Queensland’s new critical control management requirements are now in force. Since 1 June 2026, mine and quarry operators have needed to demonstrate systematic critical control management within their safety and health management systems. If you are responsible for safety at a Queensland operation, the question has shifted from “are we ready?” to “can we prove it?”
This post covers what the requirements ask of operators, what regulators expect to see in practice and how bowtie analysis helps you meet both.
What are Queensland’s new critical control requirements?
In short: the Resources Safety and Health Legislation Amendment Act 2024 requires operators to systematically identify material unwanted events, define the critical controls that prevent them, set performance standards for those controls and verify they work. The provisions commenced on 1 June 2025, with a one-year transition, so full compliance has been required since 1 June 2026. For coal mines, critical controls are integrated through Principal Hazard Management Plans, with QGN35 as the recognised guidance. For mineral mines and quarries, they sit within the safety and health management system. The approach draws directly on the ICMM Critical Control Management framework, which was itself substantially updated in 2026.
A critical control is a control that is crucial to preventing a material unwanted event or mitigating its consequences. Its absence or failure would significantly increase the risk despite the existence of other controls. That distinction matters: not every control is critical, and treating them all the same dilutes attention from the ones that keep people alive.
The stakes are not theoretical. In 2024, failure to implement effective critical controls accounted for 83% of fatalities across ICMM member companies. Not unknown hazards, and not missing knowledge. Controls that were identified, documented and did not perform on the day. As ICMM put it: this is not a failure of knowledge.
What regulators expect to see: the golden thread
Compliance on paper is not the goal. Regulators have signalled that they expect a golden thread running from risk assessment to the field: bowtie analyses linked to procedures, permits, pre-start meetings and supervisor checks, backed by control verification records.
There is a reason verification carries so much weight. Two things are true of almost every major event, in every industry: more than one critical control had failed, and those controls had been weakened long before the day. Verification is the mechanism that finds the weakening while there is still time to act on it.
In practice, that means being able to show an inspector:
- Which material unwanted events your operation faces
- Which controls you have designated as critical, and why
- What each critical control must achieve, and who owns it
- Evidence that those controls are verified and working in the field, not just documented in a folder
If your bowties live in a slide deck that was last opened during the risk assessment, that thread is broken.
How bowtie analysis supports critical control management
Bowtie analysis is the recognised method for the foundation steps of critical control management, and it is the approach the ICMM framework is built around. A bowtie diagram puts your material unwanted event at the centre, threats on the left, consequences on the right and the controls standing between them, all in one picture.
That single picture does a lot of work:
Identifying material unwanted events. Building the bowtie forces clarity about what the event actually is, what could cause it and how bad it could get.
Defining critical controls. With every control visible on one diagram, it becomes far easier to spot which barriers genuinely matter most, and just as importantly, which ones don’t. Many operations count supporting activities as critical controls: the task that reinstates the windrow is vital work, but the critical control is the windrow itself. Organisations routinely believe they have forty critical controls when they have twelve, and the bowtie is what makes that visible.
Communicating with the frontline. A bowtie is readable by everyone from the board to the pre-start meeting. The people operating your critical controls can see exactly where they fit in preventing a fatality. That shared understanding is what regulators mean when they talk about controls being understood in the field.
Where Bowtie Master fits
Bowtie Master is cloud-based bowtie software built by process safety engineers. It makes bowties easy to build, share and keep alive: your team accesses live diagrams from anywhere, every barrier and critical control has a clear owner and risk information stops sitting in silos or in diagrams only the experts can read.
It is used across 43 industries in 25 countries, is ISO 27001 accredited and comes with SSO and MFA out of the box, which your IT department will appreciate as much as your safety team appreciates the diagrams.
Beyond the bowtie: investigations and task analysis
Critical control management does not stop at the diagram. When controls fail, you need to understand why, and the Salus Suite covers that ground too.
Incident Insight lets you investigate your way. It facilitates the methodologies Australian operators already use, including ICAM, 5 Whys and root cause analysis, and includes built-in Tripod Beta developed in partnership with the Stichting Tripod Foundation and the Energy Institute.
Safe Task manages safety critical task analysis, helping you understand how human error contributes to material unwanted events without drowning in spreadsheets.
Together with Bowtie Master, that gives you one platform where your bowties, investigations and task analyses inform each other.
We’ve watched another industry learn this the hard way
The UK offshore industry has managed critical controls under law since the 1990s, and its regulator writes to operators after every inspection. We obtained four years of those letters under freedom of information and analysed every finding: where a mature, heavily regulated industry still struggles, decades in. The patterns are strikingly consistent, and none of them are unique to offshore. If you’d like to see what they mean for a Queensland operation building its critical control management now, get in touch and we’ll walk you through it.
Meet us at QMIHSC 2026
Our founder David Jamieson is speaking at the Queensland Mining Industry Health and Safety Conference on Tuesday 18 August at 10.45am at The Star Gold Coast. His talk is called Critical Controls That Actually Control: Closing the Gap Between Work as Imagined and Work as Done and will be held in the Gold Coast room as part of Session 2: People, Performance & Critical Controls.
If you are attending and want to talk critical controls, he is around all week. Drop him a message on LinkedIn to arrange a chat: David Jamieson LinkedIn Profile
Register your interest
If you would like to find out more about how Bowtie Master can help you manage your critical controls, complete the form below and a member of the Salus Suite team will get in touch to share more information with you.
Book a discovery call
Prefer a conversation? Book a 30-minute discovery call with a member of our team. We will look at how you currently manage critical controls, show you Bowtie Master live and give you an honest view on whether it fits. If it does not, we will tell you.
Click here to book a discovery call.
Frequently asked questions
Q. When did Queensland’s critical control management requirements come into force?
The critical control provisions of the Resources Safety and Health Legislation Amendment Act 2024 commenced on 1 June 2025, with a one-year transition period. Full compliance has been required since 1 June 2026 for Queensland mine and quarry operators.
Q. What is the difference between a control and a critical control?
A critical control is one whose absence or failure would significantly increase the risk of a material unwanted event, even with other controls in place. Most of what a site does day to day supports critical controls rather than being one: the task that reinstates a windrow is a supporting activity, while the windrow itself is the critical control. Critical controls warrant defined performance standards, clear ownership and regular verification.
Q. What is a material unwanted event?
A material unwanted event is a low-frequency, high-consequence event with the potential for a fatality or multiple fatalities, such as a fire, explosion, fall of ground or structural failure. The legislation requires operators to define the threshold for what counts as material at their operation, which is what the critical control programme is then built around.
Q. Do the requirements apply to both coal and metalliferous mines?
Yes, though through different instruments. For coal mines, critical controls are integrated through Principal Hazard Management Plans, with QGN35 as the recognised guidance. For mineral mines and quarries, they are integrated through the safety and health management system. The underlying approach is the same: identify the material unwanted events, define the critical controls, set performance standards and verify them.
Q. Is bowtie analysis mandatory?
The legislation requires systematic critical control management rather than a specific method, but bowtie analysis is the approach the ICMM framework is built around and is widely regarded as the most effective way to identify material unwanted events and critical controls.
