Validating Control Effectiveness: Real-World Insights from a Coal Mine Risk Assessment

One of the critical aspects of risk management in any industry is not just implementing controls, but validating their effectiveness. This topic became particularly clear to me during a recent risk assessment I facilitated at a surface coal mine, where the focus was on managing the risk of dust exposure, specifically from spiral dust.

In the risk assessment, one of the controls identified for mitigating dust exposure was the spraying of water across the work area. At first glance, this control seemed straightforward and was assumed to be in place. But as we delved deeper, I realized that validating whether this control was truly effective required more than just confirming its existence.

The Dangers of Assumed Controls

If I had simply asked, “Do you have the water spraying system in place?” I would have likely received a “yes” answer. However, I took a different approach. By asking the open-ended question, “How’s that control working for you?” the real issues began to surface.

It turns out that while there was a dedicated water cart for the area, it had been out of action for several months. Even when the cart was operational, staffing limitations prevented it from being used effectively. On top of that, when attempting to borrow water carts from other areas, the logistics were problematic: the trucks were too large to access some work areas, and the other carts were rarely available.

What initially appeared to be a fully functional control on paper was, in reality, a non-functional solution due to operational challenges. This was a critical realization: just because a control is listed doesn’t mean it’s truly in place or effective.

The Importance of Asking the Right Questions

This experience highlighted two key lessons for me. First, it reinforced the importance of having mechanisms in place to validate the effectiveness of controls. Simply checking off a control on paper is not enough; active verification is essential.

Second, asking the right questions in a psychologically safe environment is crucial for uncovering real issues. When workers feel comfortable and safe sharing information, they are far more likely to provide honest and valuable feedback about the state of the controls in place. This insight can reveal gaps and issues that may not be immediately apparent.

Reflecting on Organizational Practices

As a takeaway, I would encourage organizations to assess their approach to validating the effectiveness of their controls. Do you have systems in place to verify whether the controls are working as expected, or are they simply assumed to be in place? Are you regularly checking in with your workforce, asking the right questions, and creating a space where issues can be raised without fear of reprimand?

In my experience, the workforce has a wealth of intelligence that can help identify and address hidden risks. But to unlock that knowledge, it’s essential to ask the right questions, build trust, and foster a culture of openness.

I’m interested to hear from others—how does your organization ensure the effectiveness of its controls? Do you have strategies for regularly checking in with staff about the real-world impact of safety measures and other controls?