The petrochemical and oil and gas industries operate in environments where the margin for error is exceptionally narrow. In these high-hazard settings, the interaction between human operators, complex machinery, and organisational systems is a critical determinant of safety and operational success. For facilities operating under the Control of Major Accident Hazards (COMAH) Regulations, demonstrating robust COMAH human factors compliance is not merely a regulatory tick-box exercise; it is a fundamental requirement for maintaining a license to operate and preventing catastrophic incidents.
At Horizon Human Factors, we specialise exclusively in providing human factors training, implementation, and consultation services for the petrochemical, nuclear, and defence industries. This guide explores the essential components of human factors compliance under COMAH and how organisations can proactively manage human performance.
Understanding Human Factors in Oil and Gas
The Health and Safety Executive (HSE) defines human factors as “environmental, organisational and job factors, and human and individual characteristics, which influence behaviour at work in a way which can affect health and safety.” In the context of the petrochemical sector, human factors in oil and gas encompass everything from the ergonomic design of control rooms and the clarity of standard operating procedures (SOPs) to safety culture, fatigue management, and communication during shift handovers.
Historically, major accident investigations—such as those following the Texas City refinery explosion or the Buncefield fire—have consistently highlighted human and organisational failures as root causes. Consequently, regulators now expect COMAH establishments to integrate human factors engineering into their safety management systems (SMS) as rigorously as they do process safety engineering.
The HSE Human Factors Roadmap
To assist major hazard facilities in navigating these requirements, the regulator provides the HSE human factors roadmap. This framework outlines the key topics that COMAH sites must address to demonstrate that they are managing human reliability effectively. The roadmap typically covers several core areas:
1.Managing Human Failure: Identifying safety-critical tasks and assessing the potential for human error or non-compliance.
2.Procedures and Competence: Ensuring that operating procedures are accurate, usable, and available, and that personnel possess the necessary skills and knowledge.
3.Staffing and Workload: Assessing workload, fatigue, and shift patterns to ensure personnel are not pushed beyond safe cognitive or physical limits.
4.Organisational Change: Managing the human factors impact of changes to staffing levels, roles, or operational structures.
5.Human Factors in Design: Integrating human-centred design principles into new plant builds, modifications, and control room upgrades.
Achieving compliance requires a systematic approach to each of these areas, backed by evidence-based methodologies and expert analysis.
The Role of Safety Critical Task Analysis (SCTA)
A cornerstone of COMAH human factors compliance is the execution of Safety Critical Task Analysis (SCTA). SCTA is a structured methodology used to identify tasks that, if performed incorrectly, could initiate or escalate a major accident hazard (MAH).
The process involves breaking down complex operations into individual steps, identifying potential human failures at each step, and evaluating the performance influencing factors (PIFs) that make those failures more likely. By understanding why an error might occur—whether due to poor lighting, confusing interfaces, or time pressure—organisations can implement targeted risk reduction measures.
Specialist Human Factors Training for Petrochemical Sites
Building internal capability is essential for sustaining compliance. Human factors training petrochemical professionals need must go beyond generic awareness. It requires bespoke, industry-specific education that addresses the unique challenges of high-hazard environments.
Effective training should equip safety managers, engineers, and operational leaders with the practical skills to:
•Conduct robust incident investigations that identify human factors root causes rather than simply blaming the operator.
•Facilitate SCTA workshops and integrate the findings into the site’s safety report.
•Recognise and mitigate the impact of negative PIFs on the frontline workforce.
Why Choose Horizon Human Factors?
Generalist ergonomics consultancies often lack the deep, contextual understanding required to navigate the complexities of COMAH regulations. Horizon Human Factors is different. Our exclusive focus on the petrochemical, nuclear, and defence sectors means we possess unparalleled expertise in high-hazard human factors engineering.
We do not offer off-the-shelf solutions. Instead, we partner with our clients to deliver bespoke consultancy and training that aligns seamlessly with the HSE human factors roadmap and your specific operational realities. Whether you require a comprehensive human factors health check, support with a COMAH safety report submission, or targeted training for your leadership team, we provide the specialist insight necessary to drive genuine safety improvements.
Ready to enhance your COMAH human factors compliance? Contact Horizon Human Factors today to discuss how our specialist consultancy and training services can support your organisation’s safety and operational goals.