Critical Risks Lead, APAC

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Critical Controls Management White Paper

01. Objective

Workers regularly must engage in high-risk activities (HRAs) that involve the potential to cause serious injuries or fatalities (SIFs). We are committed to doing everything in our power to prevent SIFs at our sites. Thankfully, SIFs are extremely rare events. However, their rarity makes them harder to prevent, as we have fewer opportunities to learn and may underestimate the true risk. Combined with the unpredictability of complex work environments, managing potential SIFs is challenging.

Our approach focuses less on preventing “causes” and more on ensuring the presence of critical controls—the controls that must be in place, or a SIF event will eventually occur. These are the last line of defense. The most effective critical controls assume they prevent not the accident, but the outcome (i.e., a SIF). This method does not rely on perfection—mistakes can happen, but a good outcome is still likely.

Purpose:
This guidance document is intended to support personnel in identifying and properly managing critical controls at our jobsites.

02. Identifying Critical Controls

The first step in critical control management is to identify which controls are critical. While all controls are important, only some are critical—a critical control is the difference between a SIF and no SIF. If a control is not directly related to preventing a SIF for a given task, it is not a critical control.

Example:

• For a fall hazard, eye protection may be important, but it does not determine life or death in case of a fall.
• In contrast, a properly worn and anchored personal fall arrest or restraint system is likely a critical control.

Tip:
If removing a control (a single point of failure) would highly likely cause a SIF, it is probably a critical control.

Guideline:

• Critical controls per task should generally be 2 or 3 total.
• More than 5 critical controls may indicate the task needs redesign, as there may be too many single points of failure.

Recommendation:
When describing a critical control, use active, specific language. For example, specify “an approved safety harness, appropriately worn, connected to the correct lanyard and anchored” instead of simply saying “fall protection.”

02.1 Identifying Critical Controls – Step-by-Step

A practical process for identifying critical controls:

Assemble experienced personnel:

• Involve people directly familiar with the task for their insight into significant risks and necessary controls.

Ask: “When doing this work, what are the things that could kill you?”

• List out scenarios or hazards that should be the focus for critical controls.

Ask: “When those events occur, what controls stop you from being killed?”

• For each serious hazard, identify the controls that are vital to preventing fatality. Challenge whether each suggested control is truly critical by asking, “If that control were missing, would we expect someone to eventually be killed?”

Ask: “Is that good enough?”

• Verify that controls are sufficient and effective. Revise if necessary.

After this process, you should have a concise list of critical controls for each task or hazard.
 

03. Critical Control Management

Once identified, critical controls must be effectively managed and embedded in all work planning and execution.
 

Key Practices:

• Stop Work Program:
  If a critical control is missing or ineffective, work must stop.
• Start When Safe:
  Before work begins, verify all critical controls are in place. If not, work should not start.

Examples of onsite processes that should embed critical controls:

• Site Induction:
  All personnel onsite should be made aware of the Start When Safe philosophy and what to do if a critical control is missing or ineffective.

• Work Planning / Scheduling:
  At least six weeks in advance, identify HRAs and ensure adequate time and resources to put critical controls in place.
  Example: For a crane lift, confirm there is enough space for a controlled access zone.

• Risk Assessment and Method Statement (RAMS) / Job Safety Analysis (JSA):
  All critical controls that must be in place before starting work should be clearly identified and highlighted.

• Last Minute Risk Assessment / Pre-Task Planning:
  Final documentation should clearly identify critical controls for the task. All personnel should be able to list and verify the critical controls before beginning work.

Note: Other onsite processes may also require critical controls—this is not an exhaustive list.
 

04. Verification and Validation

Critical controls should be regularly verified and validated.

Methods:

• Observation Program:
  Embed critical control verification and validation into site observations. Regularly check for presence or absence of critical controls and track this data.

• Spot-Checks:
  Perform focused spot-checks on HRAs to ensure critical controls are present and effective.

• Incident Reviews:
  For every onsite incident, determine if HRAs were involved and assess whether critical controls were present and effective.

  • If critical controls are missing or ineffective, treat as a high-priority (P0Pot) event and conduct a thorough investigation.

All findings should be documented to evaluate and improve the effectiveness of the critical control management program, ensuring HRAs are managed to minimize SIF risk.

Location:

Remote –Johor Bahru, Malaysia, Kuala Lumpur, Malaysia

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