The HSE released a new Human Factors Delivery Guide for COMAH sites in December 2023. However, there was no briefing note or presentation to accompany it to tell us what was different and what was the same.
A year on, I’m writing that blog to attempt to fill that gap.
If you’re new to the Human Factors Delivery Guide for COMAH sites you might as well jump straight into it. We do offer a one-day introductory course: Introduction to Human Factors to Process Safety, Loss Prevention and COMAH. This covers the 6 topics and has a walkthrough of the HSE’s Human Factors Roadmap. Check it out.
If you’re familiar with the older 2016 version and not sure about what has changed in the new version then this blog will help.
Refinement rather than revolution
The core structure and principles remain unchanged. Indeed, reading through quickly you might wonder what has changed if you were familiar with the version released in 2016. It’s a case of refinement rather than revolution.
These refinements are well though and significant for some of the topic areas.
High level summary
Here’s a high-level summary of the five main changes:
- Topic 1 (Human Performance Management) is now split into two cover proactive human factors risk assessment and incident investigation explicitly.
- Topic 2 (Human Factors in Process Design) is now split into three parts.
- There are updated references and standards, e.g.
- Energy Institute Guidance on Human Factors Safety Critical Task Analysis (2020)
- Energy Institute Report 454 Human Factors Engineering in Projects (2020)
- Updated standards for fatigue management and organizational change
- There are now success criteria for Topic 6 (Managing Organisational Factors) which can now be rated like the other topics by the HSE.
- There is a new HSE roadmap in Appendix 3, which has been spun around, with some wording and detail tweaked.
Taking a more detailed look
Front cover and formatting
More for recognizing what version you’re looking at really but if you only have the 2016 version it is dated footer of every page, whereas the new Dec 2023 version is dated with a version number on the front cover.
The only other change appears to be a slight formatting issue with the logos, which you’d hardly notice unless they were sat side by side. The other general formatting change is that the Dec 2023 version doesn’t have page numbers which is a shame, but most of the sections are numbered so it’s not as much of a loss as it could have been.
Introductions
Largely the same. Some rewording and tidying of the language. It is evident at this point that the numbers have been lost from this front section and start again in the appendices which have most of the detail of the 6 topics and the success criteria.
The only other change is that the 2016 version refers to building on the ‘HID Regulatory Model’, whereas the 2023 version refers to building on the ‘Major Hazards Regulatory Model and the principles that determine how the Chemical, Explosive, and Microbiological Hazards Division (CEMHD) directs resources’. I don’t think this has any practical implications for people following the guidance.
Front sections
Only the 2016 version has a justification section, which described the link back to the CAIRG (COMAH Competent Authority Intelligence Review Group) that analysed evidence from loss of containment events in the chemical sector, which led to the launch of this Delivery Guide.
Other sections tidy up wording but they are largely the same. The new version is more streamlined and talks less about aims and intentions, and merely says what is – so it’s a more direct and reflects the maturity of the document.
The first major change is alluded to later where the 2016 version says Topic 6 doesn’t have success criteria, the 2023 version does have success criteria for it, but both version state that due to the one-off nature of the visits they will not be formally rated.
Advice around engaging with competent external Human Factors support, but maintaining an intelligent customer capability remains unchanged.
Appendix 1 – Key topics for inspection
This is the main detail and substance of the Delivery Guide as the key topics are outlined with their success criteria.
Topic 1 – Managing Human Performance
The previous Delivery Guide was also split into two sections, which were:
- 1.1 Human Factors in MAH Risk Assessment and Accident Investigation
- 1.2 Human Reliability during Maintenance, Inspection and Testing (MIT)
There new Delivery Guide brings with it a different emphasis:
- 1.1 Human Factors in Major Accident Hazard (MAH) Risk Assessment
- 1.2 Human Factors in Incident/accident Investigation
I don’t think we should take this change in emphasis to mean that MIT tasks are being de-emphasized. Indeed, the description of the 1.1 topic area includes some new wording emphasizing operational tasks, MIT tasks and Emergency Response tasks.
This is the first time we feel the benefit of not numbering the introductory paragraphs for the individual topic areas, and listing the success criteria for each sub-topic and numbering them. This benefits the usability of the guidance.
Sub-Topic 1.2 explicitly focused on why the incident occurred rather than who, which is standard Human Factors. New success criteria apply to this area.
A more subtle change is that any reference to near misses has been dropped in the new version of the guidance. Again, we would not interpret this as meaning that near miss reporting and analysis no longer matters so much. Instead, we’d rather assume it under the broader landscape of risk management and incident investigation. We noticed this while putting together a book chapter on near miss reporting and learning.
Topic 2 – Human Factors in Process Design
This topic has not significantly changed in content, but like the other areas the new version really benefits from placing the success criteria with the sub-topics.
The three same sub-topics are in both versions but the second one has changed its name, it used to be ‘Managing Process Upsets and Abnormal Situations’. The three sub-topics are now:
- 2.1 Design of Process Control Systems
- 2.2 Alarm Management
- 2.3 Human Factors Integration – New Projects and Major Modification
Topic 3 – COMAH-Critical Communications
The content is much the same with some paragraphs swapped so the guidance reads better. Again, success criteria are now co-located with the sub-topic. Shift handover and control of work systems are still the two areas of focus.
Topic 4 – Design and Management of Procedures
There’s quite a bit more preamble and context setting in the new version of the guidance compared to the previous version. There is a different paragraph on the importance of procedures e.g. referencing major industrial accidents directly rather than referencing the CAIRG review. Supervision is no longer mentioned (there was a brief hat tip to it in the previous version), and the point is made that not too much reliance should be placed on procedures as a control measure.
We copy in one of the newer paragraphs:
“Procedures may not be the best way of controlling hazards, at least not as the sole defence against human error. The key issue when preparing procedures is to consider who the documents are intended for and what they are expecting them to be used for i.e., the procedures need to be proportional for their intended purpose.”
Procedures is a complicated area as we cover on our training – we always encourage debate about what procedures are used for, e.g. are they more for training, are they for reference or will they be used in hand. Also, what level of detail do we need for simple/complex tasks, high/low consequence tasks, and tasks that are more or less familiar. Hopefully these new words allude to this sort of area.
Success criteria 4.5 is also worth copying in here for reference:
Established a framework to optimise usability of procedures 11,12, e.g., ensures:
- COMAH-critical procedures are up-to-date and readily available at points-of-use.
- Arrangements in place to manage out of date procedures.
- The level of detail is appropriate to the task, user, and consequence of failure.
- Style, language, and layout are consistent and reflect good practice.
- Users are actively involved in the development and review process and technical content is validated during the approvals process.
- Overall, there is clear evidence of front-line ownership of COMAH-critical procedures.
Topic 5 – Competence Management Systems (CMS)
There didn’t seem to be any significant changes introduced in this section.
Topic 6 – Managing Organisational Factors
Like before this topic is divided into three sub-topics:
- 6.1 Management of Organisational Change (MoOC)
- 6.2 Managing Shift Work and Fatigue
- 6.3 Managing Resources – Staffing Levels and Workload
The headline change for the new updated guidance is that each of these subtopic areas now each have completely new success criteria, whereas this was absent before. There is quite some significant detail for each one.
Appendix 2 – Performance Rating Against Success Criteria
This is the table which refers to the inspectors scoring system – No change.
Appendix 3 – The Human Factors Roadmap
The HSE’s Human Factors Roadmap has changed significantly. Well, in some sense it is the same, it tells the same story but visually it has changed quite a bit and there are a few key details as well.
The main thing is that the whole visual workflow of the roadmap has changed. Both really start with the red box, but the older one starts at the bottom and works upwards initially, but the newer version starts at the top and works downwards, which is arguably more logically given people read left to right and up to down.
Beyond the immediate workflow changes there were five more detailed changes I’d like to draw attention to:
- In both versions of the roadmap straight after the red box we have the identification of COMAH critical tasks, however the newer version greatly expands on this area. It separates out critical task identification (with added details of where these can be derived from) and explicitly adds the prioritisation step.
- Next the three boxes that really capture the heart of the SCTA methodology appear, task analysis, failure and PIF analysis. These are three separate boxes in the older version but are grouped together under the label of Human Reliability Analysis (HRA) in the new version. Interestingly, Human Reliability Analysis (HRA) appeared to only refer to the failure mode analysis in the old version, but this now encapsulates all three elements of HRA.
- Moving to the left-hand branch associated with the consideration and addition of automation and engineering controls there are slight differences. The new version mentions allocation of function, which is to do with what to automate and what to leave to human activity.
- What is no longer mentioned in the new version is MIT tasks. MIT specific PIFs have also been removed from the right side of the schematic as well. This completes a guide wide de-emphasis of this type of task, whereas it seemed a real emphasis in the 2016 version. As we argued in Topic 1 this is still relevant but perhaps it is more assumed and so does not need explicit reference.
- Finally, ‘organisational factors’ has changed to ‘organisational change’, which we don’t count as a significant change.
Summary
Before doing this detailed comparison and review I knew of the most obvious headline changes, e.g. the addition of incident investigation as a separate subtopic, the addition of success criteria for Topic 6 and a change to the Human Factors Roadmap. However, I didn’t appreciate the more subtle changes and was not confident in what else had and had not changed.
I really appreciate the efforts to simplify the guidance, make it more usable by numbering the success criteria and listing them directly underneath where the subtopics are introduced. This will make it a lot easier to engage with.
Hopefully this will help anyone trying to bridge from the 2016 to the 2023 version of the Delivery Guide.
If you’re new to the Delivery Guide then we do offer a one-day introductory course: Introduction to Human Factors to Process Safety, Loss Prevention and COMAH. This covers the 6 topics and has a walkthrough of the HSE’s Human Factors Roadmap. Check it out.
