This blog asks how do we assess competence with functional safety? Specifically, I'm thinking of the competence of people who, on a daily basis, live with high hazard processes, machinery, or who work on projects involving safety systems. Training is part of the picture, but certainly not the full story.
When I have been involved with assessing functional safety on some major process industry projects (see independent FSA), I typically have a problem with how to a conclude anything meaningful about the competence of individuals. I usually find that companies do not have competence management properly developed, even for roles involving safety.
Sometimes competence is fully evident when I complete an assessment and there is very little, if anything, to criticise about a piece of work or a project document. Often I get to meet and interview people about their activities and I can tell within a short period of time the depth of their knowledge. At other times, I look at the output of a safety-related activity and I wonder how it got approved when it contains so many inaccuracies and mistakes.
All of us make mistakes, but in some cases the mistakes are clearly related to not having sufficient depth of knowledge on a topic. After all, "A little learning is a dangerous thing" [ref.1].
Five stages of competence
The issue of unconscious incompetence is definitely a bad scenario. But, how can someone be aware of what they don't yet know?
The UK Health and Safety Executive produced valuable guidance documents in this area [ref.2], showing the different competence stages for an individual as something requiring continuous improvement - see Figure 1.
Figure 1: Adapted from HSE document [ref.2] - competence stages for the individual.
Five possible stages of competence are presented in Figure 1 for an individual presented with a new task, which I've labelled A to E. All of us start with not fully knowing our own limitations (stage A) when something completely new is presented to us. To move from stage A to stage B relies on there being not only an individual with inquisitive nature, but also a solid competence management system in place, represented by the green arrow between the two stages.
It should not rely solely on the individual to become acceptably competent. Some people will naturally seek out information, but that may only lead them some way down the path from stage A towards stage B. If there is no training or development of the individual for the new task, then they cannot be expected to reach stage C or D and be performing competently as a matter of routine.
Note that Stage C requires training, development AND experience. Training itself is not sufficient, albeit training is an important aspect of competence. Development will usually come from some form of mentoring and experience will come with doing the task and having someone already competent review it. Only when all three elements are combined can someone move into Stage D - the ideal stage. To stay in that stage, they need continuing training, development and experience - hence the green arrow back to stage C.
Figure 1 also shows some dotted red arrows leading from the ideal stage. In the HSE guidance these are labelled as "natural deterioration". The notion is that we can all become stale with our knowledge if there is no continuing update, and of course we can all develop bad habits by assuming "we've always done it this way", without fully understanding, for instance, that technology moves on at a very fast pace. We can also be presented with further new tasks.
Experience with Functional Safety Assessment Projects
What I have found, in completing the independent FSA on many projects, is that few companies are treating the competence management requirements of IEC 61511 edition 2 [ref.4] with sufficient rigour. This is especially the case with hired help, where the general assumption seems to be that "experts" know best when in actual fact they should be subject to formal competence assessment.
All of the above is very theoretical, but it does help to illustrate that competence management is required, not just good people. This is especially important when the tasks people are doing or overseeing are safety-related.
Roles, activities and competence criteria
If you take some time to read through the HSE guidance [ref.2], you will see that competence management actually starts with defining roles comprised of individual work activities that will need completing. For each role, the competence criteria must be carefully specified, and then each individual doing a specified role can be measured against the competence criteria.
Reading further into the HSE guidance [ref.2] and beyond, you will soon discover that setting up a competence management system (CMS) is no trivial task. So what advice is out there to get started?
It is certainly possible to break down the respective life-cycle phases of a project involving safety-related systems into individual work activities. Once activities are fully defined, then roles can be defined with minimum criteria set at different levels of competence.
Something like this was proposed at a somewhat high level in the Engineering Equipment and Material Users Association (EEMUA) publication 222 [ref.3], which was published prior to the second edition of IEC 61511. EEMUA 222 could be used as a starting point, but in my view it requires some significant adaptation at a practical level.
References
[ref.1] Alexander Pope - Poet - 1688-1744.
[ref.2] HSE, 2007: Managing competence for safety-related systems - Part 1: Key Guidance.
[ref.3] EEMUA 222, 06-2009 - Guide to the application of IEC 61511 to safety instrumented systems in the UK process industries.
[ref.4] IEC 61511: Functional safety of safety instrumented systems for the process industry sector. This standard is now variously known as IEC 61511 edition 2:2016 or BS EN 61511:2017 in UK and ISA 61511 in the USA.