Worker Competency

Worker Competency

I’ve been involved in project HSE for the past decade and in that time, I’ve seen this subject go from not being asked for, to becoming one of the major roadblocks for prime contractors and onboarding subcontractor companies.

The most common reason for worker competency issues when requested on a project, is not that the workers aren’t competent, it’s that they are now judged by an opinion, usually someone appointed by the prime to “determine” competency. Often the individual that signs off on competency for a project is a subject matter expert (SME) in his division, which may or may not relate to the worker’s task. An example would be an “expert” in roadbuilding with heavy equipment being appointed as the SME on heavy equipment and deciding on whether a feller buncher operator is competent or not. The SME has never operated this type of heavy equipment but will rely on his experience to presume what issues may be present during its operation. This often leads to a paper exercise, which has little value, other than a form that states the exercise was completed.

For subcontractors who come to a project with specialized equipment, an active internal competency program must be in place prior to arriving on site. With documented experience and criteria that is specific to the equipment, terrain and task, the subcontractor can demonstrate to the prime that they have judged/determined the operators to be competent, based on observation and the workers’ knowledge of the equipment’s operation.

For a worker to operate a piece of equipment on a project, he/she must be either:

• deemed competent or
• under the supervision of a competent and qualified individual

Although this seems easy enough, the reality on site is very changeable. New workers arrive on sites daily, due to new project hires, crew shifting, equipment changes, etc. Because of this, competency and its monitoring are issues that require a structured process be in place, to ensure due diligence is established and maintained.

To build this into an HSMS, there are three elements that must be developed:

1. Develop and implement a Declaration of Experience (DOE). This is a form that asks the new worker to list his previous work experience with the type of activity that he/she will be performing on the project. This would include type and size of equipment, tasks performed that reflect similar job duties on site and length of employment performing these duties. This is a signed statement that will be available for review when onboarding onto the project. It serves as a “Ticket” to get on site, to begin working and provides an opportunity to be evaluated by whoever the prime deems as appropriate for that activity.
2. A scheduled series of observations by the crew supervisor that is documented and forms part of the competency process. These observations will occur over a short time frame and will have criteria set out to show how the individual was judged and if he/she requires more time to learn or that proficiency on the specific equipment has been achieved. Criteria that the operator is judged on should be on a conceptual level, such as factors that affect stability, knowledge of the capacity of the equipment, operator preplanning of work area setup, and hazards of operation to other workers in area, not things like equipment specifications.
3. Signoff as competent to operate the equipment as it is being operated on the project. This may differ from the operation of the same piece of equipment used for a different purpose for normal activities or a different type of project; think excavators for loading material at a pad build and the same excavator being used to dig up a buried pipeline. To perform due diligence, you must be able to show that the “competent” worker has been judged on criteria that are relevant to his/her activities on site for that project.

Although these 3 elements make up a process that provides documented proof of a system in place to evaluate the workers coming onto a project, there is an underlying problem with this approach to determining competency. When a worker is brought out to site, the site conditions are often what determines competency. Has the worker worked in this type of setting before? Think proximity to powerlines, crowded sites, steepness, or type of terrain.

These are the criteria that should be specified BEFORE the worker arrives on site, to allow the process to work properly. It’s a chicken and egg situation, in which the worker isn’t allowed to operate the equipment until he/she demonstrates competency but can’t be put in the situation due to risk evaluations that were done in the planning stage.

The scope of worker competency is also complicated by the fact that the worker will be on the LEMs (Labour, Equipment and Materials reports) once on site and will be expected to produce results immediately. There is no training area or spot where new situations can be simulated to allow the operator to acclimatize to the conditions.

Companies are well served to build a worker competency element into their internal processes that allows new workers to have the benefit of time and exposure to an ever-increasing array of tasks and their associated hazards and controls. This enables the company to supply well rounded workers to projects and the “site specific” competency elements won’t be a major roadblock due to ensuring for previous similar experience.

It’s not realistic to expect that a company can always have experienced workers available for a project, but with a planned process in place, you can have a minimum set of criteria that will allow you to maintain due diligence and adjust to new project requirements faster.

Call Brandell Safety Consulting to discuss having an automated competency program built into your HSMS!