The next rung on the ladder in staffing arrangements – does HSE CRR348/2001 need updating?

In 2001, the UK HSE published Contract Research Report (CRR) 348/2001 Assessing the safety of staffing arrangements for process operations in the chemical and allied industries.  This report sets out a 2-part methodology for assessing whether staffing levels and arrangements are adequate to maintain the safety of operations in high hazard industries, using:

  • Physical assessments – which assess the ability of staff to successfully detect, diagnose and recover hazardous scenarios.
  • Ladder assessments – which benchmark organisational factors in relation to industry best practice.  CRR348/2001 provides ladders on eleven staffing issues.

In 2004, the Energy Institute launched a guidance document setting out a best practice approach to the CRR348/2001 methodology that captures learnings from its use, and provides an additional ladder for the use of automated systems.  This guidance document was authored by Dr. Andy Brazier, now an independent consultant.

A recent independent paper by Andy Brazier provides a ten year review of the CRR348/2001 methodology.  It offers some personal observations of common human factors issues still prevalent within many organisations and makes some recommendations.

Of particular interest, the paper also suggests an improvement to the ladder assessments provided in CRR348/2001.

Ladder assessments can be described as a hierarchy of statements and keywords that describe typical practice on how organisations manage (or fail to manage) particular activities, in this case those associated with managing staffing arrangements (including situational awareness, team working, alertness and fatigue, etc.).  These make up the ‘rungs’ on the ladder, with each successive rung representing better practice than the last.

As well as a method to benchmark performance, ladder assessments provide a series of checkpoints for improvement, with the top rung representing ‘best practice’.  Teams must be confident that they fully meet the expectations of one rung before they can meet the next one up.  As such, CRR348/2001 provides an overview of good and best practice (as of 2001) and a route to achieve that.

However, Andy makes the suggestion that the top rungs in these ladder assessments no longer represent best practice – “I believe the concept of High Reliability Organisations, that has developed over the last decade, gives us a good reference point for what may be considered as best practice now” – and proceeds to suggest an additional rung for each ladder detailing practices commonly found in high reliability organisations (HROs).

Does this mean CRR348/2001 is now out of date or no longer valid?

This is unlikely.  In 2009 the EI’s Human and Organisational Factors Committee (HOFCOM) reviewed and reaffirmed the EI guidance document, believing it (and the CRR348/2001 methodology it supplements) to still be valid and useful.

When using ladder assessments, we should remember that companies must fully meet the requirements of the rung below before they can move up, so until they have reached the top rung CRR348/2001 is still useful.  However, for those companies approaching the top rung, or with serious ambitions of becoming a HRO, would adding an additional rung to the ladder be beneficial?

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