Process accident history is awash with many examples of apparent incompetence involving safety instrumented systems (and other protection layers), some of them resulting in literally billions of dollars of losses, not to mention large environmental impact and loss of human life.
So, developing and maintaining competence in the area of important protection layers such a Safety Instrumented Systems (SIS) would seem to be a "no-brainer".
However, in the real world, important competence development methods, such as attending training classes, seem to get pushed onto the back burner especially when times are tough. So, what is the typical cost of training personnel in this field of engineering?
First, we need to introduce the context of competence and what the internationally recognized standards require.
The IEC 61511 process sector standard for SIS was revised and re-published in February 2016 and states:
"Persons, departments or organizations involved in safety life-cycle activities shall be competent to carry out the activities for which they are accountable."
IEC 61511:2016 clause 184.108.40.206
The above clause has existed since the original standard published in 2003. However, a new clause in the 2016 edition of the standard now additionally states:
"A procedure shall be in place to manage the competence of all those involved in the SIS safety life cycle. Periodic assessments shall be carried out to document the competence of individuals against the activities they are performing and on change of an individual within a role."
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To The Safety Instrumented System Safety Life-Cycle.
IEC 61511:2016 clause 220.127.116.11
This new requirement brings some more explicit instructions that were not in the original standard, namely:
- There must be a competence management procedure (sometimes known as competence management system) put in place.
- Periodic assessments of individuals must take place, and be documented.
- When there is a change of individual in a SIS life-cycle role, the assessment of a new individual in that role must be completed and documented.
Given that there are both the desire and need for companies with SIS projects to comply with the requirements of the IEC 61511, there is also a need demonstrate that sufficient competence exists in key roles, and that it is being actively managed and developed.
We might first approach the issue of developing a competence management procedure to comply with the existing and new requirements in IEC 61511 with the typical opening questions of "Who?", "What?", "When?", "Why", "Where?", "How?" and finally, "How much?".
The whole subject of IEC 61511 is related to Functional Safety of Safety Instrumented Systems (SIS), so it would seem very logical that solid functional safety competence should first be demonstrated by all Electrical, Control and Instrumentation (EC&I) engineers and technicians involved with SIS design, design review, installation and commissioning, testing and maintenance.
So, a good place to start would be with ensuring that there is at least one competent technical authority available in this discipline who can propose the minimum requirements for all roles in the EC&I discipline, and then make assessments about individuals against those minimum requirements.
However, anyone involved with functional safety from a "Safety Integrity Level (SIL) determination" perspective will know that there are multiple other disciplines involved in the assessment of a target SIL. So, where do these other personnel get their assessment of competence to be involved in such studies? Must every discipline have a designated "functional safety expert" that can make an assessment of others within it? That would seem extreme. In practice, I would suggest that having at least one additional person with a similar level of functional safety knowledge as the EC&I technical authority would be sufficient; perhaps a process safety professional to give it a balance of disciplines. These two independent people from different disciplines should then be able to provide the assessment of others for most safety life-cycle roles, probably still with advice and support from other disciplines when and where required.
As for the "who" should be assessed in total? The answer is that ANYONE linked to the SIS safety life-cycle should be assessed as meeting the minimum requirements for their role. That means operators, maintenance personnel, Safety/SHE personnel, process engineers and chemists, project engineers and managers, among others. Essentially, think of it applying to anyone that gets involved in either a team study related to SIL or any design, review, installation, test or maintenance activity involving either hardware or software of the SIS.
IEC 61511 lists nine elements that form the basis of "what" should be assessed and documented when considering competence. Without repeating all those elements verbatim here, it is clear that there is an expectation of assessing a mix of existing knowledge, level of training and experience, in the given discipline area or safety life-cycle role. The list also includes more general knowledge elements such as legal and regulatory requirements, management and leadership skills and understanding of the consequence of hazardous events.
My suggestion would be that a competent "functional safety authority" in any hazardous process site would already be aware of the existence of IEC 61511 for some years now. Some will have used that standard as a reference source on SIS projects implemented in the past 12 years, and some will not. A few will already have caught up with the latest requirements in edition 2 published this year. As the new standard "cancels and replaces" the first edition published in 2003 (edition 1), it would therefore be pointless to reference a new SIS capital project or SIS modification against edition 1. So, any new SIS project/modification must consider this new competence requirement for the team involved. That assessment should include sub-suppliers and contractors in addition to internal personnel.
I would also suggest that even without a project or modification, a competence management procedure should be planned as soon as possible. If not, the "periodic" part of the new requirement can never be fulfilled.
This question was partly answered in the opening requirements of this article. If you are involved with supplying, installing, operating or maintaining an SIS or related services., the only way around not implementing an SIS safety life-cycle competence management procedure is to ignore the new requirement of clause 18.104.22.168. Perhaps this can be justified for some time while a plan is developed, but probably not without a plan.
This seems to be a question that doesn't easily apply, but on reflection, competence assessment does have important "where?" aspects. The key assessment of an individual will be "on the job", so must it be made in the context of the performance of whatever the role is. That might be by witnessing a physical activity or simply reviewing a piece of documentation that has been produced.
Other than "on the job assessment" and development, functional safety training is a key aspect for personnel involved in safety life-cycle roles.
Many companies are used to sending people on training classes, and in some cases even asking personnel to take independent tests (e.g. CFSP/CFSE or TÜV FS Engineer) to demonstrate their understanding.
Very few companies are currently using the development of the internet and web-enabled devices to expand that training and testing of personnel by using e-Learning for such technical topics as functional and process safety. However, this is destined to change in the future as new generations of managers, engineers and technicians get to see the clear benefits. It is unlikely and probably ill-advised that e-Learning would ever replace face-to-face training completely, but it can very clearly enhance the frequency of access (material is available 24/7), the frequency of testing individuals (online tests can be taken regularly), and it can achieve this without any travel or "off-site" costs - a very significant benefit.
To put an estimate on the overall cost of developing and maintaining a competence management procedure is impossible without knowing a specific case. Our usual approach is to provide a gap assessment against IEC 61511 requirements, followed by a budget estimate of the costs for the specific case.