Hard truths about your critical controls
Hard truths about critical controls
F๐ผ๐ฟ ๐ฐ๐ผ๐บ๐ฝ๐ฎ๐ป๐ ๐ผ๐ณ๐ณ๐ถ๐ฐ๐ฒ๐ฟ๐ ๐ฎ๐ป๐ฑ ๐ฆ๐ฆ๐๐ ๐ฝ๐ฟ๐ฒ๐ฝ๐ฎ๐ฟ๐ถ๐ป๐ด ๐ณ๐ผ๐ฟ ๐ญ ๐๐๐ป๐ฒ ๐ฎ๐ฌ๐ฎ๐ฒ
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 "๐๐ช๐ข๐๐ฃ ๐๐๐๐ฉ๐ค๐ง๐จ ๐๐ฃ ๐๐๐ง๐ง๐๐๐ง ๐ข๐๐ฃ๐๐๐๐ข๐๐ฃ๐ฉ: ๐๐๐ง๐ ๐ฉ๐ง๐ช๐ฉ๐๐จ ๐๐ฃ๐ ๐๐๐๐ก๐ก๐๐ฃ๐๐๐จ" 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 ๐จ๐๐๐๐๐ช๐๐ง๐๐จ, not ๐๐ง๐๐ฉ๐๐๐๐ก ๐๐ค๐ฃ๐ฉ๐ง๐ค๐ก๐จ (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 "๐ฉ๐ง๐๐๐ฃ๐๐, ๐๐ค๐ข๐ฅ๐๐ฉ๐๐ฃ๐ฉ ๐ค๐ฅ๐๐ง๐๐ฉ๐ค๐ง ๐๐ค๐ก๐ก๐ค๐ฌ๐๐ฃ๐ ๐ฅ๐ง๐ค๐๐๐๐ช๐ง๐", 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




