Human Factors in COMAH
The HSE have 10 key topics: how do you know which apply to you?
Human and organisational factors have contributed to the causes of several incidents, in a variety of safety critical industries. There are important lessons for all major hazard industries detailed within the investigate reports, and it is learning such as this that focuses the expectations on COMAH sites.
Many companies, even if aware of ‘human failure’, will still focus on engineering reliability, but it is important not to forget the human element. For example, the assurance of reliability of an alarm in a control room has two parts: firstly there are the engineering aspects such as redundancy, testing etc. However, the human response is equally important to ensure that the operator will always respond in the correct manner, considering factors that may result in an inappropriate response (such as tiredness, distractions, overload, prominence of the alarm indication etc.). Only when such factors are identified and managed can human reliability be assured.
There is a wealth of guidance available, but with so many human factors aspects to consider, it can be hard to know where to start to provide the required ‘demonstration of a structured, systematic approach to managing human performance’.
C3’s human factors experience has been gained working on high hazard sites that are regulated under COMAH. We can therefore provide proportionate practical tailored solutions that are directly linked to your hazard profile.
Other relevant topics:
- Competence Management
- Critical Procedures
- Human HAZOP
- Identification of Critical Tasks
- Alarm Management
- Organisational Change
Ensuring competence involves so much more than just having a training plan.
The majority of Intervention Visits relating to competence follow the CA’s Operational Delivery Guide ‘Inspection of Competence Management Systems at COMAH Establishments’.
The HSE carries out the inspection in two parts:
- Part A is used to give a broad overview of how the Operator is managing competence and focuses on whether key personnel are achieving the desired outcomes when undertaking critical tasks. It is used where there is direct evidence of competent people undertaking critical tasks in a competent manner, i.e. there is evidence to suggest that the Operator has an effective CMS, is managing and implementing it, and it is delivering desired outcomes.
- The Part B Inspection is a more in-depth inspection of the management of competence, and is normally only undertaken when the initial Part A Inspection gives rise to concern about the way in which competence is managed. However, a Part B Inspection can also be considered at sites where, from previous regulatory activity, the CA already has significant concerns regarding the management of competence, such as during the assessment of a Safety Report. In such circumstances, it is unnecessary to undertake a Part A Inspection first.
Although the Competence Delivery Guide is freely available on the HSE’s website, it is written to cover a wide range of installations; therefore it can be difficult to know how to apply it to a specific site and its risk profile.
C3 consultants can provide you with a variety of support, ranging from a Human Factors Health Check of your systems against the HSE’s expectations up to the implementation of a Competence Management System.
Identification of Critical Tasks
Safety Critical Tasks should be closely linked to a site’s potential major accidents – do you know what yours are?
According to the Safety Report Assessment Manual; ‘A human action is Safety Critical if either its failure could cause or contribute substantially to a major accident, or its purpose is to prevent or limit the effect of, a major accident’.
Safety Critical Tasks are generally categorised into the following groups:
Human Error Initiation
Actions that have the potential to initiate an event sequence, e.g. inappropriate valve operation causing a loss of containment.
Actions required to stop an incident sequence, e.g. activation of ESD system.
Escalation Prevention Actions
Actions that may escalate an incident, e.g. inadequate maintenance of a deluge system.
Some sites will instinctively know some of their Safety Critical Tasks, but you need to be able to demonstrate that you have identified all of them. C3 can help you to identify your Safety Critical Tasks by applying a systematic screen to your existing PHA to identify tasks in each of the three categories listed above. We can then help you to analyse the potential for failure using our Human-HAZOP methodology.
The potential for human error cannot be eliminated, so must be managed.
Human-HAZOP is a Risk Control System (RCS) used to ensure that appropriate controls are in place to manage the performance of humans engaged on Safety Critical Tasks so as to prevent, control and mitigate major accident hazards (MAH).
C3’s Human-HAZOP methodology has been tried as tested on numerous Upper Tier and Lower Tier sites, receiving positive feedback from the CA as it aligns with the guidance within the HSE’s Human Factors Toolkit. The methodology can also be adapted to suit the proportionality of the site and its risk profile: including enough detail to provide the right outcome but not necessarily including all the layers of assessment detail that would only be required for industries such as rail and nuclear.
Our methodology begins with a walk-through / talk-through Task Analysis. For any failures that can result in significant consequences, a detailed Human Reliability Assessment is carried out, which includes identifying and optimising the Performance Influencing Factors (PIF).
We also provide training and mentoring to allow site personnel to carry out future assessments in-house, and can also help with the follow-on work around the relevant procedures, training and competence management.
Procedures are used to minimise errors, and should therefore be managed like any other Risk Control System.
Operating procedures may not be the best way of controlling hazards, at least not as the sole defence against human error. Problems with procedures are linked to numerous incidents and frequently cited as one of the causes of major accidents. The inadequate management of procedures have not only contributed to disasters such as Bhopal, Piper Alpha and Clapham Junction, but also to fatalities, personal injuries and ill health. The main causes are too much reliance placed on procedures to control risk, a failure to follow safe working procedures or the use of inadequate procedures.
Procedures may include step-by-step instructions, checklists, decision aids, diagrams, flow-charts and other types of job aids. There must be a system for managing procedures, covering how they are generated and reviewed, and the development of procedures should be informed by appropriate risk assessment such as Human-HAZOP. Participating in the risk assessment is also a good method of ensuring that the user is involved, which is important to ensure their buy-in.
C3 can help you to identify your Safety Critical Tasks and Procedures and carry out a Human-HAZOP to ensure that the procedure is appropriate, fit for purpose, owned, up to date and above all – used!
Do you know how many alarms you have? Are they really alarms, or just alerts?
Changes to an organisation should be managed as carefully as changes to equipment.
Organisational changes such as reducing staffing levels, using contractors or outsourcing, combining departments, or changes to roles & responsibilities are usually not analysed and controlled as thoroughly as plant or process changes. Such changes can, if inadequately conceived or implemented, have a detrimental effect on safety. Even subtle changes to organisations can have significant impacts on the management of hazards.
C3 can help you to carry out an Organisational Change Risk Assessment in order to identify and assess the direct and indirect effects of a proposed change.