On Monday, I provided a link to the Center for Offshore Safety’s (COS) industry guidelines on meeting the SEMS skills and knowledge verification requirements. Here is the link to the COS document and here is the link to the blog I wrote. There was a great deal of interest and I thought it would be worth analyzing the guidelines and what it may take to comply. Here’s my breakdown of the document:
Why – SEMS requires operators to verify that contractor personnel have the skills, knowledge and experience to perform their jobs safely and effectively. The COS guidelines are an attempt to help companies create a Skills and Knowledge Management System (SKMS), which is defined as “A systematic process that serves to control, in a logical and integrated manner, a cycle of activities to establish, assess, and develop the skills and knowledge of identified individuals for successful performance of work.”
Translation: Companies need to
- figure out what specific skills and knowledge are required for each job;
- have a process to assess those requirements; and
- fill in any gaps in worker competence.
What to focus on – It will be up to each company to decide what tasks are critical to doing the job, but the COS guidelines stress that companies should give a priority to tasks that relate to job hazards, regulatory requirements or lessons learned from previous incidents. The document mentions barriers several times. Barrier management is a fundamental of safety management concepts like the “Bow Tie” model of hazard controls. It is widely used by the large oil companies and is something contractors should be familiar with. You can find a good presentation on the topic here.
Assessing tasks – The document gives a number of options for assessing workers, but makes it clear that the process should provide “performance-based evidence that an individual can successfully perform a role and/or task” and that companies should consider field-based assessments and should aim for a process that can be done consistently.
Assessment frequency – The document doesn’t say how often workers should be assessed, but says companies should consider several factors in deciding frequency:
- New hires
- Assignment to new roles and/or tasks
- Re-assessments following remediation of gaps
- Non-routine, infrequent, and emergency situations
However, this is one place where industry practice has already been established. Most offshore operators now require annual contractor personnel evaluations, so that is pretty much the standard.
Assessing the assessors – The group that put this document together understood that the effectiveness of any verification system depends on the the person who does the assessments. The document says that companies should make sure their assessors meet the following qualifications:
- Skills and knowledge
This is a very important point. Most industries that adopt competency evaluations for workers quickly find that the integrity of the evaluations depends on the professionalism and objectivity of the people doing the evaluations.
Auditing – The document recommends that companies have an audit process for their management system. It does not say whether audits should be done by third parties or can be done internally. In practice, it is likely that operators will audit their contractors, but it looks like contractors have the option of auditing their own programs.
Records and Documentation – One of the main purposes that this document was written was to help give operators and contractors a common understanding of what it takes to meet the SEMS skills and knowledge requirements and that rests on documentation. Significantly the document includes audit records, meaning that contractors who set up an SKMS need to consider how they document their individual worker assessments and any audits they do of the program.
As noted before, my company, Lifeline Strategies, and OQSG, a leader in pipeline industry worker evaluations have developed a program called SEMSReady which helps contractors develop and meet the requirements of SEMS skills and knowledge verifications. Let us help you with your system. Contact me at email@example.com.