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Case study: Warwickshire Oil Storage Ltd (WOSL) Introducing a competency management system

Introduction

This case study explains how WOSL managed the introduction of a competency management system (CMS) with the support of Environmental Resources Management Ltd (ERM).

Who is WOSL and what does it do?

Kingsbury Oil complex, in the Midlands, is the largest inland oil storage depot in the United Kingdom and storage operators on site include BP, Valero and WOSL (Shell and the British Pipelines Agency also have facilities on site). Together with BP and Valero, WOSL stores petroleum products (eg petrol, diesel and heavy oil) for distribution around the UK and the site is classified as hazardous under the COMAH Regulations 1999.

Why did WOSL look at CMS?

Three key reasons why WOSL looked at developing a CMS were:

The General Manager of WOSL recognises the importance of competency and ■■

competency management in reducing accidents, which is particularly important in the high-risk industry that he and his colleagues work. As a member of the working group of the sector skills council for chemicals, pharmaceuticals, nuclear, oil and gas, petroleum and polymer industries (COGENT) Downstream Advisory Council (which was formed to develop guidelines for competency management systems for downstream and petroleum site), he is aware of the positive impact a well thought-out and effective CMS can have in reducing incidents. This initiative is also seen as being good for business, with any costs attached to ensuring safety fading into insignificance against the risk of a major accident. Prevention of a large-scale incident by spending time on improving the knowledge, skills and abilities of WOSL staff, was considered a small price to pay.The General Manager welcomed the HSE’s intention to increase their focus ■■

on ensuring competency at COMAH sites as this fitted well with plans already underway at WOSL.Due to organisational changes, WOSL had greater autonomy from their parent ■■

companies and, with this came new responsibilities, including establishing health and safety initiatives such as developing an effective CMS.

How is the CMS being developed?

WOSL and ERM recognise that competency is important to individuals; with intrinsic and extrinsic job feedback providing a feeling of success and ‘self efficacy’. This feedback supports workers’ sense of being competent and their awareness of how their actions are impacting on safe site operations. It also identifies practice gaps that help people to perform better.

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Guidelines for Competency Management Systems for Downstream and Petroleum Sites (COGENT (2011)) is based on six principles that are contained within the CMS cycle (see Figure 1).

Figure 1 The six principles of competence assurance

This cycle is underpinned by the management principles of ‘POPMAR’ (HSG65) and is similar to the CMS cycle published by HSE in 2002 and by the Office of Rail Regulation in 2007.

WOSL and ERM began by defining the scope of the CMS in line with COGENT guidance (2011). As part of this process, and based on experience and industry wide statistics, a team of subject matter experts decided on the safety critical tasks at WOSL. Over 20 safety critical tasks were identified (eg permit to work), together with related sub-tasks (eg completion and checking of work permits).

Major accident hazard scenarios were identified and plotted on a hazard identification and risk assessment matrix (ie based on the severity and likelihood of the scenario). The aim of this exercise was to prioritise the scenarios. Each scenario was presented as a bow tie diagram (ie a diagrammatic representation of hazardous events including threats, barriers and consequences). This helped to visualise the possible threats leading to the scenario, determine the subsequent consequences of the scenario and the potential barriers (eg control measures and mitigation factors).

In order to systematically consider the types of human failure that may occur when performing the safety critical tasks, ERM and WOSL carried out a human error analysis for each task, whereby each step of each task was assessed to determine the potential human failure and/or the opportunity to recover from this failure. In line with HSE’s Human Factors Roadmap, the human error analysis also formed

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the basis of the standard operating procedures (SOPs), with the understanding of why errors occur and the different factors that make them worse, helping WOSL to develop and improve their procedures.

ERM and WOSL ensured a high level of worker engagement, where operators and supervisors were actively involved in the updating of the safety critical procedures, using human factors professionals to apply design usability principles, like consistency, clarity and navigability. This noticeably improved the usability of critical operating procedures.

All this information makes a valuable addition to WOSL’s COMAH safety report, helping to demonstrate how the competency of staff, particularly in relation to safety critical tasks, is assured on site. The linking of the CMS with the COMAH safety report is outlined in the COGENT guidance (2011).

To facilitate the mapping of competency to the safety report, ERM ran workshops with WOSL employees to identify on which of the safety critical tasks they have an impact. Figure 2 is a photograph taken at the workshop, and shows WOSL staff and management all involved in the mapping exercise. This was found to be beneficial to all those involved, as it highlighted that everyone had a role to play in reducing accidents. In addition, individuals reported that this task had highlighted the impact that they have on safety and accident prevention.

Figure 2 Everyone at WOSL gets involved with the mapping exercise

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Feeding the results of the workshop into the safety report highlights how the safety report is a living document, the importance of which in reducing accidents is recognised by all WOSL employees. The active participation of the workforce in the workshop demonstrates how WOSL senior managers together with front line operators own the safety report, with all employees now being even clearer on their role in accident prevention.

How is the CMS being implemented?

In order to implement the CMS, all WOSL staff who carry out safety critical tasks are assessed against the competency standards for the job role. The existing standards have been in place since 2010 and there are plans to carry out a job analysis to systematically review the job description competency matrix to integrate it into the newly established CMS, in line with COGENT guidance (2011).

One method of assessment is through appraisal systems and the first stage of the WOSL appraisal system is for jobholders to assess themselves on the criteria laid out on the competency matrix. This is followed by a discussion with their line manager to seek agreement on their performance against the criteria. This process identifies where the individual’s knowledge, skills and experience gaps are. Having established where the gaps are the line manager and jobholder work together to address these gaps by developing a training plan.

The development and maintenance of competencies is primarily through qualifications, training and supervision. Evidence of individual competency is captured in the CMS records and WOSL have various methods to monitor competence, depending on the activity and skill type, for instance:

direct observation;■■

indirect information gathering (eg systems data);■■

emergency exercise simulations;■■

written and verbal questions;■■

open questions in performance interviews;■■

multiple choice question tests;■■

post-incident review.■■

The WOSL team competency matrix provides an overview of the training requirements. It shows the current and required level of training for the team. It provides a framework that enables the business to define minimum competence, together with the flexibility and cover required for the team to function effectively.

The WOSL team competency and training matrix is regularly updated centrally and gives an overview of the team competencies and training requirements. The matrix provides details on the collective set of skills and knowledge to facilitate cover, flexibility and to assure team competence.

By monitoring the competency and training matrix, team leaders are able to measure the team’s level of competence against the standards and requirements of the job. The competency and training matrix is used on an annual basis as part of the appraisal conversation and when individuals move to a new role.

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Assessing and maintaining the CMS

For the ongoing assessment and maintenance of the CMS, WOSL will be:

reviewing competence standards in light of critical task analysis and risk assessment;■■

conducting safety culture surveys to identify areas for improvement;■■

maintaining the competence of CMS managers and assessors;■■

assuring ‘proof of competence’ through the CMS and/or by mapping evidence ■■

across from a number of other different management systems; continue developing Key Performance Indicators (KPIs) such as the number ■■

of competence assessments carried out against plan and the number of task observations with non-compliance;undertaking an annual review of the CMS that could include; a) determining ■■

whether or not the CMS continues to meet its objectives; and b) identifying the availability of suitable and sufficient resources to run the CMS.

Verifying and auditing

Verifying and auditing the CMS is the final principle in the CMS cycle. Having established an active CMS, WOSL intends to audit the CMS by developing KPIs and measuring the percentage of compliance against each KPI measure. For instance, verification will be directed towards determining compliance with agreed standard operating procedures.

Application of CMS to the contractor workforce

Contractors are also expected to develop a CMS based on the COGENT guidelines (2011), linked in with the WOSL CMS and to be audited by WOSL. In line with this guidance, contractors may be categorised as type 1 contractors or as type 2 contractors, as this helps to identify where responsibility for the application of CMS lies. For example responsibility for maintaining training records lies with either the client company (type 1 contractor) or with the contractor (type 2 contractor).

What next?

WOSL are committed to establishing an effective and practical CMS, and having developed and implemented the CMS described above they are now striving to make informed improvements to the system (eg job and training needs analyses are planned that will form the basis of further development of the job description competency matrix, as well as the team and training competency matrix).

Further information

A Human Factors Roadmap for the Management of Major Accident Hazards www.hse.gov.uk/humanfactors/resources/hf-roadmap.pdf

Developing and Maintaining Staff Competence (Second edition) Office of Rail Regulation www.rail-reg.gov.uk/upload/pdf/sf-dev-staff.pdf

Guidelines for Competence Management Systems for Downstream and Petroleum Sites COGENT, UPIA 2011 www.cogent-ssc.com/Publications/CMS_Web_Version.pdf

Competence Human factors briefing note no. 2 HSEwww.hse.gov.uk/humanfactors/topics/02competency.pdf

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Published by the Health and Safety Executive 11/12 Case study WOSL Page 6 of 6

Successful health and safety management HSG65 (Second edition) HSE Books 1997 ISBN 978 0 7176 1276 5 www.hse.gov.uk/pubns/books/HSG65.htm

This document is available at: www.hse.gov.uk/pubns/casestudy#.pdf

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