Environment
and Safety
Implement a competency management
system for 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 manage-
ment 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 de-
fined standard. It applies to both individuals and teams of people.
Many people impact process safety in virtually all relevant disci-
plines, including design, construction, operation, maintenance,
engineering, and management, ranging from front-line person-
nel, 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 ac-
tions 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 attribut-
able 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 knowl-
edge and abilities to perform a job. This process assesses ap-
titude, not actual ability. Historically, the competency of per-
sonnel has been assumed based on experience and/or training.
Sometimes, the provision of procedures has been viewed as suf-
ficient. 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 com-
petency.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 require-
ment, 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
P. BAYBUTT, Primatech Inc., Columbus, Ohio
(EPA’s) Risk Management Program (RMP) rule6 address some
competencies; however, no specific regulations regarding com-
petent 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 addi-
tion, 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 indus-
tries; the restructuring of organizations; and downsizing, out-
sourcing, mergers, takeovers and spinoffs. Furthermore, per-
sonnel 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 equip-
ment 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 in-
surer requirements and contractual commitments. Compe-
tency management is a fundamental part of managing process
safety. Every company should implement a CMS.
The meaning of competency. A CCPS publication de-
scribed 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 attri-
butes of people, including personal qualities appropriate to the
duties to be performed. These additional attributes include atti-
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 Environment and Safety
tudes and behaviors, such as a positive outlook and adaptability.
FIG. 1 depicts the meaning of individual competency. Key com-
petency attributes for individuals include:
• Principal attributes:
o Pertinent qualifications
o Appropriate training
o Relevant experience
o Appropriate skills
o Ability to communicate effectively, as needed
o Knowledge and understanding relevant to activities
to be performed
o Qualities appropriate to duties—e.g., physical and
cognitive capabilities
o Appropriate attitudes and behaviors
• Other attributes:
o Willingly, ably and reliably undertake work activities in
accordance with agreed standards, rules and procedures
o Appreciation of and willingness to address own
limitations and constraints
o Physical and medical fitness and mental health
o Fitness for duty.
OSHA uses the term “competent person” in some of its stan-
dards. It is defined as “one who is capable of identifying existing
and predictable hazards in the surroundings or working condi-
tions that are unsanitary, hazardous or dangerous to employees,
and which has authorization to take prompt corrective mea-
sures to eliminate them.”12 This definition focuses on the ability
of an individual to identify workplace hazards and take correc-
tive 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 com-
petently as a group. The ability of the team to perform work con-
structively and cooperatively depends on the interactions of the
study participants, which is a function of the personal attributes
Qualifications
Training
Skills
Knowledge and Competence
understanding
Physical and
Fitness for duty mental capabilities
=
+ are developed and integrated with other management systems,
Performance standards
FIG. 1. Elements of competency for individuals.
Not yet
Novice competent Competent Proficient
FIG. 2. Levels of competency.
78 JULY 2016 | HydrocarbonProcessing.com
of the participants, including their personalities, backgrounds,
behaviors and attitudes. Incompatibilities can result in dysfunc-
tional teams. Team competency can be controlled by the ap-
propriate selection of participants, taking into account not only
their individual competency but also how their personal charac-
teristics may influence the performance of the team.
In a CMS, competency is outcome-based. It entails the as-
sessment 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 in-
volves 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 man-
agement 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, maintain-
ing, 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
Experience
CMS. Usually, competency requirements are related to the risks
and complexity of activities. They should be specific to a site,
Behavior process, and job or task, as appropriate. A CCPS book addresses
the use of competency matrices to establish required proficien-
cy levels for job roles in process safety.9
Attitudes
Where people work together in teams, competency require-
ments for the team as a whole should be set, as well as for con-
stituent roles within the team. Competency standards and crite-
ria 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
Acceptable performance as appropriate. Methods to ensure that personnel meet compe-
tency 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
Expert
to perform are controlled. The competency of the people man-
aging the CMS, as well as suppliers and contractors, also must
be managed.

Competency assessment is one of the most important as-
pects of competency management. It is used to determine the
extent to which personnel meet the established competency re-
quirements for performing activities. Its purpose is to establish
a competency profile so that gaps and weaknesses in competen-
cies can be identified. Competency assessment focuses on ac-
quiring 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 accord-
ing 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 per-
form 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 in-
dividual and team competency requirements. Records and docu-
ments that are generated by the CMS must be maintained.
Maintenance. Performance must be consistently main-
tained and developed through monitoring and periodic reas-
sessment 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 ini-
tiated when appropriate. Monitoring and reassessment ensure
that competencies do not degrade.
Audit. Periodic compliance audits of the CMS are conduct-
ed 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 improve-
ments 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 oth-
er companies should be used to identify improvements to the
CMS. The effects of changes also must be addressed. Recom-
mendations for improvements should be developed and imple-
mented 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 emergen-
cies. 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 intro-
duce an entire CMS at one time. A gradual and incremental ap-
proach has a better chance of success and acceptance.
A CMS should benefit from utilizing processes and proce-
dures, with appropriate adaptations, from other existing man-
agement systems and practices within the company, such as
Environment and Safety
Plan the CMS
Audit and review the CMS Design the CMS
Maintain competency Implement the CMS
FIG. 3. Elements of a CMS.
quality and environmental protection. Ideally, processes and
procedures for activities such as personnel training and devel-
opment 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 in-
volved 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 estab-
lished and maintained.
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.
Complete literature cited available online at HydrocarbonProcessing.com.
PAUL BAYBUTT is the founder and CEO of Primatech Inc.,
a firm that specializes in process safety, security and risk
analysis. He holds a PhD from the University of Manchester
in England.
Hydrocarbon Processing | JULY 2016 79