July 2016

Environment and Safety

Implement a competency management system for process safety

Managing the competency of company personnel is a critical aspect of process safety.

Managing the competency of company personnel is a critical aspect of process safety. Numerous catastrophic accidents have been attributed to a lack of competency. A competency management system can be established to help ensure that a company’s safety-critical activities are performed to an appropriate standard.

Competency means being able to perform work to meet a defined standard. It applies to both individuals and teams of people. Many people impact process safety in virtually all relevant disciplines, including design, construction, operation, maintenance, engineering, and management, ranging from front-line personnel, such as operators and mechanics, to senior managers. These impacts can be positive or negative. The frequency and severity of process safety incidents can be reduced or increased by the actions or inactions of many people. The goal of competency is to ensure positive outcomes of personnel performance.

Lack of competency has played a role in notable process safety accidents, including Piper Alpha, Longford, Texas City and Buncefield.^1,2 Fundamentally, most accidents are attributable to human errors. Proper management of competency is an essential aspect of reducing the frequency of human errors.

Traditional personnel selection and recruitment strives to predict whether a person has the appropriate underlying knowledge and abilities to perform a job. This process assesses aptitude, not actual ability. Historically, the competency of personnel has been assumed based on experience and/or training. Sometimes, the provision of procedures has been viewed as sufficient. Moreover, competency has been managed reactively—for example, by using checks and inspections.

However, competency can be managed proactively using a competency management system (CMS) that organizes and integrates all of the activities needed to properly manage competency.³ A CMS helps ensure safe performance by ensuring competent performance by all involved individuals and groups of people. Gaps in competencies are identified and addressed before they contribute to an accident.

In some parts of the world, a CMS is a regulatory requirement, such as under the Control of Major Hazards (COMAH) regulations administered by the Health and Safety Executive in the UK.⁴ Process safety regulations in the US do not require a CMS. Individual elements of the Occupational Safety and Health Administration’s (OSHA’s) Process Safety Management (PSM) Standard⁵ and the Environmental Protection Agency’s (EPA’s) Risk Management Program (RMP) rule⁶ address some competencies; however, no specific regulations regarding competent persons exist. The Center for Chemical Process Safety (CCPS) has addressed competency in several publications.^7,8,9

The international standard on functional safety, IEC 61508, contains requirements relating to competency.¹⁰ It dictates that all people involved with the lifecycle for safety instrumented systems (SIS), including managers, should have “appropriate training, technical knowledge, experience and qualifications relevant to the specific duties they have to perform.” In addition, it requires that competency be documented and assessed. The sector standard for the process industries, IEC 61511, also contains requirements relating to competency.¹¹

Competency is affected by business trends, including the movement of personnel between roles, companies and industries; the restructuring of organizations; and downsizing, outsourcing, mergers, takeovers and spinoffs. Furthermore, personnel are increasingly expected to take on a wider range of responsibilities with less supervision. Also, new technologies require new competencies.

Companies of every size must manage competency. In small organizations, each job holder may perform several roles and require multiple competencies. Older plants may require higher levels of competency than modern plants due to aging equipment and the use of older technologies. The operation of these plants depends more on the ability of personnel to compensate.

A CMS offers many benefits. It reduces risks to employees, contractors, the public, the environment and the company. It helps meet industry standards and satisfy legal and regulatory requirements in some jurisdictions. Also, it may help meet insurer requirements and contractual commitments. Competency management is a fundamental part of managing process safety. Every company should implement a CMS.

The meaning of competency

A CCPS publication described competency as the ability of personnel to perform tasks according to expectations.⁷ Competency is sometimes defined as the combination of knowledge, skills and experience to do a job properly and safely while meeting a defined performance standard. However, competency should include other attributes of people, including personal qualities appropriate to the duties to be performed. These additional attributes include attitudes and behaviors, such as a positive outlook and adaptability. Fig. 1 depicts the meaning of individual competency. Key competency attributes for individuals include:

• Principal attributes:
  • Pertinent qualifications
  • Appropriate training
  • Relevant experience
  • Appropriate skills
  • Ability to communicate effectively, as needed
  • Knowledge and understanding relevant to activities to be performed
  • Qualities appropriate to duties—e.g., physical and cognitive capabilities
  • Appropriate attitudes and behaviors
• Other attributes:
  • Willingly, ably and reliably undertake work activities in accordance with agreed standards, rules and procedures
  • Appreciation of and willingness to address own limitations and constraints
  • Physical and medical fitness and mental health
  • Fitness for duty.

OSHA uses the term “competent person” in some of its standards. It is defined as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous or dangerous to employees, and which has authorization to take prompt corrective measures to eliminate them.”¹² This definition focuses on the ability of an individual to identify workplace hazards and take corrective actions to address them. It does not address the ability of people to perform work to a defined standard.

Often, people work in groups or teams. Participants must be competent individually, but the team must also function competently as a group. The ability of the team to perform work constructively and cooperatively depends on the interactions of the study participants, which is a function of the personal attributes of the participants, including their personalities, backgrounds, behaviors and attitudes. Incompatibilities can result in dysfunctional teams. Team competency can be controlled by the appropriate selection of participants, taking into account not only their individual competency but also how their personal characteristics may influence the performance of the team.

In a CMS, competency is outcome-based. It entails the assessment of competency through the collection of sufficient evidence to demonstrate performance to a specified standard. Certification of competency by a third party can be used as a source of evidence to reduce the effort required for assessment and to provide an independent assessment and benchmark for high-risk job roles. Competency is a continuum with various levels of competence (Fig. 2).

Competency management

Competency management involves several elements:

• Selecting the right people
• Qualifying them
• Training them
• Developing them
• Monitoring and reassessing them
• Auditing and reviewing performance
• Continually improving performance.

These activities form the CMS of a company. As for any management system, a CMS utilizes a plan-do-check-act cycle. The cyclic process is intended to lead to continual improvement. A CMS addresses planning, designing, implementing, maintaining, auditing and reviewing (Fig. 3).

Plan. A CMS is applied to all jobs, tasks and activities that may affect process safety and all personnel who perform such jobs, tasks and activities, including supervisors and managers. The inclusion of jobs, tasks and activities in the scope of the CMS is based on the hazards and risks associated with them. A CMS should target activities so that the effort expended is in proportion to the risks associated with inadequate competency.

The CMS establishes realistic performance standards and criteria for jobs, tasks and activities within the scope of the CMS. Usually, competency requirements are related to the risks and complexity of activities. They should be specific to a site, process, and job or task, as appropriate. A CCPS book addresses the use of competency matrices to establish required proficiency levels for job roles in process safety.⁹

Where people work together in teams, competency requirements for the team as a whole should be set, as well as for constituent roles within the team. Competency standards and criteria must be validated—for example, by use in a trial.

Design. Roles and responsibilities of personnel involved with the development, implementation and management of the CMS are defined. Processes and procedures for using the CMS are developed and integrated with other management systems, as appropriate. Methods to ensure that personnel meet competency standards and criteria are selected, and requirements are established for the different elements of the CMS.

Implementation. Personnel are selected, trained, developed and assessed for competency. The activities they are permitted to perform are controlled. The competency of the people managing the CMS, as well as suppliers and contractors, also must be managed.

Competency assessment is one of the most important aspects of competency management. It is used to determine the extent to which personnel meet the established competency requirements for performing activities. Its purpose is to establish a competency profile so that gaps and weaknesses in competencies can be identified. Competency assessment focuses on acquiring performance-based evidence that a person can carry out an activity rather than simply collate evidence of knowledge or training regarding the activity. The methods used vary according to the circumstances and include simulations, practical tests, demonstrations and psychometric tests.

Successful assessment of competency leads to the issuance of a work authority that provides permission to perform designated work activities. It is important that personnel be asked to perform work only for which they are competent, and they must be able to refuse to perform work for which they are not competent.

Changes in the internal operations of a company, the external environment or the CMS itself must be monitored and flagged for possible impacts on competency management, including both individual and team competency requirements. Records and documents that are generated by the CMS must be maintained.

Maintenance. Performance must be consistently maintained and developed through monitoring and periodic reassessment of personnel. Both proactive and reactive monitoring mechanisms should be established, including self-assessment and self-reporting. Procedures should be in place to address substandard performance, and corrective actions must be initiated when appropriate. Monitoring and reassessment ensure that competencies do not degrade.

Audit. Periodic compliance audits of the CMS are conducted to identify any problems with its design or implementation. The integrity of the CMS will be maintained only if regular checks are made against the design requirements, and improvements made when needed. Audits help to ensure that the CMS has been implemented as intended and is operating as expected, and that work activities are being carried out competently.

Review. Senior management should periodically review the operation of the CMS to assess its performance. Results from audits, incident reports, assessments of job holders, process safety key performance indicators, and benchmarking with other companies should be used to identify improvements to the CMS. The effects of changes also must be addressed. Recommendations for improvements should be developed and implemented with the goal of proactive and continual improvement.

Important points for developing a CMS

A CMS should address activities for all process phases, such as startup, normal operation, degraded operation, normal shutdown and emergencies. Competency for infrequent operations, such as emergency response, can be difficult to maintain. A CMS ensures that the maintenance of such critical competencies is not overlooked.

As for all management systems, a CMS benefits from the designation of a champion to promote the CMS within the company and oversee its operation. It is inadvisable to introduce an entire CMS at one time. A gradual and incremental approach has a better chance of success and acceptance.

A CMS should benefit from utilizing processes and procedures, with appropriate adaptations, from other existing management systems and practices within the company, such as quality and environmental protection. Ideally, processes and procedures for activities such as personnel training and development and change management should be shared. A useful starting point is to map CMS requirements to related processes in other management systems.

It is possible that dependence on the need for competency may be reduced in some cases by redesigning work activities to lower their risk or complexity—for example, by improving procedures or through automation. However, new risks may be introduced and new competencies required, so care should be exercised when such approaches are used.

Recommendations

Competency management should be a foundation element of process safety. Many people are involved with addressing process safety at companies, and this provides many opportunities for human errors to produce process safety accidents. Indeed, process safety accidents are more likely to occur if competent performance is not established and maintained. HP

LITERATURE CITED

1. Wright, M., D. Turner and C. Horbury, “Competence assessment for the hazardous industries,” UK Health and Safety Executive, Research Report 086, HSE Books, Sudbury, UK, 2003.
2. UK Health and Safety Executive, “Inspection of competence management systems at COMAH establishments,” HSE Books, Sudbury, UK, 2011.
3. UK Health and Safety Executive, “Developing and maintaining staff competence,” HSG197, 2nd Ed., HSE Books, Sudbury, UK, 2007.
4. UK Health and Safety Executive, “Control of major accident hazards (COMAH) regulations,” 1999, online: http://www.hse.gov.uk/comah/background/comah99.htm
5. US Department of Labor, US Occupational Safety and Health Administration, “Process safety management of highly hazardous chemicals,” 29 CFR 1910.119, 1992.
6. US Environmental Protection Agency, Office of Solid Waste and Emergency Response, “Accidental release prevention requirements: Risk management programs under Clean Air Act Section 112(r)(7), 40 CFR Part 68,” 1996.
7. Baybutt, P., “Competence management,” in Human Factors Methods for Improving Performance in the Process Industries, American Institute of Chemical Engineers/Center for Chemical Process Safety, New York, New York, 2007.
8. American Institute of Chemical Engineers/Center for Chemical Process Safety, “Guidelines for risk-based process safety,” New York, New York, 2007.
9. American Institute of Chemical Engineers/Center for Chemical Process Safety, “Guidelines for defining process safety competency requirements,” New York, New York, 2015.
10. American National Standards Institute/International Society of Automation, “Functional safety: safety instrumented systems for the process industry sector,” ANSI/ISA-84.00.01-2004, Parts 1–3 (IEC 61511 Mod).
11. International Electrotechnical Commission, “Functional safety of electrical/electronic /programmable electronic safety-related systems,” IEC 61508, Ed. 2, Parts 1–4.

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