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Heads Up, Some Regulatory Agencies Are Requiring Human Factors Programs


A number of regulatory bodies have been forwarding proposals that would require chemical processing plants to create human factors programs. One California county, Contra Costa, which includes Equilon’s Martinez Refinery and Tosco’s Avon Refinery among others, has drafted legislation that mandates every facility within their jurisdiction have a human factors program. The proposed Contra Costa County ordinance outlines human factors requirements including:

The Human Factors Program shall address:

the inclusion of human factors in the Hazards Analysis process;
-the consideration of human systems as causal factors in the incident investigation process for Major Chemical Accidents or Releases or for an incident that could have reasonably resulted in a Major Chemical Accident or Release;
-the training of employees in the human factors program;
-operating procedures; and
-the requirement to conduct a Management of Change prior to staffing changes for changes in permanent staffing levels/reorganization in operations or emergency response. Employees and their Representatives shall be consulted in the Management of Change.

-Employees and their representatives shall participate in the development of the written human factors program.

-The program shall include, but not limited to, issues such as staffing, shiftwork, and overtime.

-A description of the human factors program shall be included in the Plant Safety Plan.

Some are viewing the proposed Contra Costa county plan as a test bed or model for other organizations looking to mandate human factors programs. Even the API is investigating possible requirements for refinery human factors programs and is looking at the Contra Costa proposal. With all of this regulatory activity, managers should be asking the question of what constitutes an effective human factors program in a chemical manufacturing plant?

The more progressive plants that have already used human factors to improve human performance will exceed most of the proposed Contra Costa requirements. Meeting the requirements for most plants shouldn’t require huge amounts of additional effort, especially for those plants pursuing industry best practices. Best practice facilities use human factors to satisfy the requirements in the following ways:

They integrate human factors into Hazops by reviewing equipment operability. Reviews of equipment operability and compliance with ergonomic and human factors principles are done as part of the Hazop reviews to ensure the equipment is within normal zones of reach, properly labeled and can be operated with normal amounts of effort.

Best practice facilities include human factors in root cause analyses by ensuring the studies address ergonomics, human performance shaping factors, and naturalistic decision making issues such as information requirements, critical cues, etc.

Best practice operating procedures are symptom based rather than event based. Their procedures do not include excessive detail nor irrelevant information and the procedures are written in a checklist format.

When making staffing or reorganization changes, best practice facilities benchmark their plant’s workload against others in the industry prior to changes. The benchmarking analyses make project-ions on reorganized workload levels and identify potential bottlenecks.

If other agencies regulate human factors there are a number of different items they could require. The Contra Costa proposal takes a narrow view of human factors within a manufacturing plant and emphasizes what have been identified as safety issues. Most likely, other agencies would require those topics that are providing the largest increases in human performance. Other likely requirements for a human factors program can be found in industry best practice facilities that are already applying human factors. Two possible candidates for inclusion are:

Crew Resource Management training, or CRM. CRM training improves team performance by improving communication effectiveness through leadership, delegation of responsibilities, establishment of priorities, and monitoring and cross checking information and actions.

Control System Interface Design. Display and alarm systems that follow human factors principles reduce operational error rates and increase human performance as the information is more clearly encoded and demarcated.

Managers must be proactive to avoid the downside of legislated human factors. As in the nuclear industry, legislation can turn human factors into an end unto itself rather than a means of increasing human performance.

If you are interested in developing a cost effective human factors program that addresses safety as well increases human performance, please e-mail us at for more information.

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