Last reviewed 31 July 2019
Determining the competence of employees, and then identifying the knowledge, skills, and attributes necessary to meet and maintain the required level, can be a challenge for the health and safety practitioner, writes Mike Sopp.
According to HSG65 Managing for Health and Safety: “truly effective health and safety management requires competency across every facet of an organisation and through every level of the workforce”.
All employees, no matter at what level they are within an organisation, must be competent (from a health and safety perspective) to undertake their tasks. One method of achieving competency is through the provision of adequate and appropriate training, which includes the provision of information and instruction.
According to the Health and Safety Executive, “training helps people acquire the skills, knowledge and attitudes to make them competent in the health and safety aspects of their work”.
However, determining competence and then identifying the knowledge, skills and attributes necessary to meet and maintain those levels can be a challenge for the health and safety practitioner.
Competence and functions
The words “competence” and “competent” are used comprehensively throughout health and safety related legislation, Approved Codes of Practice and guidance. Competence is a key element in promoting positive health and safety outcomes.
Competence is a demonstrable output or outcome and is about being able to perform consistently, effectively and safely, to a required standard utilising a combination of the building blocks of competence these being skills, knowledge, attitudes and not forgetting experience. See the Croner-i topic Competent Persons.
More succinctly, BS 45002 Occupational Health and Safety Management Systems states that “competence includes being able to spot hazards and assess risks as well as having the ability to perform activities in a way that protects the health and safety of workers”.
From the above, it can be concluded that there is a link between competence and the actual functions employees are being asked to perform, utilising any risk control measures required. Therefore, it is necessary to identify those functions to enable the risk control measures and competence requirements to apply those control measures to be identified.
As stated above, the HSE suggests competence must be assured at all levels of the organisation and therefore the functions at each level must be analysed. Clearly, in large organisations it will be necessary to scope and set parameters to ensure the analysis is manageable but, in doing so, the practitioner could also break down employees and contractors into four groups as follows.
Workers: those undertaking everyday work activities within the scope of the analysis.
Specialists: those undertaking statutory specialist functions, such as first aiders, fire wardens, risk assessors, etc.
Supervisors: those supervising workers, eg asbestos remedial work, roof work, machinery or diving operations, with responsibility for ensuring risk control measures are applied.
Managers: those with responsibility for managing sections, services, departments and organisations with overall responsibility for applying health and safety.
The practitioner has a number of options to assist in this identification of function, including a review of organisational structures, job descriptions or person specifications, performance management procedures, health and safety policies (to identify roles and responsibilities) and the completion of job safety analysis.
The latter, in particular, will enable a job to be broken down into a sequence of steps. These steps allow you to identify the health and safety hazards and any required protective measures through an assessment of the risks associated with the hazards.
How to develop a competence matrix
The outcome of the above analysis should be a comprehensive understanding of the functions (and tasks) at each level within the scope of the analysis, along with the associated hazards, risks and control measures required.
From this, it is then possible to identify the skills, knowledge, attitudes and experience required (ie competence) to safely undertake the work.
As a simple worked example, if the job safety analysis identifies that employees must work at height during maintenance work, the obvious hazards or risks associated with this may be controlled by the use of a tower scaffold, which operatives may also have to construct and dismantle.
The Work at Height Regulations 2005 require all persons working at height to be competent using the relevant equipment. This also includes those who organise, plan and supervise such work.
This is supported by the HSE, which notes that the tower selected must be erected and dismantled by “people who have been trained and are competent to do so” and that “those using tower scaffolds should also be trained in the potential dangers and precautions required during use”.
From this, it can be concluded that the competence required covers the:
ability to plan, organise and supervise the use of the tower scaffold
ability to safely erect and dismantle a tower scaffold
awareness of the risks associated with working at height
ability to use a tower scaffold utilising all good working practices.
Those undertaking maintenance work may also have the potential to disturb asbestos-containing materials (ACMs). The hazards associated with exposure are well known and clearly operatives require the competence to prevent such exposure.
The Control of Asbestos Regulations 2012 state that where an employee is, or is liable to be, exposed to asbestos, or if that employee supervises such employees, then the employer must ensure that adequate information, instruction and training be provided.
The Approved Code of Practice details the types of training that is required including “awareness training” for “persons who are liable to disturb asbestos while carrying out their normal everyday work, or who may influence how work is carried out”. Guidance to the regulations then details further the requirement but in terms of competence, operatives and supervisors (as well as managers) may need to:
• be aware of the risks of ACMs and how to avoid those risks (eg by using PPE)
• undertake non-licensable work with ACMs safely (where applicable)
• undertake licensable work safely (where applicable)
• supervise or manage any asbestos-related work undertaken.
From the above it is clear that there can be various competence requirements for each job being analysed at various levels within the organisation. The development of a competence matrix can assist in tracking requirements.
As noted above, training is a means for employees to obtain the necessary skills, knowledge and attitudes (along with experience) required. Training may not necessarily always be classroom-based but can be a blended approach combining classroom, e-learning, practical application, etc.
To help assist in identifying training needs, the practitioner should be aware of any specific legislative requirements and utilise all available guidance.
Referring to the examples above, in relation to tower scaffolds, the practitioner could make reference to guidance and training opportunities offered by the Prefabricated Access Suppliers and Manufacturers Association (PASMA).
Similarly, for asbestos, the Approved Code of Practice gives further details of the specifics required in terms of training. Further reference can then be made to for example, UK Asbestos Training Association (UKATA).
From this the matrix can be populated with the training required — detailing what the training is, how it is going to be sourced (in-house or external), at what level, frequency etc.
Clearly, as well as specific training needs, there will also be more generic information and instruction that need to be provided, particularly as part of induction. This should include:
• an understanding of the health and safety policy
• a knowledge of the fire emergency procedures
• how to report an incident/accident
• first aid procedures.
These requirements can also be built into the matrix so that the employer has a comprehensive understanding of the competency requirements of the organisation in relation to health and safety, how this is to be delivered and how often.
Not only will this enable the organisation to show to relevant stakeholders that it is meeting its legal obligations, it will also assist in any future budgeting for training, assist with appraisals, recruitment and development of job specifications.
Drawing up a training matrix
For a general training matrix, list the (four) levels of the organisational structure can be listed on the vertical axis. Then on the horizontal axis, the jobs under analysis can be listed, along with broad task heading/risk control measure (eg working at height, using a tower scaffold) along with the competence required to safely undertake the task. See our example Staff Safety Training Matrix Form.
Specific organisation or department matrices could list employees’ names on the vertical axis, with type of training, date of training, trainer and whether refresher training is required on the horizontal axis.