1. Health and Safety Executive Health and Safety Executive Managing competence for safety-related systems John Cryer Health & Safety Executive

2. Available Free download in 2 parts from http://www.hse.gov.uk/humanfactors/comah/ competence.htm. Split to make it more readable. –Key guidance. –Supplementary material.

3. History 2003. HSE + IET + BCS agreed to develop guidance on “Managing Competence for Safety-Related Systems”. Special reference to IEC 61508, complex safety- related systems for protection and control. 2 rounds of industry consultation, ended 2006. 30+ submissions from individuals, organisations and associations. Aerospace, nuclear, offshore, rail transport, petrochemical, chemical processing, electricity generation and distribution, C&I contractors, construction, training and assessment. Published in July 2007.

4. What is competence? Competence is the ability to undertake responsibilities and to perform activities to a recognised standard on a regular basis. Competence is a combination of practical and thinking skills, experience and knowledge. Qualifications, experience, personal qualities (communication, supervision …)

5. What is competence management? Systematic organisation of training and experience to demonstrate suitability for a specific task. Appropriate documentation – NOT an exercise in bureaucracy! BUT should be auditable when evidence is asked for.

6. Legal duty HSWA etc. Duty to control risks, both to employees and to those affected by their work. Competence to work safely. Competence to deliver a safe product. Competence to manage major hazards etc. Guidance is not compulsory. Use your own scheme, if you’ve got a good one. Consensus of industry, institutions and regulators indicates good practice. Persuasive indication of compliance with legal duty.

7. Proportionality. How much is enough? Aim: NOT an exercise in bureaucracy. Aim: NOT an unreasonable burden on technical experts. Risk based – how important is it to get the job right? How much depends on the individual (and team) competence? Fewer backups = more dependence on competence = more attention to CMS.

8. CMS: activities, criteria, assessment, documentation Activity #1 Activity #2 John Smith–Assessment results Safety-related system software realisation SIL 2/3 shutdown protection systems, up to 1000 I/O Chemical/Petrochemical industry, onshore and offshore Duplicated/triplicated PLC architectures using IEC 61131-3 languages especially ladder logic. Mature organisation with safety experience and familiarity with IEC 61511. Transposing from requirements into design Presented design specification for PLC application of sequence control in car plant. Able to identify design constraints relevant to sequence control, i.e. checking safety conditions in every state and ensuring single entry/exits to sequences. Showed how design matched organisation procedures and identified testability aspects of design. Experienced PLC software designer but no specific expertise in shutdown system design. Activity #3 Activity #4 Activity #5 Activity #1 Activity #3 Activity #4 Role documented evidence of competence competence criteria for each role assess person against competence criteria work activities in CMS scope are defined

9. CMS in practice. 61508 lifecycle ‘functions’ hazard and risk analysis safety requirements allocation safety requirements specification architectural design hardware realisation software realisation installation and commissioning validation operation and maintenance modification decommissioning verification

10. CMS in practice Function: safety-related software realisation broken down into a set of tasks. Task requires technical skills and knowledge. Indicates training and competence needs. E.g. ‘transposing from requirements into design’, ‘coding’, ‘specifying software tests’. task requires behavioural skills and underpinning knowledge - attributes. E.g. ‘application domain knowledge’, ‘team-working’.

11. Example: 3-level competence criterion Safety-related system software realisation – Task 4: Coding Translates the specified software functional and design requirements into easily understood, analysable source code through the correct use of an appropriate programming language. Pays due heed to the requirements of a relevant coding standard (with particular regard to the safety implications of different constructs and the environment in which the code is to operate). Supervised practitionerPractitionerExpert Has coded individual modules using the relevant programming language(s) in accordance with the organisation’s programming style and commenting strategy. Has coded complete software sub-systems for typical safety-related systems, using a safe sub-set of the relevant programming language in accordance with a defined coding standard. Is abreast of the latest developments in software engineering research, particularly with regard to unsafe constructs and the circumstances in which they should be avoided, and maintains latest understanding in an organisational coding standard.

12. Uneven individual competence. Team competence. Unnecessary to have everyone expert in everything. Aim for a competent team. Individual assessment. Safety-related software realisation. Level T1T2T3T4T5T6T7A1 A2A3A4 Expert Practitioner Supervised practitioner

13. Proportionality again! How much is enough? NOT an exercise in bureaucracy. Risk based – how much depends on the individual (and team) competence? Who needs the evidence of competence? In how much detail? If the CMS lives unused on a shelf like some QMSs, then it’s not working, neither for customer nor contractor.

14. Management of change Competence isn’t permanent. People change. Technology changes. Industry standards change. Regulatory requirements change. Companies move into new markets and work. Need to audit and review CMS working. Scope still ok? Identify new training/refreshment needs. But not as a burdensome and bureaucratic task. Guidance does NOT state how much formality of CMS organisation is required.

15. Not yet competent and unaware of limitations Individual presented with a new task Unaware of a changing environment or development of bad habits Performs competently as a matter of practice and habit Competent, through training, development and experience Not yet competent but aware of limitations Stages of competence

16. 15 principles Guidance summarised in 15 high level principles. Interpret these for your own needs. Planning the CMS: what work activities are in scope? What are the competence needs? Designing the CMS: setting competence criteria. Operating the CMS: assessing, developing and monitoring competence. Managing change, audit and review.

17. Summary Competence is needed for safety of staff and those affected by their work. CMS is a persuasive indicator of good practice. Some formality of CMS is needed to ensure coverage of training and organisation of evidence. 15 CMS principles to be interpreted for your own situation. MUST NOT become an unproductive burden. Level of detail and formality of CMS is not stated in guidance. Opportunity for feedback and FAQs, see links on HSE webpage.