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Published: 6th September 2022

How a COMAH site developed its Competence Management System (CMS)

Vita Comfort UK’s Operations Director – Nick Wood, shares insight to help high hazard industry leaders develop their site’s Competence Management System – to reduce risk and improve their workforce competence, safety and regulatory compliance.

If I’d have had the ability to access these types of lessons learned from other industry peers when I was starting out on my Competence Management journey, I think that we would be on a very different stage than we are on today. We would be in a much more advanced and embedded stage

Nick Wood
Operations Director, Vita Comfort UK

The background

Vita Comfort UK, based in Middleton, Manchester, England – part of a global business called Vita (Holdings) Limited, is a low tier COMAH facility, manufacturing polyurethane foam products. The business utilises a combination of high hazard chemistry and traditional operating process systems to develop mattresses and furniture materials meaning that Vita Comfort UK has many complex workforce competence, compliance and safety requirements.

Pre 2005, Vita Comfort UK’s competence management efforts included an old-fashioned buddy training plan, with indiscriminate staff training used as a measure of competence, but this wasn’t focused or targeted enough.

After the 2005 Buncefield major process safety accident in the South of England, the HSE became very interested in similar lower tier COMAH sites and Competence Management became very prominent within the COMAH world. Between 2015 to 2018 the business appointed a previous external competence management systems supplier, who focused on developing content purely to satisfy the HSE’s 15 Principles guidelines requirements.

Vita Comfort UK’s Lessons Learned

Competence Management Systems Project

  • What IS a Competence Management System (CMS)? Some confusion arose, as Vita Comfort UK didn’t have a strong definition of how to develop a Competence Management System and it’s content, Lesson Learned. Below is the Cogent Skills Competence Management Systems overview
    • Definition ‘Competence’ means the ability to undertake responsibilities and perform activities to a relevant standard, as necessary to ensure process safety and prevent major accidents. (COMAH Competent Authority)
    • Purpose of a CMS is to control, in a logical and integrated manner, a cycle of activities that will assure competent performance
    • Aim of a CMS is to ensure that individuals are clear about the performance expected of them, that they have received appropriate training & development, assessment and re-assessment; and that they maintain or improve their competence over time.
  • Focus. Vita Comfort UK previously tried to demonstrate competence based purely on the HSE 15 Principles guidelines requirements. Lesson Learned. Create a CMS framework which is more focused on business and COMAH critical requirements and include critical tasks for each priority role, relating to an individual’s safety and on- the-job skills, knowledge and behaviours.
  • Choose Pilot Project Carefully. Vita Comfort UK previously chose a high hazard COMAH operation as it’s pilot subject and only built competence standards for one task. Lesson Learned. Pilot your CMS review and development on an area without an associated COMAH badge and develop standards, assessment and systems which can cross other functional areas. Then make improvements before rolling out to the wider business.
  • Simplify/Standardise your Procedures. Previous CMS project work resulted in a large number of very detailed procedures with no standardisation. Lesson Learned. Simplify and prioritise the business critical and COMAH tasks, with a strong focus on the front line, safety critical roles. Standardise, combine and/or reduce the number of procedures against which safety critical roles will be assessed.
  • Simplify Levels of Skill Proficiency. Very little consistency and measurable definition between front- line employees’ competence and skill levels hampered Vita Comfort UK’s business improvement aims. Lesson Learned By simplifying the required competence levels and defining segmented operations, front-line employees fit into one of the 3 competence levels (listed below). Based on business operation’s needs, Cogent Skills and Vita Comfort UK have defined the 3 competency proficiency levels as:
    1. Can carry out the task with supervision
    2. Can carry out the task without supervision
    3. Can carry out the task without supervision, can fault find/problem solve
  • Role Definition. No internal competence management and assessment standards were defined for various roles. Lesson Learned. Assess and develop competence standards requirements for business-critical roles. For operations, help workforce to understand the procedure, observe and assess them carrying out the procedure asking knowledge-based questions to ensure that they understand the critical steps and what to do if things don’t go to plan. For example – do they understand how to return operations to normal, steady state if necessary? Include adopting correct safety behaviours during the assessment process . Have a robust recording system for the assessment process for audit purposes, etc.
  • Leadership and Competence Priority over IT Systems. Vita Comfort wasted about 20 months developing a clumsy infrastructure system and administration process. Making the process work seemed impossible without an embedded CMS. Lesson Learned. Move your focus from being software and systems led to leadership led to drive competence – to do the right thing, rather than implementing systems. Develop and get the CMS framework in place first, before developing an internal infrastructure system – then adapt the internal IT infrastructure to suit the more simplified CMS process.

The challenge

Vita Comfort UK didn’t just want to satisfy regulatory authority requirements, they wanted to do a better job to embed a competence management system into business operations. In addition to this, the previous external supplier’s effort had resulted in detailed planning mistakes, leading to unsatisfactory business outcomes – such as:

  • Too many (>45) detailed standard operating procedures with no standardisation or risk priority
  • 15-20 months spent on developing a clumsy IT infrastructure system and administration process.
  • No internal competence management standards were defined for operational roles.
  • Lack of critical tasks defined and assigned to each priority role, relating to an individual’s on-the-job skills, knowledge and behaviours
  • An outstanding need remained to demonstrate to the regulators that the business knew what they were doing with regards to competence.

A new, revised CMS Framework was needed by the business to:

  • Build competence standards – aligned and benchmarked to Competent Authority compliance standards
  • Embed safety and compliance to help reduce the risk of a critical incident
  • Ensure that operations were delivering a better, more accurate performance
  • Develop a consistency of individuals and operators per task – focused more on a behavioural safety type of competence
  • Demonstrate that everybody was being assessed and being competent – via consistent, standard assessments and auditing.

This resulted in their decision to search for and appoint an external Competence Management expert, who would provide specialist guidance and develop a simplified Competence Management System (CMS) Framework and standards – focused on COMAH and business critical requirements for Vita Comfort Middleton site implementation. The ultimate aim was to develop an informed CMS Framework which can be rolled out across the wider business.

Developing a competence management framework felt like a daunting animal that we didn’t really know how to tackle. We needed to do something better as our previous competence management focus had been on developing IT systems and satisfying the HSE’s 15 Principles guidelines requirements – as opposed to defining an individual’s behavioural safety skills and knowledge.

Nick Wood
Operations Director, Vita Comfort Uk

The solution

Between 2019 to 2020, Vita Comfort UK appointed Cogent Skills to review and develop their Competence Management System Framework, after researching the market and considering a number of different providers.

Cogent Skills started the project by focussing on one pilot plant – conducting a trial on an onsite recycling operation which didn’t have an associated COMAH badge but was still a fairly intense area. Vita Comfort UK agreed to begin the CMS Framework development of this pilot plant as it was relatively small but had a number of high- risk activities. Development work in this pilot plant is underway and to date stages 1, 2, 3 and 4 have been completed with other stages close to completion.

It has taken approximately nine months to achieve a system that everyone is happy with – with the next step being to assess, amend then roll it out to the wider business.

Cogent Skills six stages of developing a Competence Management System Framework

  1. Resourcing Workshop
    • Priorities, ownership, timescales, support
  2. Map existing resources to CMS
    • Strengths v. Gaps
  3. Manage the Competence Management System
    • CMS Policy/Procedure, manage change, review & audit
  4. Manage Tasks
    • Task identification, task risk/criticality, assign tasks to roles
  5. Prepare for Assessment
    • Assessment criteria, assessment capacity
  6. Manage training
    • Map training provision, identify gaps

Although still in the early stages of the implementation, Vita Comfort UK has already started to introduce significant simplification in the way that they do things and appraise everything that they do, instead of having very detailed standard operating procedures for task elements that are not required.

In tandem with this CMS project Vita Comfort UK are also applying change management principles as the CMS system is implemented.

We’d started to do more of our Process Safety Management training with Cogent Skills, which gave us confidence in their high hazard compliance knowledge and after they presented their competence management capabilities, we felt at the time and are very confident now, that we’ve made the right decision.

Cogent Skills brings the external expertise of embedding a long- term competence management system development into our business and we’re confident that we’re now aligned with a supplier who understands what we are trying to achieve

Nick Wood
Operations Director, Vita Comfort Uk

The impact

2020 – Present. Implementing a comprehensive Competence Management Systems framework assessment and strategy with Cogent Skills, has helped to deliver COMAH requirements and standards plus consistency and simplicity of operations, which will help develop Vita Comfort UK’s growth strategy.

Within a high-risk operation, it is very important to ensure consistency via easy-to-understand competence management definitions and critical tasks simplicity – so that individuals are clear about the performance expected of them. This can then lead to individuals receiving appropriate training & development, assessment and re- assessment, to maintain or improve their competence over time – especially in a time of growth.

Vita Comfort UK anticipate rapid business growth over the next few years and with the help of the CMS framework, it will be easier for the business to on-board new people in a safe, compliant and competent manner.

Key Business Outcomes. 2020 – to date:

  • Reduced the business operations risk profile
  • Improved risk assessment process
  • Provided competence management consistency and structure – across the business
  • Simplified the skill set tiers. Introduced the following 3 competency tiers, based on business operation’s needs – as defined by the following proficiency levels,
    • Supervision needed
    • Can do the job without supervision
    • Super operator, who can problem solve and can work independently etc By simplifying the task tiers and defining segmented operations, people fit into one of the 3 tiers – so it’s best to ring fence tasks and still manage them the same way
  • Validated CMS System evidenced via assessment process and prioritised Business and COMAH Critical tasks and assigned critical tasks to roles.
  • Developed competency standards within the business’s simplified, standard operating procedures, with a strong focus on the front line, safety critical roles
  • Redeveloped competence standards requirements for business-critical leadership roles
  • Enabled redevelopment of Competence Management Systems Database – with more simplified reports
  • All workstream leads are now educated in CMS from ‘bottom up’ – improved understanding, acceptance and implementation.

In a nutshell, I would wrap up our experience of working with Cogent Skills on our CMS journey by saying we’ve got simplicity, we’ve got structure where structure didn’t exist before and it is starting to be embedded. I’m definitely seeing the benefits of the consistency that we were craving

Nick Wood
Operations Director, Vita Comfort Uk

The solutions used

Competence Management Systems Development
Workplace Competence Assessor Training
Change Management Principles
(Bespoke for client)

Future Ready

Cogent Skills is sector based, working with companies from across the Science and Technology Industries embracing Life Sciences, Industrial Sciences and Nuclear.
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