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Namaka Subsea undertakes Safety Management System audits of diving and ROV contractors on behalf of the oil and gas majors, as well as part of diving contractor IMCA membership applications. The biggest challenge is for organisations to understand the requirements of how they should demonstrate the competency of their personnel. This should be the cornerstone of any organisation's decisions to invest in, as it is ultimately their personnel that will undertake the operations, whether diving or ROV and ensure that they can demonstrate competency. These individuals, such as the divers, are placed in high-hazard and high-risk environments daily, and we must ensure that they are able to demonstrate they are competent to carry out their duties as safely and efficiently as possible.

Previous means of demonstrating competency was through a tick box exercise or saying that they have been trained, so ultimately they must be competent, but competence is an ongoing process from the start of your career to the very end of your career. This should be supported by the organisation that is contracting personnel as part of their requirements under legislation, the responsibility resides with the employers, and, in the event of an incident, they will be held responsible regardless of their contract status. The ability to demonstrate competence is essentially doing your job but being measured against the relevant standards of IMCA in the subsea industry, so no one is being asked to go beyond that unless there is additional client or internal requirements. The benefits of doing this, is we are ensuring personnel are safe and that others they work with are operating to the same condition. It also allows the organisations to identify any skills gaps within individuals and allows for career advancement, as well as ensuring they are complying with legislation, regulations and IMCA guidance. Another bonus is efficiency as some personnel may have undertaken a task that has been done incorrectly and if observed, a task that may have taken 2 hours before may only take one hour making the use of their time more efficient, for example.

The challenges are that many organisations do not understand competence and are therefore averse to investing in people and training. However, the subsea industry must take the same approach to competence as when purchasing equipment. Many organisations will not think twice about spending millions on pieces of equipment but hesitate at the prospect of spending tens of thousands on their personnel. This requires a mindset change from organisation leaders to ensure that the competency of their personnel is a priority and not a byproduct of an audit. The other challenge is auditors have a responsibility when auditing to ensure competence is at the forefront of their audits. At Namaka Subsea we recognise that one of the fundamental areas of a safety management system audit is reviewing the competency of the personnel within the organisation, so all auditors whether completing the scope for regulatory, client or internal audit requirements also need to understand the fundamentals of what a structured Competence Management System (CMS) looks like. For too long many have accepted and allowed a procedure and a tick box document to be used in this case. To have a structured CMS, organisations should have the following as a minimum:

• Policies and procedures.
• Trained assessors and verifiers.
• Structured assessment and verification processes.
• Standardised assessment plans for roles.
• Identified safety-critical job roles.
• Documentation or digital software for candidates to upload.
• Downloadable reports.

This list is non-exhaustive but is the minimum requirement organisations should have in place when operating in the subsea industry if we are to improve the competence of their personnel. As auditors, we should not be accepting anything less from those in the subsea industry, as we would be doing a great injustice to the safety of our personnel.

This is why we created Namaka Compliance, as over the years within Namaka Subsea, we recognised that there was a requirement to develop the competence of subsea personnel. I desire to exceed what is currently deemed as the acceptable standard. Having seen the advancements in the industry with digitalisation, we realised that as a subsea industry, we should be leading the way in terms of competence. With that experience, Namaka Compliance brings to the table its Outsourced Competence Assurance Support (OCAS) services. We recognise that not everyone is a competence expert, that is why we have created the service, as it takes the headache away of trying to develop an in-house CMS when Namaka Compliance has a team of experts who have worked not only with Subsea but also Topside, Drilling Contractors and Engineering Companies, and therefore we are bringing a wealth of learned experience across the different sectors to transfer knowledge to the subsea sector. Our team will act as a competence department and as an extended arm of the organisation or can complement the existing competence of a client’s team. If you would like to hear further information on our CMS, please get in touch with Namaka Compliance.

Author: Sandy Harper, CEO Namaka Group