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70 The guidance on maintaining competence includes requirements for monitoring, and reassessing,
the performance of staff to ensure performance is being consistently maintained and developed.
Guidance is also given on updating of the competence of individuals in response to relevant changes.
71 The integrity of the competence management system will only be maintained if it is regularly
checked against the design, and improvements made when needed. Some form of verification
and audit of the system should be undertaken. Verification should support the assessors, check
the quality of the competence assessments at a location and individual level, including the
competence of the managers operating the system, and ensure the assessment process remains
fit for purpose. Audit should inspect the whole competence management system and judge
compliance against the defined quality assurance procedures.
72 The ORR guide can be used from any point in the cycle for improving existing systems, or for
setting up and implementing new competence management systems. It describes:
the principles and factors that should be considered in any CMS;
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how to ensure that the competence of individuals and teams satisfy the requirements of
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existing legislation;
guidance and responsibilities relating to medical and physical fitness.
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73 Appendix 1 of the ORR guide defines what is meant by fitness. It provides an outline of fitness
assessments, and of the roles of those involved in the process (eg the responsible doctor). These
principles are similarly applicable here.
74 The ORR guide refers to the need for directors and senior managers responsible for the
overall policy of the company to be aware of the general objectives and benefits that may result
from the use of the guidance. However, implementation is more likely to be successful if directors
and senior managers are more than just ‘aware’, but demonstrate commitment to the process.
75 A key issue for dutyholders to consider is the competence of staff in relation to the control of
major accident hazards, and how this is identified, assessed and managed. Major accident hazard
competency needs to be appropriately linked to the major accident hazard and risk analysis and
key procedures. The aim is to assure competence in safety critical tasks, and associated roles
and responsibilities.
76 Competency in major accident hazard prevention is necessary at all levels in the organisation,
not just the front line. There should be standards set for competency at all levels, and these
should be process/job specific.
77 The research report
Competence Assessment for the Major Hazard Industries
RR086 is also a
very useful reference for COMAH sites. This aims to provide:
an authoritative view of what comprises good practice in the field of competence assessment
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in relation to control of major accident hazards; and
a model of good practice.
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78 The National or Scottish Vocational Qualification (NVQ/SVQ) system can provide some general
and some site-specific competencies, but they are not usually linked to major accident hazards.
Dutyholders of COMAH sites need to adjust their systems to make this link.
79 Cogent, in conjunction with the petroleum industry, has developed National Occupational
Standards (NOS) for:
Bulk Liquid Operations (Level 2); and
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Downstream Field Operations (Level 3);
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Downstream Control Room Operations.
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