Getting the most out of critical control management systems
Globally, the mining sector has invested significant time and resources during the past five years to implement critical control management (CCM) systems intended to prevent fatal incidents. Notwithstanding the advent of these CCM systems and the release of guidance in 2015 by the International Council on Mining and Metals (ICMM), the mining industry continues to experience high numbers of fatalities. ICMM members have collectively experienced more than 350 deaths over the past five years. According to ICCM, “What the data shows us is that the increased and sustained focus on the elimination of fatalities has yet to mature. We have seen continued success in reducing the number and rate of injuries; however, a focus on fatalities must remain.”
What is keeping mining companies from realizing value from their CCM systems and successfully reducing fatalities? There are three things many companies can do to extract and create greater value from their CCM systems in relation to reducing the number of fatal risks and more broadly in the context of material operational risks.
Don’t settle for mere compliance
Many companies are creating a goliath CCM system that performs vast numbers of critical control verifications.
While organizations are investing enormous time and effort to perform physical observations of controls, and are generating huge volumes of data on critical control checks in the process, it is all for naught if the organization gets stuck in a compliance mindset, or simply executing a checklist of tasks because employees feel they must rather than because they understand the benefit of it.
When CCM is implemented as a mere systems solution the benefits are short-lived. Most commonly, following an initial burst of enthusiasm in which the workforce embraces the CCM system, critical control verifications begin to lapse into mindless inspections that uncover no learning and improvement opportunities. Companies eventually lose engagement and credibility with their workforce and leaders lose a sense of urgency. Fatalities re-emerge, incident rates increase and the workforce becomes blind to hazards. In the worst extreme, reporting of critical control failures goes underground.
This occurs when employees feel the motivation to perform critical control verifications comes from an external influence – either a particularly influential company leader, a verification quota target established by corporate headquarters, or a system prompt to close-out overdue actions. Behaviour is characterized by employees seeing safety merely as a matter of following rules developed by someone else. The underlying message to employees is “follow the rules and you will be safe,” which delivers only minimal strengthening of critical controls.
To achieve greater value and improve results of CCM, companies should endeavour to integrate the system into a company culture characterized by safety maturity. It is not effective for organizations to simply be compliance driven and reactive, in which risk management is a result of rules and procedures in place, often ignoring the underlying human elements involved (represented by the North-South axis in the figure above).
Workers and leaders should also aspire to have higher levels of situational awareness and be better able to identify risks affecting the working environment, and feel empowered to proactively seek to resolve them (represented by the East- West axis in the figure).
When companies apply CCM amidst a mature culture that harnesses beliefs and attitudes and generates improved situational awareness, as well as drives compliance to rules and procedures, they can achieve and sustain improvements that strengthen critical controls and reduce fatal risks. In addition to detecting and addressing individual critical control failures, the organization is better able to evaluate when and why control failures are outside of tolerance levels, and learn from data gathered.
Put more trust in automated systems
In an era when technological applications are exploding onto the scene in the mining sector, it is surprising that the CCM approach taken by many companies remains heavily reliant on managers and supervisors performing in-person physical observations of critical controls, such as combing through reams of equipment maintenance and inspection records to check whether equipment certifications and inspections are current.
Instead, there are opportunities for companies to move toward automated retrieval and reporting of data, and use of automated remote detection devices to perform inspections rather than relying on human verifications. Not only does this have efficiency benefits, it makes more human resources available to analyze trends rather than inspect for failures, and enables leaders to have more quality safety interactions with their workers.
Leverage all available data insights Many companies are limiting CCM to field-based controls, such as plant and equipment operation or when performing construction, maintenance, and inspection. However fatal incidents can stem from failures in asset integrity management, design, maintenance strategy and planning, management of change, and work planning, as well. For critical control identification and verification to deliver greatest value, it should encompass critical controls embedded throughout operational processes within and outside of field-based activities. A focus on the last-line-of-defense limits the value that can be realized.
Also, a wealth of critical control compliance data exists among many companies indicating the locations and timing of detected critical control failures. While companies are using this data to monitor completion of verifications and closure of actions with a view to reducing critical control non-compliance by their workforce, it could be analyzed alongside other data (e.g. fatigue, equipment reliability, and stress). This generates rich insights that enable work teams and control owners to pre-empt risks and take proactive instead of responsive action.
Maximize return from CCM investment
CCM systems represent a significant investment of both man-hours and financial resources for mining companies.
There are three things many companies can do to extract and create greater value from their CCM systems: integrate CCM with company culture instead of thinking of it as a mere compliance exercise; extend the reach of critical controls beyond the last-line-of-defense; and optimize field verification and reporting of critical control failures by making use of existing and emerging technologies.
In these ways, mining companies can achieve an improved return on their substantial CCM investments.
Samantha Fraser is senior manager with DuPont Sustainable Solutions. DuPont Sustainable Solutions, a business unit of DowDuPont Specialty Products division, is a leading provider of world-class operations consulting services to help organizations transform and optimize their processes, technologies, and capabilities and is committed to improving the safety, productivity, and sustainability of organizations around the world. For more information, go to www.sustainablesolutions.dupont.com.