and risk owners were receiving incident information that systematically understated the fatal risk.

Two uncomfortable questions worth sitting with.

When was the last time you reviewed a "near miss" in your operation and asked, honestly, whether the energy and barrier degradation present meant it could have killed someone?
Are your investigators competent to assess fatal potential separately from realised injury severity, or are they classifying by what happened rather than what could have happened?

The research closes with a recommendation worth quoting: �� . Events with no injury may still represent high fatal risk if energy exposure and barrier degradation are present.

That's a different lens to the one most mining incident systems are built on.

If you want a pressure test on how your investigation process actually classifies fatal potential, give me a call.

Check out my carousel here: PFI

Scott Graham

Founder and Managing Director, Mineplex

0400 820 250

sgraham@mineplex.com.au

ICMM CCM Revised Guidance

Wed, 29 Apr 2026 09:23:19 GMT

ICMM's New CCM Good Practice Guide: A Useful Benchmark, But Not a Starter Kit

On 28 April 2026, the International Council on Mining and Metals (ICMM) published the updated Critical Control Management: Good Practice Guide . It is the first significant overhaul of the document since the original 2015 release.

For Queensland mine operators, the timing is quite timely. The new guide arrives roughly five weeks before the 1 June 2026 deadline for sites to have critical controls in place for their identified Principal Hazards and/or Material Unwanted Events (MUEs).

This article explains what has changed in the guide, why those changes matter, and what officers and senior leaders should be doing about it before the deadline.

What's actually new

There are three substantive changes worth focusing on.

One document instead of two

The 2015 Good Practice Guide and the separate Implementation Guidance have been merged into a single 2026 edition. Pulling them together makes the document more usable as a working reference rather than a pair of standards on a shelf.

The new edition also incorporates lessons from a decade of ICMM member company implementation and review. That is significant. The guide is no longer a theoretical framework. It is a record of what has actually worked, and what hasn't, across the sector.

Stronger guidance on governance, accountability and leadership engagement

These three areas have been substantially expanded. They also happen to be the three areas where the 2022 Queensland CCM benchmarking work, presented by Peter Wilkinson, flagged the biggest gaps. Sites had identified critical controls. Many had even verified them. But governance was patchy, accountability was unclear, and leadership engagement was either missing or performative.

For officers under s47A of the Coal Mining Safety and Health Act , and s44A of the Mines and Quarries Safety and Health Act 1999 , this is where the new guide is definitely worth your time. The accountability and leadership engagement sections speak directly to officer due diligence obligations. They describe what active engagement actually looks like, not what a board pack dashboard substitutes for it.

Maturity evaluations and operational readiness checks

This is the part of the update I find most useful. The guide now includes assessment tools that let an organisation test whether its CCM system is working in practice, not just whether it exists on paper.

The distinction matters. Plenty of sites have folders full of bowtie diagrams and verification schedules. Far fewer can demonstrate that those documents reflect what is actually happening on the shift today. The new tools force that question.

Why this matters five weeks out

If a Queensland mine is still designing its CCM system from scratch, the updated guide is a benchmark to test against, not a starter kit. Sites should already be well past initial design and into verification rhythm. If they are not, the priority now is getting the basics defensible by 1 June, then using the new guide to lift the system properly through the back half of 2026.

For officers and senior leaders, the position is different. The new guide is not optional reading. The accountability and leadership engagement chapters describe the conduct expected of someone meeting their officer obligations. Reading them gives officers a clear picture of what active engagement looks like. Not reading them, in my view, leaves an officer relying on others to tell them whether they are meeting obligations that sit with them personally.

A dashboard in a board report is not gaining an understanding. The new guide makes that distinction sharper than it has been.

The verification question

I have been putting one question to CMOs and SSEs for months. The new ICMM tools effectively put it back to officers as well.

Can you demonstrate, right now, that your critical controls for each principal hazard or MUE are specified, verified, and reported up and down the organisation?

Specified means the expected performance is defined. Verified means someone has checked the control is doing what it is supposed to do, against that defined performance. Reported up and down means the workforce knows the verification results, and so do the officers.

If the honest answer is yes on all three, a site is in good shape. If it is "not quite", the new guide and the 1 June deadline are now both pointing at the same thing.

How Mineplex can help: the CCM Diagnostic

This is exactly why Mineplex developed the CCM Diagnostic. It is an independent assessment of where a site's CCM system actually stands, measured against the new ICMM guidance and against the officer obligations under the CMSHA and QMSHA.

The diagnostic gives officers and senior leaders a clear, defensible read on:

Whether the controls in place are genuinely critical, or whether they are broad management-system items being labelled as critical
Whether expected performance is specified well enough for verification to mean anything
Whether verification is measuring quality, or just volume
Whether the reporting loop actually closes back to officers in a form that supports a timely response

It is built specifically for officers who want to know, before the deadline, what they are actually signing off on.

Final thought

Useful guidance is only useful if it gets used. The 2026 edition is a meaningful step up on the 2015 document. For Queensland mine operators, it lands at almost exactly the right moment to test the work that has been done over the past 12 months.

The window between now and 1 June is short. If you would like to talk through what good looks like in practice, or want a candid read on where your site stands, give me a call or send me a message.

You can find the ICMM Good Practice Guide (April 2026) here: ICMM CCM GPG

You can download my CCM carousel here: CCM for Mining Officers

Scott Graham

Founder and Managing Director, Mineplex

0400 820 250

sgraham@mineplex.com.au

Gibson v Maritime New Zealand — Lessons for QLD Mining Officers Before 1 June 2026 | Mineplex

Mon, 20 Apr 2026 20:47:37 GMT

Gibson v Maritime New Zealand: what every Queensland mining officer needs to read before 1 June 2026

By Scott Graham · April 2026

The NZ High Court has just upheld the conviction of the former CEO of Ports of Auckland for a due diligence failure under New Zealand's health and safety legislation. The decision should be sitting on every Queensland mining officer's desk right now, because the duties that convicted Tony Gibson are about to become live in Queensland on 1 June 2026.

This isn't a story about a bad operator. That's what makes it worth reading.

Who Gibson was

By every account that came out in the proceedings, Gibson was exactly the kind of CEO most boards say they want on a high-risk operation:

He was engaged and visible
He ran workshops with frontline staff
He pushed hard engineering controls over behavioural ones
He personally drove the introduction of safer equipment after seeing unsafe work first-hand
His workers, including ones who gave evidence, called him a good boss

He was convicted anyway.

What actually failed

The exclusion zone around operating cranes was a critical control. It existed as a policy. Training covered it. The documentation was

in order. But no one was reliably checking whether it was being applied on night shift. It wasn't. A container fell, and a thirty-one-year-old man died.

The court's finding wasn't that Gibson was careless or disengaged. It was that the verification loop on the one critical control that

mattered on the night a man died was not closed. The information about how the control was actually performing on shift never made it to the level where someone could act on it.

That's the gap. Not absence of policy. Not absence of training. Absence of verification.

Why this matters for Queensland

From 1 June 2026, officers of Queensland mining corporations have a positive duty under s47A of the Coal Mining Safety and

Health Act 1999 and s44A of the Mining and Quarrying Safety and Health Act 1999 to:

Gain an understanding of the hazards, risks, and critical controls associated with the corporation's operations
Ensure the corporation has appropriate processes for receiving and considering information regarding incidents, hazards, risks, and critical controls , and for responding in a timely way

Read those duties carefully. They aren't passive. They're not asking you to be informed in a general sense. They're asking you

to know the critical controls specifically, to know how information about those controls reaches you, and to ensure the corporation actually responds when it does.

That's a feedback loop duty. And it's exactly the duty Gibson was found to have failed.

Four questions worth putting to yourself before 1 June

If you're an officer of a Queensland mining corporation, these are the questions I'd be testing against your current arrangements right now.

1. Can you name the critical controls for each principal hazard at your operation?

Not the hazards. Not the risks. The specific controls. If you can't name them, you can't fulfil the duty in s47A or s44A.

2. How does information about whether those controls are being applied actually reach you?

Through what report. At what frequency. With what verification behind the numbers. "It's in the monthly safety pack" isn't an

answer, that's a process for receiving information about indicators, not about controls.

3. When a control fails or is bypassed at three in the morning on a Sunday, what's the path from that event to your desk?

And how long does it take to get there? If the answer is "it depends" or "the next monthly meeting", the loop isn't closed. This is precisely where Gibson's case turned.

4. When it does land on your desk, what does "responding in a timely way" look like in practice?

Could you demonstrate, after an incident, that you responded? In what document, with what evidence? "Timely" doesn't mean fast, it means proportionate, recorded, and visible.

The Queensland stakes are higher again

Gibson was convicted under New Zealand legislation. In Queensland, s47A and s44A sit underneath industrial manslaughter

provisions. An officer who fails the due diligence duty in a way that contributes to a worker's death isn't just facing a personal prosecution under the safety legislation, they're facing the possibility of an industrial manslaughter charge.

The combination is unforgiving. Gibson did a great deal of good and was still convicted. None of his engagement, visibility, or investment protected him because the verification loop for one critical control was not closed.

Queensland operators have until 1 June 2026 to make sure theirs are.

CCM diagnostic for Queensland mining officers

I've partnered with Wayne Reilly to offer Queensland mining company officers a Critical Control Management Diagnostic — a structured review designed specifically around the s47A and s44A officer duties, with verification loops as the central focus.

If you'd like to walk your CCM arrangements through the same test the Gibson decision applied, get in touch.

Book a CCM Diagnostic

Scott Graham is a mining engineer with thirty years of Queensland coal industry experience and twenty years as a Site Senior Executive across open-cut and underground operations. He is the founder of Mineplex

About Scott →

Safety of Work vs the Safety of Work

Mon, 20 Apr 2026 08:02:52 GMT

Safety of Work vs the Safety of Work

Most of what we do in the name of safety in Queensland mining is just safety work and does not make the mine safer.

THE EVIDENCE

Four things we do that don't work.

Take 5s

A controlled trial found no evidence they improve planning, heedfulness, education, or hazard ID. Workers batch them, pre-fill them in the ute, fill them in for each other. Rae calls it the "Not for Me" effect —useful for someone else, never for me.

Risk assessments done after the decision

"Unless you have a time machine, risk assessments cannot directly drive risk reduction." —Drew Rae. Most JSAs I review are utter crap —more likely to prove in an investigation that it was tick-and-flick.

TRIFR & LTI dashboards

Month-to-month changes are statistically indistinguishable from noise. Not "mildly noisy" —literally noise. Boards "gain an understanding" of safety from random variation dressed up as a trend.

The clutter itself

Every incident adds paperwork. We never take anything away. And every safety activity that takes a supervisor off the floor is making work less safe, not more.

THE ELEPHANT IN THE ROOM

We're about to hit 1 June 2026 with safety systems so full of safety work that there's no room left for the safety of work.

CCM, done properly, requires the opposite.

It requires us to be ruthless about what a critical control actually is, what "working" actually looks like, and how we verify it.

You can't do that inside a system buried in cards, audits, pre-starts, forms, and dashboards that everyone privately knows aren't doing anything.

FOUR QUESTIONS

CMOs, SSEs & company officers:

Can you name three pieces of safety work on your site that you'd bet your own money actually reducethe risk of a fatality? If you can —why aren't you doing more of those and less of everything else?
If you removed a piece of safety work tomorrow, would anyone be able to demonstrate the risk went up? If not —what was it actually doing?
How much of your board's monthly safety report is signal, and how much is month-to-month noise?
If you asked your supervisors what the stupidest thing they do every day is —and meant it —what would they say? And what's stopping you from asking?

0dda7db8

Hard truths about your critical controls

Hard truths about critical controls

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Scott Graham

Are your near misses telling you the truth?

Scott Graham

ICMM CCM Revised Guidance

ICMM's New CCM Good Practice Guide: A Useful Benchmark, But Not a Starter Kit

What's actually new

One document instead of two

Stronger guidance on governance, accountability and leadership engagement

Maturity evaluations and operational readiness checks

Why this matters five weeks out

The verification question

How Mineplex can help: the CCM Diagnostic

Final thought

Scott Graham

Gibson v Maritime New Zealand — Lessons for QLD Mining Officers Before 1 June 2026 | Mineplex

Gibson v Maritime New Zealand: what every Queensland mining officer needs to read before 1 June 2026

Who Gibson was

What actually failed

Why this matters for Queensland

Four questions worth putting to yourself before 1 June

1. Can you name the critical controls for each principal hazard at your operation?

2. How does information about whether those controls are being applied actually reach you?

3. When a control fails or is bypassed at three in the morning on a Sunday, what's the path from that event to your desk?

4. When it does land on your desk, what does "responding in a timely way" look like in practice?

The Queensland stakes are higher again

CCM diagnostic for Queensland mining officers

Safety of Work vs the Safety of Work

Safety of Work vs the Safety of Work

THE EVIDENCE

Take 5s

Risk assessments done after the decision

TRIFR & LTI dashboards

The clutter itself

THE ELEPHANT IN THE ROOM

FOUR QUESTIONS

Less safety work. More safety of work.

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