Are Your Controls Too Complex for Workers to Understand?

Risk management systems are often praised for their thoroughness and meticulous documentation. Risk registers, bowtie analyses, control verifications—these tools are essential for establishing a structured approach to managing risk. But here’s the critical flaw: What good is a control if the worker implementing it doesn’t understand it?

When control effectiveness is assessed, the worker’s capacity to understand and implement those controls is often neglected.

The Paper-Perfect Illusion

In many organisations, the risk register is seen as the ultimate authority. Each control is listed, assigned a criticality level, and matched with an associated verification process. From a management perspective, everything looks great. The risks are identified, controls are established, and the system functions—on paper.

But what happens when the control is taken out of the boardroom and put in the hands of a worker on the ground? Complex processes that are clear and logical to engineers or safety professionals may be baffling or unclear to the people tasked with implementing them.

A 12-step process for controlling a high-risk activity might be effective in theory. But if the worker lacks the skills, knowledge, or experience to fully understand and apply each step, the control is rendered ineffective.

The Reality Gap: Why Controls Fail

Most critical control verifications are designed to check whether a control is present, implemented, effective in managing the risk and maintained. But this process often overlooks a crucial factor: whether the control is understood by the workers using, applying or activating the controls.

Take a complex engineering control involving electrical isolation procedures, for example. To an engineer or safety officer, the steps are logical and aligned with regulatory requirements. But an inexperienced worker on-site may not understand the terminology or may be unaware of why certain steps are necessary. If they miss one critical step due to a lack of comprehension, the entire control fails.

This issue is particularly prevalent in industries with diverse workforces where skill levels, education, and language proficiency can vary widely. A control may be documented in technical language that is completely incomprehensible to some workers. Worse yet, there may be an assumption that once training is provided, comprehension is assured.

Effective Control Implementation Requires Simplicity

The solution is not to eliminate complexity but to simplify the user experience. Critical controls must be designed with the end-user in mind.

That means:

Understanding the worker’s knowledge, skills, and experience relevant to the control.
Adapting training materials to suit different learning styles and proficiency levels.
Providing clarity through simplified instructions, visual aids, or even interactive learning tools.
Testing comprehension as part of control verification, not just checking for control presence.

Mitigating Controls: The Pressure of Immediate Response

Not all controls are preventive; some are mitigating controls—designed to be implemented swiftly when something goes wrong. These controls are often critical yet are rarely scrutinised from the perspective of the end-user's capability.

We often assume that workers will know exactly what to do in an emergency, but how often is this assumption tested? Office evacuations are a well-practiced control, drilled repeatedly until it becomes second nature. But what about other responses that require quick, decisive action?

When a fire breaks out, a machine malfunctions, or a hazardous spill occurs, the expectation is that workers will implement mitigating controls immediately and effectively. But is there robust training in place? Have these responses been practised under realistic conditions? And most importantly, do workers truly understand the actions they need to take and why?

There’s a common but flawed assumption that experienced workers—particularly those who have been in a role for a long time—automatically know how to respond to an incident. But experience alone doesn’t guarantee competence in emergency situations, especially if the worker has never faced the scenario or been properly trained to handle it.

What if the mitigating control is complex? What if it involves steps that are difficult to remember or execute under pressure? The truth is, these controls are only as effective as the worker's ability to recall, understand, and apply them.

We need to move beyond the assumption that people “just know” what to do and instead verify their capability through practice, feedback, and continuous improvement. Training programs should be designed with user comprehension and simplicity in mind, emphasising not only the “how” but the “why.”

Assessing Control Complexity: A Training Framework Analogy

To better understand this, it is helpful to consider the analogy of a training framework—similar to the structure of qualifications such as Certificate II, Certificate IV, Diploma, and Degree.

Just as training frameworks are structured according to different levels of knowledge, skill, and application, controls should also be assessed on a gradient of complexity. A simple control—such as checking a machine guard—is akin to a Certificate II level skill, easily understood and implemented by most workers. But a complex control—such as a 12-step process involving chemical isolation—may be more akin to a Diploma or Degree level, requiring advanced comprehension and applied knowledge.

Yet, unlike a formal training framework where individuals are trained and assessed to meet the required standard, risk management systems often assume comprehension based solely on training attendance or years of experience. This is a flawed approach.

We should be assessing the complexity of controls in the same structured manner that training frameworks assess competency. For every control, there should be:

An assessment of the complexity of the control itself.
Alignment of the control’s complexity with the worker’s skills, knowledge, and experience.
Training and verification processes tailored to the control’s complexity.

Without a framework for assessing control complexity, we risk setting workers up to fail—particularly when complex controls are placed in the hands of those who may not have the necessary training or comprehension.

Worker-Centric Control Verification (WCCV)

What if we assessed controls not just for their technical accuracy, but for their usability? What if we introduced Worker-Centric Control Verification (WCCV) as a standard process?

WCCV involves:

Assessing controls for accessibility and comprehensibility by the workers required to implement them.
Creating tools and methods that align with the worker’s capabilities and ensuring they understand not just the “how” but the “why.”
Including worker feedback in control design and effectiveness assessments.
Testing control effectiveness through field assessments, ensuring that those closest to the hazards can effectively apply the controls.

Bringing Workers into the Conversation

It’s time to rethink control effectiveness assessments. A control that isn’t understood by its end-user is a failure waiting to happen, no matter how comprehensive the documentation.

Leaders in risk management must prioritise simplicity, comprehension, and real-world usability. That means working with the people who are expected to implement controls, not just issuing directives from above.

The question we must ask is: Have we assessed whether the worker understands the control, or have we only confirmed that the control exists?

By integrating worker comprehension into your control effectiveness assessments, you not only improve safety but also strengthen the resilience of your entire risk management system.

Ultimately, a control is only as strong as the weakest link in its implementation. To achieve true control effectiveness, risk management professionals must start assessing whether workers can understand, apply, and sustain critical controls.

The journey from paper-perfect systems to real-world effectiveness begins with understanding the worker.

Ready to transform your risk management approach? Discover how to make your critical controls truly effective by aligning them with worker capabilities. Contact us today to learn how our tailored risk management solutions can help your organisation bridge the gap between theory and practice.