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KBC|South Africa|Critical Controls|Equipment|Mine Safety|Mining|Occupational Health And Safety|Skills Development|Louise Woodburn
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A training record cannot stop a fatality: mining leaders must test what works at the point of risk

20th October 2026

     

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By: Louise Woodburn - General Manager: Risk Solutions at KBC

Every mining fatality is a person who should have returned home. That sad reality must remain the starting point for any discussion about safety performance.

At the Mine Health and Safety Summit on 17 September, the Minister reported that South African mines had recorded 49 fatalities by 14 September 2026. The industry recorded 41 fatalities in 2025. While these figures demand urgent attention, they do point to the efficacy of health and safety systems, including controls and training.  The focus of this article is to breakdown the complexity of multiple systems to help leaders focus on some of the basic elements to gain maximum returns and reverse the fatality trend.  The focus in on training, controls and verification.  We need to examine what happened in the workplace, which controls were required and whether those controls were effective.

Too often, the question goes beyond: “Was the worker trained?” Rather, leaders should be asking: “Did we prepare the team for the risks they actually faced, and did the required controls work when they were needed?”

Start with the work as it is done

So let’s look at the basics - A Standard Operating Procedure (SOP) or Code of Practice (COP) may set out the correct safety method clearly, yet still fail to describe what happens on the ground. Equipment, ground conditions, access routes and the sequence of tasks can change, and teams may develop workarounds when a procedure is difficult to apply.

In these cases, attention should focus on reviewing SOPs and COPs with the people who perform and supervise the work. Walk through the task at the workplace, and ask where the documented steps differ from practice, what prompts those differences and which controls become vulnerable as a result. The aim is to make the requirements practical, current and clear enough to guide decisions under real operating conditions.

That review must lead to action. Where a procedure cannot be followed because of the way the work is designed or resourced, updating the document alone will achieve little. The mine must correct the underlying condition and then confirm that the revised method works.

Use assurance to reveal the gap between paper and practice

Another critical element to be explored is that of internal audits – is the system delivering what it was designed to deliver.  Internal audits can identify whether required systems exist and whether they are being applied. Independent third-party audits can add a valuable challenge to established assumptions, particularly in high-risk activities where familiar practices may have become accepted without sufficient scrutiny.

The strongest audits go beyond checking training records, signed procedures and completed permits. They follow the work into the field. They speak to workers and contractors, observe tasks, examine changes from the planned method and test whether supervisors can explain what they will do when a critical control is missing.

Findings should answer a practical question: Could the way this task is being performed result in serious harm, even though the paperwork appears complete? Tracking these outputs will reposition the effectiveness, rather than closing out a report when the work is complete.

Verify critical controls to test whether training works

Focused training is necessary, but it comprises attendance through knowledge retention, assessment and in the field verification.  Attendance alone does not demonstrate that a worker can apply what they learned during a critical-risk situation. Verify that an employee has carried over the learning and applied it in the workplace.  Has the employee understood the Critical controls in high risk situations and effectively implemented them – a simple key test to ensure no harm on site.

Here is an example: verification should establish more than whether a worker attended isolation training. It should test whether the correct equipment has been identified, isolation has been applied and confirmed, and the team knows what to do if the conditions do not match the permit. In a mobile equipment area, it should examine both the physical separation of vehicles and pedestrians and whether people follow the required movement rules.

These checks can reveal two different problems: a person may need further coaching, or the system may be making the safe action difficult or impossible to perform. Leaders must respond to both. Repeating a course will not repair a failed barrier, an impractical traffic plan or a production schedule that encourages shortcuts.

Prepare teams to respond when conditions change

Realistic scenarios can strengthen training by requiring workers and supervisors to make decisions, not simply recall rules. A team could rehearse what happens when a lifting arrangement changes, ground conditions deteriorate or an isolation point cannot be confirmed. They should practise recognising the change, communicating it, stopping the task where necessary and securing the correct control before work resumes.

Supervisors also need to demonstrate that they will support those decisions. If a worker who raises a concern faces blame or pressure to recover lost time, the organisation weakens a vital line of defence.

Make field evidence a leadership decision

The value of sharing learning from incident investigations, SOP and COP reviews, audits, worker feedback and critical control verifications amongst mining companies and operations cannot be underestimated.  Thankfully the industry has set up forums for ongoing discussions and learning and this should be supported. Discussions around repeated workarounds, failed field checks or uncertainty about stop-work decisions require management action, with clear ownership and follow-up at the workplace and leaders can gain insight into these important facets from their colleagues.

A safety system has to work where the risk exists. In a dynamic, changing pressurized workplace leaders should pay particular attention to 3 basic areas of risk management – without neglecting the other elements of their safety risk system 

  • Ensure that their procedures reflect the reality of work to be performed,
  • Make sure that employees are competent to do perform their work to the highest level 
  • Double check that everyone understands the need for and reality of risk based critical controls– especially when conditions change. 

It’s an ongoing challenge that must be met for the industry to be successful.

Edited by Creamer Media Reporter

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