This guidance note shared recently by Maureen Hassall covers the critical control framework integration into Qld coal mines.
But, it may interest others, too.
Just a few extracts:
· “Industry experience suggests that it is possible to identify a number of plans, processes and tools that can be inappropriately classified as controls”
· Image 1 provides the control identification decision tree to focus on fewer, but more targeted control measures
· No surprises: they define a control as:
1. Of itself, an act, object or combination of act and object
2. An act is an intentional human action intended to prevent an unwanted release of energy/cause of harm, or mitigate the consequences
3. Objects are things designed to prevent unwanted releases or to mitigate
4. Hazards are uncontrolled sources of energy or other causes with potential harm
· They include activities/items and sources of information which may not meet strict definitions of a control, but support the control
· They provide a couple of examples of this decision tree applied to coal mining – e.g. strata failure, where the one control is to excavate roadways to approved designs. The act is excavating to approved design, procedures are sources of info, lasers etc. are supporting tools, and workplace monitoring are verification activities, whereas survey scans to check final excavation is a verification
· Image 2 is the critical control decision tree – which includes prompts like is it a control as per prior tree, would absence or failure of the control significantly increase the risk of multiple fatalities (despite the presence of other risk control measures)
· They cover the importance of defining critical control performance, and this is said to be “often the weakest area of the hazard management process … largely due to the loss of important context and information due to the time gap between risk assessment and verification tool development
· Critical control info should be recorded on a critical control information summary sheet or similar – they provide worked examples, which I’ve skipped here
· Such info should include the specific objectives related to the principal hazard / material unwanted event, what critical control performance specs are needed to meet the objectives, what support activities enable the critical control, what verification activities and accountabilities are needed, and the critical control performance trigger
· The “Performance Trigger is the point at which the critical control has not been implemented or maintained”
· They delineate workplace monitoring, verification activities, and verification
· Workplace monitoring “requires examination of the work area by [Coal Mine Workers] to confirm critical controls are still effective” and “should be done prior to starting a task and during the performance of the task”
· Monitoring allows people to “take the appropriate actions to correct any erosion of the critical control before it reaches the Performance Trigger”
· They indicate how monitoring also allows supervisors to check that the critical controls remain effective, though I sympathise a bit with supervisors since they’re apparently responsible for almost everything on site (just check out the responsibility column on any SWMS) – and that assumes they’re even set up to ‘supervise’ (check out how much time they’re stuck in the site office…)
· Then critical control auditing, ensuring which critical controls need to be audited and when, how frequently, what needs to be audited for each critical control and more
· Critical controls not meeting the performance target should “trigger a response which is designed to protect CMWs until the critical control is returned to Target Performance”
· And “Responses should be approved by the relevant person prescribed in the approved Management Structure. These responses should be documented”
SafetyInsights.org 