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Looking at the available guidance on Competence, development of Standard Operating Procedures (SOPs), and HRA, the problem of managing competence on COMAH sites might seem daunting. But the success criteria are straightforward and answering five simple questions can help to cut through the fog ….

  1. Do you have a defined and workable system for managing competence?

Your Competence Management System (CMS) should control how you develop and maintain the competence of everyone involved in preventing or mitigating the consequences of major accidents. This includes front-line personnel and supervisors through to those in managerial and board positions.

  1. Is your CMS clearly linked to your own MAHs on site?

This requires COMAH-critical tasks to be identified and prioritised, and competence standards to be set, based on HRA outcomes. Training and assessment programmes can then be set to target key steps in critical procedures.

  1. Do you have a system for on-the job-training and assessment?

A structured framework must be in place to provide underpinning knowledge and on-the-job training for both routine and non-routine or infrequent activities. This will help to develop understanding of specific plant, processes and MAHs.

  1. Is there a process for consolidating training?

The system should allow for differences in learning ability and style so that training can be consolidated in a way that best suits individual learner needs. This may require provision of extra support and supervision to confirm that essential knowledge and skills have been acquired.

  1. Does your CMS cover periodic monitoring of key personnel?

Having confirmed that key personnel involved in carrying out COMAH-critical tasks have met the required competency standards; it doesn’t stop there. There should be a mechanism to ensure that performance of key personnel is periodically monitored and re-assessed, and sub-standard performance is managed appropriately. The CMS itself should also be subject to monitoring, audit and review.

Hopefully this has given food for thought in terms of what’s expected for managing competence on high hazard sites. If competence management is something you or your company would like to learn more about then be sure to visit our website and check out our training and events pages to see what’s planned for the year ahead.