Competence Assurance beyond compliance and certification
1. Competence assurance beyond compliance and certification.
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Mervyn R. Stewart - Founder: Strategic Competence Assurance Systems Ltd.
For Safety purposed Competence Assurance, the quality of framework, the processes and the
practices in place should be the prime focus. Certification, if pursued should be secondary. When
assessing the performance or success of risk-based proven competence assurance initiatives,
certification of individuals can be a misleading indicator of system performance.
The Piper Alpha incident resulted in significant strengthening of regulations incorporating worker
competence into the structure of Safety Management Systems for major accident hazard (MAH)
environments in the United Kingdom. Evidence of this resides in the legislative updates, the presence
of active regulatory oversight and industry supporting organisations (e.g. Health and Safety Executive
(HSE), Step Change in Safety, SQA, ECITB, E.I. and OPITO etc.) and the substantial presence of
Competence Assurance Management Systems (CAMS) companies and consultants across the British
Oil and Gas Industry. In the U.S.A initiatives of the BSEE and SEMS suggest that the Deepwater Horizon
incident is set to become for Oil and Gas sector Competence Assurance in the United States, what
Piper Alpha was for the U.K.
In most cases, safety system focused workplace CAMS revolve around units of competence structured
in similar fashion to those used in national vocational qualifications (NVQ) tweaked to incorporate
task and site/equipment risk in a case/company specific manner. Consequently key features of such
systems include; written CAM policy and procedures, trained and certified assessors steeped in the
particular discipline, trained and certified internal verifiers (internal quality assurance persons) and
risk influenced units of competence.
However unlike vocational qualifications frameworks, safety focused workplace CAMS are not
purposed with the award of a credential. Their primarily concern is with the management of safety
through personnel capability management. In some jurisdictions, proof of workplace competence
assurance management (CAM) is a matter of compliance with regulations.
While some companies do not include certification as a feature of their CAMS, others do so in various
forms. Some award certificates using customised awards from recognised NVQ bodies such as SQA
and ECITB, to employees upon successful completion of their assessments, some forego individual
certification and instead seek certification of their system from recognised leading bodies (such as
OPITO) and other companies seek neither individual nor system certification and instead rely entirely
on their internal resources and processes for their CAMS. It should be emphasised that the HSE has
published and regularly updates its recommendations outlining good practice for safety focused
workplace CAMS. However it does not currently mandate organisations to adopt its suggested
structure.
When issued by a credible body, certification implies that a workplaces’ CAMS is being operated in-
line with the prescribed quality assurance requirements set out by the certifying body. Certification
also provides an effective way of recording the state and status of a company’s CAMS. However,
overreliance on using certification as an indicator of the efficacy, reliability and appropriateness of
safety focused workplace CAMS can be detrimental.
The necessarily customised and company specific nature of workplace CAMS means that in most cases
the certifying body is totally dependent on the company to provide information under the assumption
that accurate and up-to-date policies and data will be submitted. A key point of concern reported in
an OPITO sponsored research paper “Tick Safety not Boxes: Competency and Compliance in the oil and
gas industry” (Marcella, Pirie and Doig 2011) is the reported ticking-the-box culture that has found its
