Critical Control Management - Queensland Mine and Quarry Operations

Chad Pettitt | Partner, AusSafe Consulting

Critical Control Management (CCM) requirements are now mandatory for all mine and quarry operations. If you're operating in Queensland, these changes will directly impact your compliance obligations, your risk management approach and safety and health management systems.

What's Changed?

As of June 1, 2025, Critical Control Management became a prescribed requirement under Queensland's Mining and Quarrying Safety and Health (MQSHA) Act 1999. These amendments, introduced through the Resources Safety and Health Legislation Amendment (RSHLA) Act 2024, represent a fundamental shift in how mine and quarry operations must approach risk management.

Critical controls are defined as risk control measures that are essential to either prevent material unwanted events or mitigate their consequences. Crucially, their absence or failure would significantly increase risk, even when other risk control measures exist.

Operators will have until 1 June 2026 to become compliant with new provisions (see s296 deferral).

Key Legislative Changes You Need to Know

The amendments have strengthened three critical sections of the MQSHA Act:

Section 27(3) - Risk Management

Risk management now explicitly requires the systematic application of policies, procedures, and practices that provide for critical controls. This isn't just about having controls in place— it's about systematic critical control processes and implementation.

Section 44A(3) - Officer Due Diligence

Officers now have enhanced obligations to inter-alia:

- Understand the nature of operations and associated hazards, risks, and critical controls

- Establish appropriate processes for receiving and responding to information about incidents, hazards, risks, and critical controls in a timely manner

Section 55(5) - Safety and Health Management Systems

The identification of critical controls is now mandatory to ensure your Safety and Health Management System (SHMS) achieves an acceptable level of risk.

Note: For Qld Coal Mines, similar amendments were also introduced. See the RSHLA Act 2024.

What This Means for Operations

If You Already Have CCM Programs

Many progressive operations have already implemented Critical Control Management as preferred practice. However, what was once voluntary is now mandatory compliance.

Action Required: Review your current CCM programs for scope, application, and effectiveness. Ensure they meet the new legislative requirements.

If You Haven't Implemented CCM Yet

With the compliance deadline of June 1, 2026, now is the time to act. While you have almost a year to prepare, the complexity in implementing an effective CCM program shouldn't be underestimated.

An 8-Step Implementation Roadmap

1. Stakeholder Consultation and CCM Program Design and Development

Engage key stakeholders to design and establish a site-specific CCM program. For multi-site operators, ensure systematic consideration within corporate-level systems.

2. Material Unwanted Event Identification

Identify and model material unwanted events (MUE), including causation, escalation factors, and consequences. Bow Tie Analysis through facilitated workshops is typically the most effective approach.

Some additional consequence and risk modelling may be warranted.

3. Critical Control Identification

Apply a critical control decision tree to identify both:

- Preventative controls (preventing MUE)

- Mitigative controls (reducing consequences)

4. Performance Standards Development

For each critical control, establish clear performance requirements and establish measuring, monitoring, and reporting processes.

5. Accountability Framework

Define clear accountability and responsibilities for critical controls management across all levels of your organisation.

6. Critical Control Impairment Processes

Establish robust processes for managing critical control failures, impairments, or temporary bridging arrangements, including formal reporting, learning mechanisms and managment of change triggers.

7. Human Factors Integration

Develop mature approaches to human factors analysis, particularly regarding initiating events, risk escalation, and safety-critical tasks.

8. Implementation and Integration

Roll out your CCM program with comprehensive training, leadership engagement, and integration with existing management systems.

Don't Underestimate it.

While the legislative changes may appear subtle, the required analysis and supporting change program is substantial. Successful implementation requires:

- Demonstrated leadership commitment at all levels

- Resource planning and allocation for design, build, implementation, and ongoing management

- Training and capability improvement/ upskill

- System integration with existing HSMS, including consideration of critical control standards/protocols

- Learning processes that focus on critical control failure/impairment

- Ongoing assurance and verification processes

Bottom Line

Critical Control Management isn't just about compliance— but managing critical risks to workers and operations. It remains a preferred systematic approach to managing risks of a material nature in higher risk sectors.

With the June 2026 deadline approaching, early action will give you the best opportunity to design and develop, test, and refine your approach.

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Need guidance on implementing Critical Control Management for your operation?

AusSafe has been assisting clients navigate complex S&H requirements since 1987. Our team of expert consultants can guide you through every step of CCM design, establishment and implementation, from initial scoping and risk modelling to full system integration and programmed implementation support.

Get in touch for further guidance and support.