Over the last 15 years the coal mining industry has achieved impressive gains in its work health and safety (WHS) performance. These are widely attributed to the development of a new WHS architecture based on structured risk management concepts and WHS management systems.

Regulators too have sought to harness this approach in the development of a new form of “management based regulation” which holds out the promise of “regulating at a distance” in a manner that is resource efficient while at the same time promising better WHS outcomes than more prescriptive alternatives.

However, the coal mining industry has been unable to sustain its impressive injury/fatality reduction trajectory and individual companies have been unable to apply their WHS architecture successfully across the entirety of their operations. These findings raise important questions for WHS.

Based on over 150 interviews mining industry stakeholders and on in depth access to multiple mine sites within individual companies, the authors conclude that corporate systems and other tools of management-based regulation only work well when WHS is institutionalised, and when it gets into the “bloodstream” of the organisation at site level. Only when the formal systems (audits, reporting, monitoring) are supported by informal systems (trust, commitment, engagement) will they be fully effective.

These findings and policy prescriptions are relevant not just to mining and WHS but to the multiple areas of social regulation where a systems-based approach has become an article of faith for companies and regulators alike.