When you take your car to a garage, you don’t need to be a mechanic. But you probably want to know enough to judge whether you’re being told something reasonable. Is a new clutch at 60,000 miles plausible? Should the brakes really need replacing already? You’re not doing the work – but you need enough knowledge to ask sensible questions, spot when something doesn’t sound right, and avoid being sold work you don’t need.
Now raise the stakes. You’re having an extension built on your house. You’ve hired an architect, a structural engineer, and a builder. But if you know nothing about construction, how do you know the architect’s plans are practical, the engineer’s calculations are sound, or the builder is doing quality work? Most people who’ve been through a building project will tell you they wished they’d known more. Some hire a project manager to be that knowledgeable person on their behalf – someone who can oversee the work, ask the right questions, and know when standards aren’t being met.
Now raise the stakes further. You’re responsible for a COMAH site and the HSE expects you to maintain “intelligent customer capability” for human factors. What does that actually mean? How much do you need to know? Do you need a degree in ergonomics? A short course? Or just enough common sense to ask the right questions?
This is the question we get asked often. And it deserves a proper answer.
Where the Term Comes From
The concept of the “intelligent customer” was developed by the UK’s Office for Nuclear Regulation (ONR) and has since gained international acceptance. The International Atomic Energy Agency (IAEA) defines it as follows: the management of a facility should know what is required, should fully understand the need for a contractor’s services, should specify requirements, should supervise the work, and should technically review the output before, during and after implementation.
The HSE defines Intelligent Customer Capability as “the capability of the organisation to have a clear understanding and knowledge of the product or service being supplied.”
This principle is now embedded in the COMAH Human Factors Delivery Guide. The guidance states that COMAH operators may choose to draw on external, competent support to help with human factors integration – for example, a Chartered Ergonomist or Human Factors Specialist. However, in doing so, the operator must maintain an effective intelligent customer capability. This isn’t optional advice. It’s in the guidance your site is inspected against.
What Intelligent Customer Capability Is (and Isn’t)
There are three related concepts that are often confused, and it’s worth distinguishing between them.
Intelligent Customer Capability is an organisational capability. It’s about being able to oversee, procure, and evaluate human factors work done on your behalf. You don’t need to be able to do the work yourself – but you need to know what good looks like.
SQEP (Suitably Qualified and Experienced Person) is about individual competence to perform specific work. Someone who is SQEP for SCTA can do the task analysis, failure analysis, and PIF analysis themselves, and might have experience of the domain and analysing the task they’re looking at, e.g. they have done a tank to tank transfer at a fuel terminal before.
Chartered status (e.g. Chartered Ergonomist or Chartered Human Factors Specialist) is a professional accreditation that demonstrates competence across the breadth of the ergonomics and human factors discipline. It’s broader than being SQEP for a specific task and might not contain the domain experience.
These serve different purposes, and one doesn’t replace the others. You can hire the best Chartered consultant in the country – you still need intelligent customer capability within your organisation to oversee and evaluate their work. And someone can be SQEP for SCTA without being Chartered, and vice versa.
The confusion between these concepts matters, because it’s often where things start to go wrong.
What Happens When Intelligent Customer Capability Is Lacking
We’ve seen situations where the absence of intelligent customer capability has led to problems. Two examples illustrate different failures:
The clear case. An organisation hired someone to sort out their policies and procedures. The person claimed to have human factors knowledge, but it was evident they were straying into an area they weren’t competent in. The organisation couldn’t see this because they had no benchmark for what competent human factors work looks like. Without intelligent customer capability, there was nobody in-house who could recognise that the emperor had no clothes.
The less clear case. A different organisation brought in someone who said they had human factors experience in another sector. On paper, this looked reasonable. But it became apparent that this person wasn’t familiar with the COMAH Human Factors Delivery Guide or the expectations behind it. The words in guidance documents only say so much – understanding the required standards and what inspectors actually expect comes from experience of working within that specific regulatory framework. This person had general knowledge but lacked the sector-specific depth to deliver what was needed.
The first case is about catching obvious gaps in competence. The second is subtler and arguably more common – it’s about distinguishing between someone who broadly knows about human factors and someone who understands the specific requirements of your regulatory context or sector. Back to the car analogy: the difference between a qualified mechanic and someone who’s watched a few YouTube videos might not be obvious until something goes wrong.
Both cases point to the same root problem: the organisation didn’t have enough knowledge to spot the issue.
So How Intelligent Do You Need to Be?
This is the heart of the matter. Drawing from the IAEA definition, we can identify a minimum baseline for intelligent customer capability. You need to be able to:
- Know what you’re buying and why – not just “the regulator said so” but a genuine understanding of what the work is meant to achieve and how it fits into your safety management system.
- Specify requirements clearly – something better than “we need some human factors doing.” A good brief leads to good work. A vague brief leads to misaligned expectations and wasted effort.
- Evaluate provider competence – can you tell the difference between someone with genuine experience and someone who’s overstating their credentials? Do you know what qualifications and experience to look for?
- Judge outputs at a high level – you might not be able to critique every step of a hierarchical task analysis, but can you tell whether the recommendations are practical, whether the right people were consulted, and whether the findings make sense for your site?
- Know when something doesn’t feel right – even if you can’t pinpoint exactly why. This is the instinct that comes from understanding the subject well enough to recognise when an explanation doesn’t add up.
Back to the car garage: you can’t diagnose the fault yourself, but you can tell when you’re being given a plausible explanation versus being taken for a ride.
It Depends on the Topic
Not all human factors topics require the same depth of intelligent customer knowledge. The COMAH Human Factors Delivery Guide covers six topic areas, and the level of understanding needed to oversee work in each one arguably differs.
Take Safety Critical Task Analysis (SCTA). This is a methodologically detailed process involving hierarchical task analysis, systematic failure analysis, and performance influencing factor assessment. To judge whether an SCTA has been done well, you need to understand the process in some depth. A superficial familiarity won’t be enough to spot when corners have been cut or when the analysis lacks the rigour the regulator expects.
Compare this with managing shift work and fatigue. This is still a specialist area, but the core concepts – shift patterns, rest periods, workload management – are more intuitive to people with general management experience. An informed manager can engage meaningfully with proposals about shift design without needing the same methodological depth as SCTA oversight.
The principle is: the more technical and specialist the topic, the more “intelligent” your customer capability needs to be. And this has implications for how organisations invest in developing that capability.
Intelligent Customer Capability as Part of a Journey
In a previous blog on management models for proactive human factors, we outlined three approaches:
- Done-For-You (DFY), where external consultants do the work;
- Do-It-Yourself (DIY) centralised within the organisation.
- Do-It-Yourself (DIY) distributed within the organisation
Most organisations start with DFY, and intelligent customer capability is essential in this model – it’s how you ensure you’re getting value and quality from the people you’ve hired.
As organisations mature, they may move towards doing more of the work themselves. At that point, they’re moving beyond intelligent customer capability into practitioner territory – building SQEP-level competence internally. Some organisations adopt a hybrid approach, doing routine work in-house and bringing in external specialists for particularly critical or complex tasks.
The important thing is that intelligent customer capability isn’t a fixed state. It sits on a continuum, and where you need to be depends on your management model, your risk profile (e.g. upper or lower tier COMAH site), and how far along this journey you are. It’s also not a one-off investment – maintaining and developing this capability over time matters, especially as standards evolve and staff change.
When Is Enough, Enough?
Let’s circle back to the title question. The honest answer is: there isn’t a single threshold that works for every organisation and every topic. But there is a minimum below which you’re essentially flying blind.
That minimum is knowing enough that you wouldn’t have hired either of those two people described earlier – or at the very least, that you’d have spotted the problems early enough to do something about it. Below that line, you’re relying on luck. And the more safety-critical the topic, the higher that line needs to be.
The car garage can get away with a bit of trust and common sense. The house extension benefits from a project manager who knows the building trade. A COMAH site needs something more deliberate – a considered investment in knowledge that’s proportionate to what’s at stake.
A Practical Example: Building Intelligent Customer Capability for SCTA
To make this concrete, let’s use SCTA as an example of how intelligent customer capability can be built at different levels. This isn’t the only route, but it illustrates the spectrum.
Awareness. A free mini-course on Human Factors Critical Task Review (HFCTR) gives you a sense of what SCTA involves and why it matters. It’s a starting point – enough to understand the conversation, but not enough to judge the detail of the work being done on your behalf.
Informed oversight. An introductory course like our HF_PLC (Introduction to Human Factors for Process Safety, Loss Prevention and COMAH) gives you the broader framework – the six Delivery Guide topics, what the regulator expects, and how SCTA fits within the wider human factors management system. This is closer to meaningful intelligent customer capability, where you can engage with providers, ask informed questions, and understand how the pieces fit together.
Assessment. For organisations that already have SCTA work underway and want to evaluate its maturity and quality, tools like our SCTA Health Check provide a structured way to do this. It’s worth noting that this sits at the informed oversight level and above – you need a certain level of knowledge to use it meaningfully, which itself tells you something about the “how intelligent” question.
Practitioner capability. The full SCTA course is for people who are going to do the work themselves – moving beyond intelligent customer capability into SQEP territory. This is the investment for organisations transitioning from DFY to DIY.
Ongoing development. Maintaining and growing capability over time matters. The Human Reliability Hub is a community we’re building for people on this journey – a space to share challenges, stay connected to evolving practice, and develop capability beyond a one-off training event. If you’re interested, we have a waiting list for people who’d like to join.
These aren’t rigid stages, and the right entry point depends on where your organisation is and what it needs. But they illustrate the principle: different levels of engagement serve different purposes, and intelligent customer capability is a journey, not a box to tick.
Where Do You Sit on This Spectrum?
If this blog has prompted you to think about your organisation’s intelligent customer capability for human factors, that’s a good start. The question isn’t whether you need it – the Delivery Guide is clear on that. The question is whether you have enough, and whether it’s the right kind, for the topics that matter most to your site.
We’d be happy to discuss where you are on this journey. Sign up to our blog and mailing list for more content on human factors for COMAH sites, or get in touch directly.
Acknowledgement
This blog was written with the assistance of Claude (Anthropic). The concept, arguments, real-world examples and domain expertise are mine — Claude helped with research into the origins of intelligent customer capability, structuring the blog, and drafting the text through an iterative conversation. I reviewed and edited the final version.
References and Resources
Blog: Management Models for Proactive Human Factors
Mini-Course: Human Factors Task Reviews: Quality & Safety
One-Day Course: Introduction to Human Factors for Process Safety, Loss Prevention & COMAH
Webinar Replay: SCTA Health Check: Introduction
CIEHF-accredited training: Master Human Factors Safety Critical Task Analysis
Coming soon: Join the waitlist for our Community of Practice
Delivery Guide: HSE Human Factors Delivery Guide for COMAH
HSE Website: Intelligent Customer Capability page
