Safe Staffing Levels: Latest Energy Institute Guidance

Michael Wright, Greenstreet Berman, UK

Stuart King, Energy Institute, UK.

HOFCOM objective

• Human and Organizational Factors Committee (HOFCOM) of the Energy Institute objective:

• Provide clear and concise guidance to help companies in the petrochemical and allied industries to determine appropriate levels of staff

• For use by people responsible for determining the approach to assessing staffing levels such as:

• Business team managers, human resources, maintenance and operations leads, project managers and planners,

• Safety and regulatory persons.

Background• Existing guidance

• Safe staffing arrangements – User guide for CRR348/2001 Methodology : 2004

• Fatigue – Human Factors Briefing Note 5

• Managing major accident hazard risks (people, plant and environment) during organisational change

• Observed that:

• Many other methods exist

• CRR 348/2001 focuses on control rooms

• Many developments since 2001

Why do safe staffing levels matter?

• Chronic fatigue amongst operators due to working 12 hour shifts for 30 days.

• A single operator responsible for three

complex process units.

• Centralisation of specialist

resource away from a site

• Insufficient staff to assess and

resolve process safety hazards

Why can organisations get staffing levels wrong?

Organisational drift

Lack of assessment

Poor change management

Simplistic benchmarks

No allowance for abnormal

events

No allowance for ad hoc or

supplementary tasks

Lack of foresight

Recognising change

Plant

• New or modified plant

• New controls systems

Organisational

• Fewer staff, managers or supervisors

• Relocation, new ways of working

Operational

• Changes in production level/time

• New operational requirements

Risk

based

screening

Recognising staffing issues: indicators

Overtime, gapped posts

Stress, staff turnover, error

Unplanned use of contractors, incomplete tasks

Real time fatigue & hours worked management“… a risk-based plan or system of controls that

identifies, monitors and manages fatigue risk,

with the aim of ensuring that, so far as

reasonably practicable, employees are

performing with an adequate level of alertness.”

(p17).

• the maximum number of consecutive day & night duties;

• minimum durations of rest periods between duties; and

• the maximum number of hours of work before a break ought to be taken.

• Defining triggers, such as the above, for acting on individual working hours, in real time;

• Real time recording of working hours, rest periods & sleeping time between shifts for each

employee, including travel and commuting time;

• Guidelines on what staff and supervisors / managers can do if they think someone is too

tired;

• Training in recognition of fatigue in self and in others; and skills needed to empower staff to

report and manage their fatigue, such as asking for help, and challenging others’ fatigue.

• Formal policy of minimum rest periods and sleeping

time between shifts;

• A statement of limits for:

• the maximum number of hours of work per day;

• maximum overtime / extended hours limits;

• weekly and monthly work hours;

Recognising staffing issues: Operational auditing, near misses and incident reviews

Operational audits

• Is the minimum staffing level fulfilled?

• Is the ratio of supervisors to managed persons consistent with good practice on spans of control

• Is there evidence of people being unable to take rest breaks due to gaps in staffing?

• And so on

Near misses and incident reviews

• Checking the hours worked preceding the incident.

• Checking if the minimum staffing level fulfilled?

• Checking simultaneous tasks?

• Checking whether time available to complete a task credible?

Assessing staffing levels

• Unit of assessment• Assess a single operation, e.g. a

control room or maintenance department

• Assess an entire site

• Bounding the assessment• Task inventory

• Normal operations

• Peak demand

• Abnormal & emergency operations

Assessment methods: simpler operations

Simple & well known operations

• Judgement

• Operational experience

Moderately complex operations

• Work flow chart

• Task analysis

• Time line analysis

Assessment methodsTask workload rating methods• Subjective Workload Assessment Technique

• National Aeronautics and Space Administration Task Load Index

• Team Workload Assessment

• Alarm Metrics, such as from The Engineering Equipment and Materials Users Association (EEMUA) and

• Visual Audio Cognitive Psychomotor.

Control room tasks

• Crisis Intervention and Operability (CRIOP)

• Entec method• …timelines, scenarios,

benchmarks

Assessment methods: Exercises, commissioning checks and simulation

• Useful for new operations and uncertainty

• Choose representative tasks

• Achieve moderate to high task fidelity

• Defining objective task performance measures, such as:

• Task completion time;

• Compliance with safe systems of work;

• Able to monitor the situation, indicators and alarms, and maintain situational awareness;

• Effective communication, coordination and teamwork;

• Correct task performance; and

• Staff stress levels;

• Recording task trials for evaluation.

Selecting a method

Yes

Subject Matter

Expert judgement

possibly aided by

Workflow

Mapping

Task & / or

timeline analysis

High level

of

operational

experience

Uncertainty

Simple

task

Task

complexity

&/or

cognitive

tasks

Select a workload

assessment

method

Physical,

desktop &

commissioning

exercises

No

Yes

No

Verification &

validation

Yes

No

Complex or cognitive

Moderate complexity

End hereStart here

Auxiliary tasks

• Need to identify & add on time allowance

• A % of each person’s time

• If each person has, e.g. 25% on auxiliary tasks, then need 4 people to do 3 operational roles.

ADMINISTRATION TRAINING MEETINGS

ANNUAL LEAVE IMPROVEMENT ACTIVITIES

Supervisor to staff ratios

Verification and commissioning checksVerification

• Have all safety critical tasks been considered?

• Have suitable bounding scenarios been noted?

• Has a suitable form of activity or workload

analysis been applied?

• Has the potential for human failure been

adequately considered?

• Whether realistic fatigue (human endurance)

assumptions have been made in the specification

of working hours and shift systems?

• Whether realistic assumptions and reliance has

been placed on staff competence and

supervisory support?

• Whether realistic assumptions have been applied

for auxiliary duties?

Commissioning

• Asking for feedback from operators about the workload involved in the operation of new or changed equipment;

• Observing task completion times and task success/failure;

• Checking that simultaneous tasks and tasks occurring in different locations have been identified.

Staff engagement• Scoping, defining bounding scenarios, conduct

of assessment and its validation;

• Developing workflow, task analysis and task mapping;

• Involving in physical exercises and trials;

• Review and verify the outputs from assessments

Organisational staffing and emergency response ‘baselines’

• Baseline identify all safety critical posts and competences:

1. Operational and maintenance staff,

2. Supervisory and managerial

3. Managerial and director staff who develop

and lead policy etc

• The baseline may have two or more levels,

such as:

• Minimum for normal operations and reasonably foreseeable events;

• Resilience level – allowance for unplanned illness, resignation and early retirement.

• Baseline are used for control for changes in staffing. These changes may arise from:

• Staff retirement, staff resignation, long term absence or staff changing jobs within an organisation; or

• From planned changes, such as from organisational change.

• And for monitoring

• Monitoring whether post holders meet

competence requirements;

• Tracking the proportion of baseline posts that

are filled/unfilled posts;

• Identifying vulnerabilities, such as where there

is reliance on one person to perform a role

Staffing level risk controls

Task simplification

Task automation

Reducing task demands

Reducing task durations

Task sharing Task support

TrainingTask

enrichment

Conclusions

• Key lessons learned from previous major accidents include:• Risk from inadequate staffing was either not recognised or acted on, and

• Decisions on staffing levels were not robust.

• The guidance in this publication:• Helps managers and supervisors to recognise staffing issues and

• Offers a systematic approach to assessing staffing needs and incorporating these into common safety management processes.

• Guidance on ensuring safe staffing levels: S1181

In press for 2021