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Paul100  
#1 Posted : 28 March 2014 22:29:20(UTC)
Rank: New forum user
Paul100

I'm looking at how to establish an efficient competence assurance programme for maintenance staff working on a TT COMAH site. The approach that I'm considering is:
1. Identify the safety critical equipment (i.e. whose failure could result in a major accident).
2. Identify the maintenance tasks that has to be carried out on the SCE (e.g. remove and overhaul a SCE pump or replace a bursting disc).
3. Carry out human factors risk assessments to ID the errors which maintenance personnel can cause when working on SCE (being as generic as possible e.g. consider pump replacement in general rather than replacement of each individual pump). The HFRAs will ID the safeguards/layers of protection (both existing and additional) to prevent one human error resulting in a major accident.
4. Implement the safeguards/layers of protection etc.
5. Provide training and assessment of competence.

I am not sure how general I can be in terms of SCE in order to avoid carrying out HFRAs on each specific SCE items. When is a sign off by a second person required, etc?
andybz  
#2 Posted : 29 March 2014 11:29:19(UTC)
Rank: Super forum user
andybz

Paul

The process you describe appears to be an excellent way of developing an initial training and assessment package for new maintenance technicians. One of its key features is that it provides a clear link between process safety risks and 'soft' controls. However, I do not think it addresses all of the key requirements of a competence assurance system.

I would suggest that your main challenge is demonstrating competence assurance of existing personnel on am on-going basis. Just because someone went through your described process originally does not mean they remain competent for ever more. Things change, people forget and pick up bad habits. Also, you will find that some of your most critical tasks are performed infrequently and your process as it stands may not be enough for people to ever become competent.

As a minimum, you need to consider the need for re-assessment for the most safety critical tasks. This will need to address the tasks performed frequently (so it is actually easy to arrange an observation) and those performed infrequently. In some cases you may actually have to run a simulated training and assessment program in advance of an infrequent task being performed, and this needs to be factored into the job planning process.

Other safety critical competencies need to be covered. As a minimum these would include knowledge of your permit-to-work and management of change systems; and diagnosis skills. Also, I would suggest an area that maintenance personnel are often very weak at is understanding process isolations (they tend to assume equipment has been isolated properly without checking). Also, you need to recognise that some of your most critical tasks may be performed by contractors, but you will still have some responsibility for ensuring their competence.

I will say at this point that everything I have said is theory. As a consultant I am very experienced in applying safety critical task analysis. However, despite many attempts to get my clients to take this through to competence assurance I have not managed to get any to do it (yet). A few have said that they are going to do it 'in-house' but every attempt I have seen so far has become a bureaucratic tick-box exercise that has added little or no value.

Good luck with this. If you get it right I am sure it will reap massive benefits.
boblewis  
#3 Posted : 29 March 2014 20:43:25(UTC)
Rank: Super forum user
boblewis

As previous poster states you are looking carefully at the initial stages of a working system BUT you are overlooking the whole question of managing competence. I am not working in this area any longer but I could suggest a conversation with Rakesh Maharaj at Armsa Consulting as he and I have closely allied thinking over such matters.

Broadly you need to look at the Organisation, The task(s) and the Persons

Bob
PIKEMAN  
#4 Posted : 31 March 2014 09:01:55(UTC)
Rank: Super forum user
PIKEMAN

I did this some time ago on a higher tier COMAH site. I worked with a local college and used the City and Guilds "Profile of Achievment" in which 6-7 items are picked to build a portfolio for the individual. For example for a mechy fitter 1 of these was having their original apprenticeship. Another was training in the PTW system. However, the hub of it was for the tradesperson to do specific tasks "by the book" ie following the SOP and Risk Asessment, this was witnessed by someone else eg Engineer / Team leader and this built up a portfolio of tasks. We used the COMAH report to ID safety critical items eg pumps and used the maintenance of this kit as examples. The completed portfolio was audited by the college and eventually led to the profile of achievment. This was accepted by the Competent Authority. http://www.cityandguilds...1-profile-of-achievement
Salis  
#5 Posted : 01 April 2014 08:12:48(UTC)
Rank: Forum user
Salis

Paul, I think you are on the right lines, I'd add another step to your programme and that is to create a audit plan, audit the processes to ensure everything is flowing well and all key tasks and operations are being undertaken.
boblewis  
#6 Posted : 01 April 2014 13:18:58(UTC)
Rank: Super forum user
boblewis

The task actually requires that we need some form of CPD in process for all competent persons. Most of what is being said here revolves around a one off achievement that mere audits are not going to fully warrant as an operational competence system. Competence can only be maintained by ongoing development - it is NOT a static one off matter. In truth the individuals concerned should be able to modify processes and procedures as the task unfurls during work, look at the Electrical competence needs under IEE regs - Here people inspect and certify the work they haave done.

You should therefore be looking at how you can assist these persons to maintain and develop there skills with appropriate records to demonstrate their ongoing development. Monitoring on a routine ad hoc basis then becomes a further essential task to demonstrate ongoing compliance and competence.

Bob

Marshall16325  
#7 Posted : 04 April 2014 06:55:56(UTC)
Rank: Forum user
Marshall16325

Hi Paul

In addition to the above.
As part of our competency to operate process, my team and I conducted hierarchical task analysis for maintenance and production activities. This enabled us to understand the sub-element activities, ensuring full coverage of competencies required (breadth and depth). This allowed us to develop bespoke training plans and develop skill pools etc.

Regards

Richard.
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