The topic of ‘Human Factors’ has been at the forefront of process industry regulator thinking for a number of years. It is a convenient way of grouping a number of related topic areas all involving the performance and limitations of the human being when involved in industrial, high hazard processes.
If the regulatory and legislative framework is to embrace human factors in the near future, what does this mean for the industry and what should we be doing about it?
Those companies operating in environments with strong and evolving regulation (such as parts of Europe, some sectors within the US) should be well placed to cope. Regulation of human factors issues will become more formal and possibly demanding, but will probably not take surprising and unexpected turns. For example, those companies operating in the UK and subject to the increasing demands of the COMAH regulations in this area should be well prepared.
Those companies to whom this is new or currently a bit of a ‘box-ticking’ exercise, should be preparing to pay a bit more attention to the topic and getting ahead of coming changes to public, regulator and legislator pressures in this field. Even where there is little regulatory or legislative framework, the insurance industry is becoming increasingly aware of national and global standards and expectations. Insurance as well as regulatory inspections will be looking at the key human factors topic areas in increasing detail.
Fortunately we can learn from each other, not only within companies with a global perspective, but also through industry bodies. While it can sometimes be difficult to find commonality with a plant making a different product with a different technology, when it comes to human factors we all share the same basic component, the Mk. 1 human being. Humans are subject to the same basic issues whether manufacturing methanol, supervising a pipeline, unloading a tanker or changing a grade. In fact, for those who want to truly learn and improve, as well as simply comply, there is a rich seam of learning and good practice available from aerospace, healthcare and other high risk industries.
One final area that may have an impact in the immediate future is where the topics of risk assessment, competence and human factors overlap. As regulations such as Seveso and the various CFRs are updated and overhauled, the need for human factors to be incorporated in to operations and particularly into the process of risk assessment is likely to be formalised. The tools and methodologies required to formally analyse human error and associated risk will become increasingly expected or even mandated.
At the same time, regulators such as the UK HSE are increasingly becoming interested in the topic of competence as applied to the hazard and risk assessment process. The recently announced competency inspection topic by the UK HSE explicitly warns operating companies that this will be the case . In the US, recent industry events have highlighted deficiencies in hazard and risk analysis that will inevitably also focus on the competence of individuals and organisations in this area. Given the need to include rigorous human factors input into the risk assessment and management process, and the need to demonstrate competence of individuals and organisations in this area, it might be worth considering adding a human factors professional to your process safety team.