As Parliament considers amendments intended to strengthen managerial responsibility, employer accountability, enforcement and penalties under the Mine Health and Safety Act, Alvarez & Marsal (A&M) warns that tougher rules must be matched by stronger execution at the rockface.
South Africa's mines cut total fatalities to a record low of 41 in 2025, yet fall-of-ground deaths, historically a leading cause of underground fatalities, rose by around a quarter over the same period. According to A&M, the gap is rarely the controls themselves, but whether they hold up in the daily reality of the operation.
Across mining, metals and other high-hazard industries, two decades of investment in safety systems, standards and reporting have not eliminated fatalities and high-consequence events, often involving known hazards and controls that already existed on paper.
A&M; supports stronger accountability and enforcement, but warns that the bigger risk is not necessarily a shortage of controls. Critical control management (CCM) is treated as a documentation exercise rather than a discipline owned by the people running the operation day to day. According to the company, the organisations that hold on to their safety gains are the ones where line leadership, not a central health and safety function alone, owns the controls, verifies them in the field and responds quickly when something looks wrong.
For operators, and increasingly for boards, the question is no longer only whether the right controls exist on paper, but whether frontline leadership makes them hold up in daily operations, under pressure to produce, on ageing infrastructure, with a stretched workforce and growing investor scrutiny of operational risk.
In practical terms, boards and mine leaders should be able to answer five questions:
1. Which controls prevent each fatal risk?
2. Who owns them on every shift?
3. How is their effectiveness verified in the field?
4. How quickly are weaknesses escalated?
5. Whether employees can stop work when a control is missing or compromised?
“High-consequence events rarely happen because a hazard was unknown,” said Johan van der Westhuyzen, MD and head of Alvarez & Marsal’s Cape Town office. “Far more often, a critical control existed on paper, but was absent, bypassed or never verified in practice. That is an execution problem, not a knowledge problem, and it has to be fixed on the front line, not in a policy document.”
More than a checklist
One of the more important shifts in the sector, in A&M’s view, is the recognition that CCM cannot sit inside the safety function alone. Many organisations still run critical controls as a compliance exercise, built on long checklists and reporting systems that nobody on the front line recognises. When everything is labelled critical, the controls that actually prevent fatalities get lost among the rest.
“When everything is labelled critical, nothing is,” he adds. “Effective control management means a small number of controls that genuinely prevent fatalities, clear ownership, and visible verification in the field, not another layer of paperwork.”
A consistent lesson across high-hazard industries is that catastrophic events are usually preceded by weak signals on the ground: a barrier not put back, equipment left to degrade, a bypassed system, an unreported defect. These conditions are visible well before an incident, but only if someone is verifying controls in the field and the culture makes it safe to raise problems.
Van der Westhuyzen continues: “The strongest operations treat a visible weakness as useful intelligence, not as a failure to hide. That culture, more than any procedure, is what determines whether a control holds when it matters.”
Embedding critical control management
South Africa’s deep-level mining industry illustrates both how far execution can take safety performance and how quickly it can slip. The sector cut total fatalities to record lows of 42 in 2024 and 41 in 2025. Over the same period, fall-of-ground fatalities rose by 25%, from 12 to 15, even though controls such as netting, bolting and entry examinations helped drive fall-of-ground deaths to a record low of six in 2022. The Minerals Council has named the deeper embedding of critical control management among its priorities for 2026.
“In Africa’s mining, energy and infrastructure investment, the constraint is rarely the controls that exist on paper. It is whether they are built into the way the operation runs from day one. That is far cheaper and safer than retrofitting execution discipline after harm, and it is exactly where investors are now looking.”
For more information on Alvarez & Marsal, visit www.alvarezandmarsal.com
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