This is a summary and critique of the brand new guidance produced by ARMI on Competence in the Asbestos Industry. I will try to reduce the 28 pages into something more concise and give my spin on the wording to help clarify. Reading this summary would hopefully allow you to fully implement ARMIs suggestions, and/or help navigate the full document if you want to read more (available at http://www.armi.org.uk/Download/ARMI_Competency_Guidance.pdf).
The guide starts with an explanation of what competence is and a statement that most contractors will be assessing it anyway. However this existing assessment may be entirely informal and subconscious (a vague understanding of – you wouldn’t ask John to do X because of Y).
‘The ability to perform a task to a specified standard’
‘The skills, abilities, knowledge and behaviours that lead to successful performance.
Understanding what skills are required, what skills are held by an employee and whether there is a gap between.
Contractors and asbestos removal
As the roles and duties you expect of an employee change, the skills (or Competencies) also change. Similarly Competencies also change if we change the way the job is to be done. Due to a variety of reasons, an employees’ Competence will change as time progresses – in either direction.
Consequently Competence assessment must be continuous to identify shortfall and inform training.
It must be remembered that training here does not mean set piece refresher courses, but a variety of tools to bridge the skills gap identified. It could be a formal training course, but equally it could be:
- Mentoring (placing George with John so that John’s weakness in air lock construction is improved)
- Internal training sessions
- Toolbox talks
- Modular spot training
The guidance goes on to identify the clear regulatory basis that requires employers to conduct a structured Competence system. The document explains that you can get external assistance in performing some or all of these duties. However before you rush to an expensive external consultant – it states correctly that the duty can’t be delegated. Essentially what this means is that if a largely external system fails to deliver, it will be the employer in the dock.
As you are already at the Assure360 site – just click on Home tab to see how we can provide a simple, cost effective solution. Assure360 allows an employer to run an internal Competence system without creating extra work or recourse to expensive consultants.
- Establish the employees’ roles and duties. Identify the relevant skills and competencies for the position.
- Agree performance standards in relation to relevant competency elements and the employees’ duties.
- Collect evidence of the employees’ performance and compare with th
- e desired performance standard.
- Produce training needs analysis (TNAs) based on the gaps identified between the employees’ performance and the required performance standards.
- Provide training to close performance gap(s).
- Carry out on-going assessment to ensure continued competency.
Image taken from the ARMI Guide
Steps 1 & 2 establish the skill set required and agree the standards have almost certainly already been completed. Your company H&S Policy and Standard Procedures, if correctly written will be tailored to your precise circumstances, describing the precise duties you expect of those individuals.
The ARMI’s guidance document goes into some detail on what could be seen as a standard set of Competencies for the industry. However, unless we all rewrite our H&S Policy and Standard Procedure documents to match ARMI’s guidance they are unlikely to ever be the ‘standard’ Competencies. They do however broadly map out what you would expect.
The guidance raises two important points that I would wish to echo and highlight. Competencies are role based not title based, recognising the fact that employees are often a blend of roles. i.e. a senior Operative might have some Supervisory duties. Similarly in a small removal company a lead Supervisor might have key Management duties. This is a key point and useful to stress.
Secondly the guidance recognises how critical teamwork and communication is at all levels in the organisation, going some way to identifying what this looks like at different levels in the organisation:
Core duties – i.e. Competencies that everyone from the operative to the MD should have):
- Works with others (colleagues, management, client…)
- Follows the plan of work
- Reports change and near misses
Supervisory duties – as above, plus:
- Communicates PoW and any changes effectively
- Manages changes to the PoW correctly
- Encourages input from operatives
- Lead by example – attend site and use this to reinforce policy, procedure, PoW etc…
- Seek feedback – effective measures to actively involve other employees in improving policy and procedure
- Involve other employees in designing PoW and conducting Risk Assessments
This aspect of teamwork and communication as a Competency is largely overlooked by the majority of removal companies and could contribute enormously. Strategies on how to promote these should be sought, but the guidance does not help with this.
Step 3 (Collect Evidence) and to a lesser extend Step 4 (Produce Training Needs Analysis or TNA) are the ones that will cause most issues with Licence Holders. Unfortunately other than tell you of some sources for gathering the required information the guidance crucially falls short:
- Direct observation on site i.e. audit – this is stated as the primary source of information
- Supervisor site reports
- Read through site files for evidence
- Oral quizzing
- Simulated tasks
- Written exam
- Exposure records
However, other than little more than these bullet points there are no clues on how to:
- Gather the information in a way that does not become a huge task in itself, or
- Understand and analyse the information obtained quickly and easily
In fact just adding these tasks to an already full workload may be an ‘ask’ to far.
To be fair the guidance does repeatedly say, ‘many of these tasks are already being done by licence holders’, the problem is existing measures typically do not gather the kind of information needed to create a detailed understanding of an employee. The trick remains – to transform the tasks that are already being done into an exercise that automatically provides the competence assessment.
An employee must be deemed competent to do a task and until they are, they need to be supervised. This has most impact with new starters (including agency); whether this is an experienced supervisor/manager or someone fresh to the industry – they will have little idea on how you as an organisation do things and you will have no idea of their Competence. Induction into company H&S policies and procedures is therefore critical and a high level of supervision must follow.
Next on the cycle comes produce TNAs. TNAs are an old problem, and as most training organisations know actually getting a TNA for an employee is a rare event, getting one long enough in advance to plan appropriately has until recently been almost unheard of. Nowadays I do know of several companies that complete TNAs in advance and submit these to the training providers.
The guidance seems to suggest that creating TNAs is an additional exercise over and above Competence Assessments. It identifies who assessors should be and what competencies they should have. Essentially this comes down to Supervisors and Line Managers as the in-house experts best placed to do this. Having TNAs as an extra task, added to a busy workload, will have the almost inevitable result of it not happening at all.
Again the trick is to make the process automatic. Direct observation should produce a competence assessment, which by its nature (looked from the other side) is a TNA. But the guidance does not tell us this bit.
This is obviously the act of closing the gap. We’ve identified the strengths and weaknesses (competencies), we’ve developed the training requirements (TNA), and this is merely the delivery of that plan. What the guidance makes clear though is that training is not just the annual refresher and can take the form of toolbox talks, practical sessions and even informal chats.
Essentially what this means is that; once we know (in detail) what weaknesses an operative, supervisor or manager may have, we can be much more imaginative in addressing those needs:
- If an operative has an identified issue with rolling cubes, then why wait till next year – train him internally now
- If managers repeatedly miss non-asbestos hazards; target this as a standalone issue
- If a supervisor implements changes on site without authority, tackle it head on
- If a trend of minor issues is identified, these can be collected into a bespoke training session.
Many of these are issues, which if we recognise them, can be dealt with internally.
A senior operative; if he excels in the skill to be imparted can deliver training. Supervisors can become key mentors, contracts managers can learn from each other.
Equally if you understand the weaknesses on site, you should know your strengths, the industry has an awful lot of expertise and this is by no means restricted to training organisations. Good ideas, innovation and excellent performance should be identified, reinforced and shared.
Increased supervision is effectively ‘on the job training’. An identified slip in performance in an experienced operative or a new starter can be tackled by mentoring. Just because a new employee comes to us qualified and experienced, we do not know their level of Competence. Equally we should be near certain of their lack of competence in our own company procedures. This support can be seen as simultaneous training and assessment.
Or rather – start again. It should be noted, though, that the guidance correctly identifies that ‘establish roles’, and ‘agree performance standards’, won’t normally need to be returned to on a regular basis. As the collection of evidence and consequent identification of training needs is continuous, the cycle should just keep rolling. The guidance document does note that infrequently completed tasks may need to be tested via simulations to ensure competence is maintained. A good example of this could be emergency procedures or fire drills.
There should also be a formal review (minimum annually) – or employee appraisal. The competence, and TNA assessments that have been completed throughout the year, should be used as part of this exercise. Events that should trigger reviews:
- New employee (probation periods)
- Work method changes
- Equipment changes
- Identified competency gaps
The guidance is an effective definition of what competence is and gives pointers to how Licence Holders (LHs) can design their own systems to fulfil the requirements. It also identifies many tasks typically already done by LHs that can provide evidence of Competence and therefore inform TNAs and training.
Essentially as a guide to creating a competence system it does work. However the process it describes is a colossal amount of work.
The ARMI guide starts by creating separate performance criteria and matrices for every role. In of itself, this could be a few weeks work. It then describes a host of evidence sources that (admittedly companies do at least some of). However it gives no guidance on how to streamline the process of analysing the ‘big data’ this would produce. All H&S managers in the asbestos industry know that a PDF audit report can be a dead end and is lucky to be closed out, never mind trends identified. iAuditor can produce Excel exports but these are incredibly labour intensive to analyse. Typically the ‘degree of granulation’ achievable is to supervisor level and no further, leaving the majority of the staff un-assessed. Essentially to administer the competence system as described would require a dedicated full time individual.
As I say the guidance does explain the concept, gives sound guidance on where to start. But it leaves us hanging with the slight echo of ‘pick the bones out of that’.
However, there is help beyond the guidance. New commercially available systems streamline this process into a ‘click-of-a-button’ solution – my assure360 database and app is one.
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