A guide to the installation verificationand miscellaneous aspects ofamendments by the Offshore

Installations and Wells (Design andConstruction, etc) Regulations 1996 tothe Offshore Installations (Safety Case)

Regulations 1992

GUIDANCE ONREGULATION S

L 83 - HSE BOOKS

©Crown copyright 1996Applications for reproduction should be made to HMSOFirst published 1996

ISBN 0 7176 1193 0

All rights reserved. No part of this publication may bereproduced, stored in a retrieval system or transmitted in any form or by any means (electronic, mechanical, photocopying, recording, or otherwise) without theprior written permission of the copyright owner.

i

This guidance is issued by the Health and Safety Executive (HSE). Following the guidance is not compulsory and youare free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law.Health and safety inspectors seek to secure compliance withthe law and may refer to this guidance as illustrating good practice.

Cover photograph courtesy of BP Exploration

(ii)

Contents Preface iv

Introduction 1

Verification of safety-critical elements of installations

Relationship between these Regulations and otherhealth and safety law 2

Amendments to the Offshore Installations (Safety Case)Regulations 1992 relating to installation verification 3Amendment to regulation 2(1) Definition of ‘safety critical elements’ 3New regulation 2(7A) The verification scheme 3New regulation 2(7B) Means of verification 4New regulation 2(7C) Independence 5New regulation 13A

New regulation lS(2A) Keeping of documents and records 6Amendment to regulation 15(3) Records kept by electronic means 6New regulation 15A Verification schemes for safety-critical

elements 7New regulation 15B Matters to be included in a verification

scheme 7New regulation 1SC Review and revision of verification

schemes 7New regulation 1SD Continuing effect of verification

schemes 8New regulation 1SE Defence 9New Schedule 9 Matters to be provided for in a

verification scheme 9

1

Transitional provision relating toverification 6

Appendix 1 Further amendmentsto the Offshore Installations (Safety Case) Regulations 1992 11

Amendments relatingto well operationsAmendment to regulation 2(1) Definition of ‘concession owner’ 11New regulations 11(S), 11(6)and 11(7) Notification of well operations from a

vessel 11Amendment to Schedule 6 Particulars to be included in notification

of well operations 11New Schedule 6 A Particulars to be included in notification

of well operations from a vessel 12

Amendments relating to toxic gas New Schedule 2 paragraph 9A

New Schedule 3paragraph 7A

Particulars to be included in a safety case for a fixed installation 13Particulars to be included in a safety case for a mobile installation 13

Other amendmentsAmendment to regulation 2(1) Definition of ‘management system’ 14Amendment to regulation 8 Definition of ‘audit’ 14

Appendix 2 References 15

(iii)

Preface This document provides guidance on the Offshore Installations (Safety Case) Regulations (SI 1992/2885) 1 (SCR), as amended by regulation 26 andSchedule 2 of the Offshore Installations and Wells (Design and Construction,etc) Regulations 1996 (SI 1996/913)2 (DCR), which will come into force on30 June 1996. It is intended to assist those people who may be affected by theRegulations to understand what the Regulations require.

Detailed guidance on other matters contained in the DCR may be found in thepublications:

(a) A guide to the integrity,workplace environment and miscellaneous aspects ofthe Offshore Installations and Wells (Design and Construction, etc) Regulations19963; and

A guide to the well aspects of the Offshore Installations and Wells (Design andConstruction etc) Regulations 19964.

(b)

In due course the guidance contained in this document will be incorporated into the guidance on the SCR when the current guidance document (Aguide tothe Offshore Installations (Safety Case) Regulations5) is revised and updated totake account of modifications introduced by the Offshore Installations andPipeline Works (Management and Administration) Regulations 1995 (SI1995/738)6 (MAR) and Offshore Installations (Prevention of Fire andExplosion, and Emergency Response) Regulations 1995 (SI 1 995/743)7

(PFEER) as well as DCR.

For convenience the text of the Regulations appears in italics, with the relevantguidance below. Where the Regulations are considered to be self explanatoryno comment is offered. There are several references to relevant legislation andguidance in the text; these are numbered the first time they appear, and a list isprovided at Appendix 2.

(iv)

Introduction 1 The Regulations and guidance in this document have been drawn upfollowing consultation with representatives of the industry associationsrepresenting offshore operators and contractors, trades unions representing theoffshore workforce and other interested organisations and governmentdepartments.

2cover the introduction of requirements for the safety-critical elements of anoffshore installation to be verified as suitable by an independent and competent person. They replace the certification regime established by the OffshoreInstallations (Construction and Survey) Regulations 1974 (SI 1974/289)8,which are revoked by the DCR. There is, however, the option of a transitional period for installations already covered by the certification regime; furtherdetails are given in paragraph 32.

3in relation to the notification of well operations from vessels which are notinstallations. It also introduces some amended definitions, and gives full effect to Extractive Industries (Boreholes) Directive (No 92/9l/EEC)9 (EID) provisions relating to toxic gases. Guidance on these matters is provided inAppendix 1.

Verification of safety-critical elements of installations

4 The overall objective of the offshore verification scheme is to set in placeindependent and competent scrutiny of those parts of an installation which arecritical to safety (referred to in these Regulations as safety-critical elements).The purpose of this scrutiny is to obtain assurance of the achievement of thesatisfactory condition of such items. Throughout the installation’s life cycle (from design through fabrication, construction, hook-up and commissioning,and the whole operating life to decommissioning and dismantling) theverification scheme should ensure that appropriate examinations are carried outof these safety-critical elements to provide independent confirmation that theyare (or will be) suitable for their intended purpose.

5demonstrations required elsewhere in these Regulations. It will therefore beappropriate to include a summary of the scheme in installation safety cases.

6 The verification requirements, like those in the rest of the SCR, applyalike to fixed and mobile installations, including those installations designed and built abroad for use in UK waters. The requirements also apply to bothnew and existing installations. The definition of an installation for the purposeof the SCR is as set out in regulation 3 of MAR, and includes any pipeline connected to the installation within 500 metres of any part of its main structure. It also includes wells attached to an installation by pipe or cable, andany apparatus or works on or affixed to the installation’s main structure.

7remain unchanged throughout the installation’s life. Rather, it will developfrom a broad outline of the overall scheme to more detailed arrangements asthe design and construction phases give way to hook-up, commissioning andoperating activities. It is important for duty holders to view the verificationscheme for an installation as a holistic project; individual components of thescheme are important in themselves but will only give a true picture when considered with reference to each other.

The Regulations and guidance set out in the main part of this document

Schedule 2 of the DCR amends the SCR in certain other respects, chiefly

For the duty holder, the scheme will contribute to the duty holder’s

The verification scheme will not come into being on a specified date and

1

Relationship between these Regulations and other health and safety law

8 These provisions complement other regulations in a number of areas.Specific links are described under individual sections of the guidance. Thissection deals with the place these requirements take in the overall pattern oflegislation, particularly that focused on health and safety.

Safety Case Regulations

9the introduction of a safety case regime offshore, underpinned bycomplementary legislation dealing with specific aspects of safety. The SCRwere introduced in 1992, followed in 1995 by MAR and PFEER and in 1996by the DCR. One of the major facets of the SCR is the requirement todemonstrate that management systems are adequate to ensure compliance with relevant statutory health and safety provisions. The verification arrangementsintroduced into the SCR by DCR will be an important component of suchmanagement systems. They will also contribute to the demonstrations of safetyrequired elsewhere in the SCR.

10 Regulation 8 of MAR requires every person to co-operate with the duty holder so far as is necessary to enable the duty holder to comply with relevant statutory provisions. This is relevant to the verification requirements; furtherguidance is given in this document at regulation 15E.

PFEER

11 The verification scheme will contribute to ensuring compliance with obligations under PFEER, and will help provide evidence of such compliance.Work done to comply with PFEER regulation 19’s requirement for a written scheme of examination may also contribute to the verification scheme; furtherguidance is provided in this document in relation to regulation 2(7B).

DCR

12installations and well safety. Both these areas can be expected to featureprominently in verification arrangements for safety-critical elements. As forPFEER, verification schemes will help to provide evidence of compliance with obligations under the DCR. Work done to comply with the well examinationrequirements in DCR regulation 18 may contribute to the installationverification arrangements, as described in the guidance for regulation 2(7B).

The Provision and Use of Work Equipment Regulations 1992

131992/2932)1 1 (PUWER) seek to ensure the safe provision and use of workequipment. Where such equipment is safety-critical, as defined in the amendedSCR, it will be subject to verification arrangements.

Article 100 and 100 A derived legislation

14the legislation implementing European Directives made under Articles 100 andl00A of the Treaty of Rome (such as the Supply of Machinery (Safety)Regulations 1992) (SI 1992/3073) 12. Such legislation contains requirements for conformity assurance measures as evidence of compliance with essentialhealth and safety requirements (EHSRs) laid down in the Directives.Compliance by manufacturers, importers and suppliers with the EHSRs maycontribute to verification schemes.

In his report on the Piper Alpha disasterlo, Lord Cullen recommended

Two major parts of the DCR deal with assuring the integrity of offshore

The Provision and Use of Work Equipment Regulations 1992 (SI

Some equipment found on offshore installations will also be covered by

2

Mar

Modification of the Offshore Installations (SafetyCase) Regulations 1992

Regulation 26

Amendments relatingto installation verification

1 .2 to 4 of this Schedule.

15verification arrangements for installations. Guidance on the other aspects isprovided in Appendix 1.

3.definition:

“safety-criticalelements” means such parts of an installation and such of its plant(including computer programmes), or any part thereof-

Paragraph (1) of regulation 2 shall be amended in accordance with paragraphs

The material presented in this part of the document deals only with

After the definition of “safety case”, there shall be inserted thefollowing

(a)

(b)

the failure of which could cause or contribute substantially to; or

a purpose of which is to prevent, or limit the effect of,

a major accident.

16provisions. Any structure, plant, equipment, system (including computersoftware) or component part whose failure could cause or contributesubstantially to a major accident is safety-critical, as is any which is intended toprevent or limit the effect of a major accident. The identification of an item assafety-critical should follow from the identification of major accident hazards required by regulation 8(1)(c). Reference to the meaning of ‘major accident’set out in regulation 2 may be helpful.

17safety-critical elements. Within such systems, while many individualcomponents are themselves in the category of safety-critical elements, theremay be others which are not.

18 The term ‘contribute substantially to a major accident’ is intended to include within the category of ‘safety-critical element’ those parts whose failurewould not directly cause a major accident but would make a significantcontribution to a chain of events which could result in a major accident.

19detection, control and mitigation of major accidents. Items improvingreliability by providing redundancy or diversity should also be considered.

20

5.paragraphs:

“(7A) A n y reference in these Regulations to a verification scheme is a reference to asuitable written schemefor ensuring, by means described in paragraph (7B), that thesafety-critical elements-

The term ‘safety-critical elements’ is an important component of these

A systems approach is necessary to identify those systems which are

Consideration of safety-critical elements should include systems for the

Although many items will be safety-critical on every installation, there will

Afterparagraph (7) ofregulation 2 there shall be inserted the following

(a)

(b)

are or, where they remain to be provided, will be suitable; and

where they have been provided, remain in good repair and condition.”.

3

21order to be regarded as a ‘suitable written scheme’, it would need to giveassurance of achieving the objectives described in this regulation, and the requirements set out in regulation 15. The scheme should ensure that safety-critical elements are suitable; in this context ‘suitable’ includes beingappropriate for the intended use, dependable and effective when required, andable to perform as intended. The verification scheme should provideindependent checks to confirm continuing suitability throughout theinstallation’s life cycle. It should take account of maintenance work, repairs andoperating practices. The scheme is complementary to, but not a substitute for,routine maintenance programmes. A verification scheme would be expected toidentify errors or failures in areas such as specification, selection of appropriateperformance standards, design, construction or maintenance of elements whichhave been identified as safety-critical, so that appropriate preventative orremedial action can be taken. Industry representatives are developingguidelines on drawing up and implementing verification schemes.

“(7B)

Paragraph (7A) explains what is meant by a ‘verification scheme’. In

The means referred to in paragraph (7A) are-

(a) examination, including testing where appropriate, of the safety-criticalelements by independent and competent persons;

examination of any design, specification, certificate, CE marking orother document, marking or standard relating to those elements by suchpersons;

examination by such persons of work in progress;

the taking of appropriate action following reports by such persons;

the taking of such other steps as may properly be provided for pursuantto regulation 15B and Schedule 9; and

the taking of any steps incidental to the means described in sub-paragraphs (a) to (e) of this paragruph. ”.

(b)

(c)

(d)

(e)

(f)

22paragraph (7A). Duty holders should select the most appropriate means ofverification for each aspect of the scheme.

23persons’ to carry out verification. Guidance on what is meant by ‘independent’in this context is provided at paragraphs 30-31. Issues for consideration withregard to the competence of a person carrying out verification work includesuch matters as technical competence (suitably qualified staff in adequatenumbers, relevant experience, etc); and aspects such as the allocation of tasksto staff competent to undertake them and arrangements for the flow ofinformation. Examination by competent persons will involve careful and criticalscrutiny of safety-critical elements, or the processes involved in achieving andmaintaining their suitability, using appropriate techniques, which may includetesting. Professional judgement will be an important aspect of such work, as will the use of appropriate methods of examination, testing and analysis.

24work who are appropriately independent and competent to do the workallocated to them. They will need to be able to justify their selection and maywish to make reference to existing standards and established schemes forvalidation of organisations offering specialist services (eg the NationalCertification Scheme for In-service Inspection Bodies13 for inspection aspects

Paragraph (7B) lists the means to achieve the purposes described in

Frequent reference is made to the use of ‘independent and competent

Duty holders are responsible for selecting persons to carry out verification

4

of verification). Duty holders are free to use other means of demonstratingcompliance with the legal requirements.

25means the examination of activities such as fabrication, construction, andrepair.

26 Sub-paragraph (d) requires duty holders to take appropriate action in thelight of the findings of examinations by the independent and competent person.If problems are identified, they will need to decide how to resolve them, andensure that any necessary remedial work is carried out.

27 Sub-paragraphs (e) and (f) allow for additional steps to be taken besides those specified in (a) to (d) where they are necessary to meet the requirements of regulation 15B and Schedule 9, or of the remainder of this regulation.

28legal or voluntary requirements such as classification (of mobile installations), or declarations of conformity with European product legislation. It is notnecessary to duplicate any work done for another reason, as long as it issuitable to contribute to the verification scheme. It is up to the duty holder toensure that it is sufficient for the purposes of these Regulations, and to decidewhat else may be needed to complete the verification package for a particularinstallation.

29examination required by PFEER regulation 19 ( 2 ) .Arrangements for theverification of the suitability of such plant may take account of the examination carried out in compliance with PFEER requirements. Similarly, where a well is associated with an installation, work done to meet the requirements of the wellexamination scheme in DCR regulation 18 may contribute to the installation’soverall verification arrangements as appropriate.

“(7C)shall be regarded as independent only where-

The ‘examination of work in progress’ referred to in sub-paragraph (c)

The verification scheme may take into account work done to satisfy other

Some safety-criticalplant will be subject to the written scheme of

For the purposes ofparagraph (7B) and regulations 15A and 15C a person

(a) hisfunction will not involve the consideration by him of an aspect, of athing liable to be examined, for which he bears or has borne suchresponsibility as might compromise his objectivity; and

he will be sufficiently independent of a management system, or of a partthereof, which bears or has borne any responsibilityfor an aspect, whichhe might consider, of a thing liable to be examined, to ensure that he willbe objective in discharging hisfunction. ”.

(b)

30the ‘independent and competent persons’ who must carry out various functionsunder the verification scheme. In this context ‘person’ has the same meaning asin the Interpretation Act 197814 and includes any body of persons corporate orunincorporate. The main concern here is to ensure that these persons aresufficiently impartial and objective in their judgement that safety is notcompromised. They should not be subject to conflicts of interest.

31levels of impartiality and independence from pressures, especially of a financialor operational nature, which could affect sound judgement. They should notverify their own work, and their management lines should be separate from those whose work they are checking. For instance, while it is acceptable inprinciple for a duty holder’s in-house team to check work done elsewhere in the

Paragraph 7(C) provides the basis for determining the independence of

It is important that those carrying out verification work have appropriate

5

same organisation, it would influence objectivity if their management chain included the manager responsible for meeting production targets which mightbe unachievable if plant were shut down on safety grounds. Promotion, payand reward systems should not compromise professional judgement.

8.regulation:

“Transitionalprovision relating to verification

13A. Theprovisions of regulations 15A to 15D shall not apply in relation to aninstallation while provisions of the Offshore Installations (Construction and Survey)Regulations 1974 are deemed to remain inforce in relation to that installation byvirtue of regulation 24 of the Offshore Installations and Wells (Design andConstruction, etc.) Regulations 1996. ”.

32regulations 15A to 15D while the duty holder makes use of the transitionalprovision in DCR regulation 24. Further guidance on this provision is given inA guide to the integrity, workplace environment and miscellaneous aspects of theOffshore Installations and Wells (Design and Construction, etc) Regulations 1996. Inessence, adherence to the provisions of SI 19741289 will, for the duration of thetransitional period, be regarded as an adequate substitute for the verificationscheme required by these Regulations.

9.paragraph:

“(2A)

After regulation 13 (transitional provisions), there shall be added the following

Regulation 13A waives the new verification requirements introduced in

After paragraph (2) of regulation 15 there shall be inserted the following

The operator or owner of an installation shall ensure that-

(a) its verification scheme, any modification of that scheme, and anynote made pursuant to regulation l5A(1) (d) or (3) (d) or regulation15C(b), is kept, at an address in Great Britain notified to the Executive,until the expiration of six months after such scheme or, as the case may be,modifcation of that scheme, has ceased to be current; and

records, sufficient to show the matters described in paragraph 5 ofSchedule 9, are kept at the address notified pursuant to sub-paragraph(a) of thisparagraph until the expiration of six months after the scheme,pursuant to which they were compiled, has ceased to be current.”.

The purpose of this requirement is to provide an auditable trail showing

(b)

33what work has been done, its findings, any recommendations made and anywork carried out as a result. The necessary records should be retained for aperiod of six months after the relevant scheme ceases to be current (forexample, after the installation has been decommissioned). Earlier records pertinent to a new or modified scheme should be retained for as long as they are relevant.

10.and (g) ’’there shall be substituted the words:

“sub-paragraphs (b), (e), (e) and (g), ofparagraph (1) , and with paragraph(2A) ”.

34means.

In paragraph (3) of regulation 15, for the words “paragraph (1) (b), (c), (e)

This paragraph deals with the acceptability of records kept by electronic

6

11.

“Verification schemesforsafety-criticalelements

15A- (l)time before completion of the design as is identifed by regulation 4(1), ensure that-

After regulation 15 there shall be inserted the following regulations:

Subject to paragraph (2), the operator of a fixed installation shall, a t such

(a)

(b)

(c)

(d)

a record is made of the safety-critical elements;

comment on the record by a n independent and competent person is invited;

a verification scheme is drawn up by or in consultation with such person;

a note is made of any reservation expressed by such person as to thecontents of-

(i) the record; or

(ii) the scheme; and

such scheme is put into effect.

Where, in the case of a fixed installation, the time referred to in paragraph

(e)

(2)(1) has at the cominginto force of this regulation expired, the operator shall ensurethat the installation is not operated unless the provisions of sub-paragraphs (a) to (e)of paragraph (1) and regulation 1 5 B have been complied with.

(3) Subject to paragraph (4), the owner of a mobile installation shall, beforethe installation is moved in relevant waters with a view to its being operated there, ensure that-

(a)

(b)

(e)

(d)

a record is made of the safety-critical elements;

comment on the record by a n independent and competent person is invited;

a verification scheme is drawn up by or in consultation with such person;

a note is made of any reservation expressed by such person as to the contents of -

(i) the record; or

(ii) the scheme; and

such scheme is put into effect.

Where, at the coming intoforce of this regulation, a mobile installation is

(e)

(4)being operated, the owner shall ensure that it does not continue to be operated unless the provisions of sub-paragraphs (a) to (e) ofparagraph (3) and regulation 1 5 Bhave been complied with.

Matters to be included in a verification scheme

15B. A verification scheme shall provide for the matters contained in Schedule 9.

Review and revision of verification schemes

15C. The operator, in the case of a fixed installation and the owner, in the case of amobile installation, shall ensure that, as often as may be appropriate-

7

(a) the verification scheme is reviewed and, where necessary, revised orreplaced by or in consultation with an independent and competent person;and

a note is made of any reservation expressed by such person in the course ofdrawing it up.

(b)

Continuing effect of verification schemes

15D. The operator of a fixed installation, and the owner of a mobile installation, shall ensure that effect continues to be given to its verification scheme, or any revision orreplacement of it, while the installation remains in being. ”.

35 Regulations 15A-15D provide more detail on how a duty holder isrequired to prepare and put into effect a verification scheme. Fixed and mobileinstallations are dealt with separately in this regulation because they come into UK jurisdiction at different stages. For a new fixed installation, a verificationscheme is required to be put in hand before the completion of design work.

36enters UK waters, but it is important that duty holders understand that theywill need to be able to demonstrate the adequacy of verification schemes in allrespects, including matters relating to design, construction and theinstallation’s history before it entered UK waters. Previous class and flag statesurveys may prove helpful here.

37designed and built with these legal requirements in mind, and it is stronglyrecommended that suitable records of the installation’s design and constructiondetails are obtained with the installation. Duty holders purchasing second-handinstallations would be well-advised to seek similar records of their operating life. Duty holders may be able to demonstrate compliance with the verificationrequirements by other means.

38monitoring and review throughout the installation’s life cycle. Anydevelopment which could alter the list of safety-critical elements, or affect theverification arrangements appropriate to them, should be fed into the reviewprocess and, where necessary, into the revision of the verification scheme. Thisiterative process should be carried out with the help of appropriatelyindependent and competent persons for the task in hand.

39accurate identification of the safety-critical elements for the installation. Thework done to identify hazards in preparing the safety case will assist this process. The duty holder’s own organisation may perform this work, or it may be done by an appropriate contractor. The identification of safety-criticalelements is crucial to the effectiveness of the scheme. The responsibility for the. list of safety-critical elements will rest with the duty holder. Regulation 15A requires the opinion of an independent and competent person to be sought where this identification has not been carried out by such a person. If thisperson is not content with the list, and the difference of opinion cannot beresolved in discussion, the reservation should be noted. A detailed assessmentby the independent and competent person of the methodology used to identifythe safety-critical elements is not required. This person is expected to useprofessional judgement, expertise and experience to reach a view on whetherthe list is appropriate for the installation in question.

For a mobile installation, the verification requirements take effect when it

It would be helpful if any installation intended for use in UK waters were

A verification scheme will develop and should be subject to continual

The essential preliminary to developing a verification scheme will be the

8

40similarly be subject to a check by a person who is both competent and independent if it is not drawn up by such a person. These checks could be carried out during the development of the scheme.

41 Here too, the responsibility for the scheme - how and with what frequencysafety-critical elements should be examined, etc - will rest with the duty holder.If concerns are raised with the duty holder by the independent and competent person these must be documented; the duty holder should be able to justify thedecisions reached.

Defence

“15E.-(l) In any proceedings for an offence for a contravention of any of theprovisions ofregulations 15A to 15D it shall, subject to paragraphs (2) and (3), be adefence for the person charged to prove-

The scheme itself, covering the topics set out in Schedule 9, should

(a) that the commission of the offence was due to the act or default of anotherperson not being one of his employees (hereinafter called “theotherperson’?; and

that he took all reasonable precautions, and exercised all due diligence, toavoid the commission of the offence.

The person charged shall not, without leave of the court, be entitled to rely

(b)

(2)on the defence referred to in paragraph (1) unless, within a period ending seven cleardays-

(a) before the hearing to determine mode of trial, where the proceedings are inEngland or Wales; or

before the trial, where the proceedings are in Scotland,(b)

he has served on the prosecutor a notice in writing giving such information identyfying or assisting in the identification of the other person as was then in his possession.

For the purpose of enabling the other person to be charged with and (3)convicted of the offence by virtue of section 36 of the 1974 Act, a person whoestablishes a defence under this regulation shall nevertheless be treated for thepurposesof that section as having committed the offence. ”.

42the proper performance of functions required under these Regulations. Regulation 15E offers a defence under the circumstances set out in sub-paragraphs (l)(a) and (b).

43required by regulation 8 of MAR to co-operate with (among others) ownersand operators of installations so far as is necessary to enable compliance with relevant statutory provisions. Regulation 14 of the SCR is also relevant.

The duty holder will need to put in place suitable arrangements to ensure

Independent and competent persons carrying out verification work will be

16. After Schedule 8 there shall be added the following schedule:

“SCHEDULE 9 Regulation 15B

M A T T E R S T O B E PROVIDED F O R I N A VERIFICATION SCHEME

1.persons-

(a)

The principles to be applied by the duty holderfor the installation in selecting

to perform under the scheme; and

9

(b)

Arrangements for the communication of information necessaryfor the proper

to keep the scheme under review.

2.implementation, or revision, of the scheme to the persons referred to inparagraph 1.

3.

4.

5.

The nature and frequency of examination and testing.

Arrangements for review and revision of the scheme.

The arrangements for the making and preservation of records showing-

(a)

(b) thefindings;

(e) remedial action recommended; and

(d) remedial action performed.

Arrangements for communicating the matters contained in sub-paragraphs (a)

the examination and testing carried out;

6.to (d) of paragraph 5 to an appropriate level in the management system of the dutyholderfor the installation. ”.

44 Schedule 9 contains details of the information needed in a verificationscheme. Paragraph 1 requires the principles applied by the duty holder inselecting the independent and competent person(s) to carry out work under thescheme, including its review, to be explained in the scheme. The informationrequired relates to matters such as the degree of technical expertise, knowledge and experience which will be needed to carry out tasks within the verificationscheme, and the appropriate levels of independence.

45person or organisation who will do the work; those detailed selection processes will be an important component of the duty holder’s safety managementsystem. T o avoid creating a conflict of interest for the independent and competent person(s), it may be appropriate for the duty holder to select theperson(s) to carry out the verification work described in the scheme after thescheme has been drawn up.

46carried out by the same person, nor to prevent this, as long as the person(s)involved are suitably independent and competent.

47 Paragraph 2 refers to the communication of information to the person(s) carrying out verification work under the scheme so that they can perform theirtasks. It is important that duty holders ensure that those responsible for managing their verification schemes have a thorough understanding of theimplications of all facets of the different stages of the installation’s life cycle andhow they fit together. The process would benefit from appropriate access tocurrent design details throughout the installation’s life cycle so that lateractivity can be checked for compatibility with the appropriate parameters.

48 Co-ordination will be particularly important if several different persons ororganisations are used to implement a scheme for a single installation, or wherea verification contract is re-allocated to another person. Care will be needed toavoid gaps in verification coverage.

49the verification process to the appropriate levels in the duty holder’sorganisation. An appropriate level would be that with sufficient authority toensure that the action required in the light of verification findings is taken.

The information provided under this requirement need not identify the

There is no requirement for all verification work for an installation to be

Paragraph 6 refers to the arrangements for communicating the output of

10

Further amendments to the Offshore Installations(Safety Case) Regulations 1992

Amendments relating to well operations

SCHEDULE 2 Regulation 26

MODIFICATION OF T H E OFFSHORE INSTALLATIONS (SAFETY CASE) REGULATIONS 1992

1.2 to 4 of this Schedule.

2.definition:

“concession owner” in relation to a fixed installation, or to a well or proposed well means the person who at any time has the right to exploit or explorefor mineralresources in any area, or to store gas in any area and to recover gas so stored, i f , atthat time, the installation, or, as the case may be, the well or proposed well is, or is tobe, used in the exercise of that right.

7.

Paragraph (1) of regulation 2 shall be amended in accordance with paragraphs

For the definition of “concession owner” there shall be substituted the following

There shall be added to regulation 11 thefollowing paragraphs:

“(5) Where an operation is to be carried out in relation to a well or proposedwell by means of a vessel which is not an installation, the well-operator shall ensurethat the c a r r y i n g out ofthe operation is not commenced unless at least 21 days beforeits commencement he has sent to the Executive a notification containing the particularsspecified in Schedule 6A.

(6) Where there is a material change in any of the particulars notified pursuant to paragraph (5), the person who, at the time of that change, would havehad the duty under paragraph (5) to notify those particulars, if they had been requiredat the time of that change, shall notify the Executive of that change as soon as ispracticable after that change. ”.

1well operations specified in the new Schedule 6A to those carried out from a vessel 21 days before such operations start. It is an offence not to do so. Inaddition, regulation 11(6) requires further notification should there be materialchange to the information in the original notification.

2the notification of the specified well operations.

This amendment to regulation 11 extends the requirement to notify the

Regulation 11(5) identifies the well-operator as the person responsible for

“(7) In this regulation “well-operator”, in relation to a well or proposed well, means the person appointed by the concession ownerfor the well or proposed well toexecute the function of organising and supervising all operations to be carried out bymeans of such well or, where no such person has been appointed, the concessionowner.”.

14. In Schedule 6 there shall be added to the heading the words:

“from an installation”.

After Schedule 6 there shall be added the following schedule:15.

1 1

-Schedule “SCHEDULE 6 A Regulation 11(5)

PARTICULARS TO B E INCLUDED I N NOTIFICATION OF WELLOPERATIONS FROM A VESSEL

1.

2.this Schedule referred to as “thevessel’?.

3.

4.any field development of which it may be part.

5.

The name and address of the person notifying the particulars in this Schedule.

The name of the vessel by means of which the operation is to be carried out (in

Particulars of the fluids to be used to control the pressure of the well.

Particulars of the type of well, its number, and slot number, and the name of

Particulars, with scale diagrams, of-

(a)

(b)

(c)

(d)

A description of the operations on the well and a programme of works which

the location of the top of the well;

the directional path of the well-bore;

its terminal depth and location; and

its position, and that of nearby wells, relative to each other.

6.includes-

(a) the dates on which the operations are expected to commence and finish; and

the intended operational state of the well at the end of the operations. (b)

7. A description of-

(a) any activities on or in connection with the vessel during operations on thewell described pursuant to paragraph 6, which will involve any hazardswith the potential to cause a major accident;

(b) such hazards.

In the case of an existing well-

(a)

(b)

(c)

(d) its current operational state;

(e) its state of repair;

(f)

8.

a diagram of the well;

a summary ofearlier operations in relation to it;

the purposes for which it has been used;

the physical conditions within it; and

2 (g) its production capacity.

9. Particulars of-

(a) the meteorologicaland oceanographic conditions to which the vessel mayforeseeably be subjected;

the depth of water; and

the properties of the sea-bed and subsoil,

(b)

(e)

at the location at which the operations will be carried out.

10. Sufficient particulars to demonstrate that the arrangements and procedures ofthe person notifying the particulars in this Schedule, and of the operator and owner ofthe vesselfor managing the operations are co-ordinated to reduce risksfrom a major accident to the lowest level that is reasonably practicable. ”.

31 1 (5). If the planned programme of work is changed materially after notification, the Regulations require a further notification which identifies thechanges.

4a vessel are of particular importance. The notification will therefore need todescribe how the management arrangements of the licence operator and the owner of the vessel will be co-ordinated.

5can be carried on. Should the information provided give cause for concern,HSE may intervene by, for example, requesting further information, inspecting, or by issuing an enforcement notice under the Health and Safety at Work etcAct 1974l5. When considering whether intervention is appropriate, HSE willtake account of the following factors (among others):

(a)

(b)

(c)

Schedule 6A sets out the information to be provided under regulation

The management arrangements for well operations being conducted from

Notification does not require acceptance by HSE before well operations

the major accident potential of the well operation being undertaken;

the assessed adequacy of the management and other risk control systems;

whether the operations will take place in extreme or unusualenvironmental conditions, or whether the well operations themselves areunusual.

Amendments relatingto toxic gas

12.

“9A. A description ofarrangements madeforprotecting persons on the installationfrom toxic gas at all times other than during the period described inparagraph 9.”.

13.

“7A. A description of arrangements made for protecting persons on the installation from toxic gas at all times other than during the period described in paragraph 7.".

6of requirements for specific consideration of the risks of hydrogen sulphide andother toxic substances. These provisions fulfil a requirement in the EID.

Afterparagraph 9 ofSchedule 2 there shall be inserted the following paragraph:

After paragraph 7 of Schedule 3 there shall be inserted the following paragraph:

These paragraphs amend Schedules 2 and 3 of the SCR by the addition

13

Other amendments

4.definition:

“management system” means the organisation and arrangements established by aperson for managing his undertaking.

6.paragraph:

“(4)

After the definition of “major accident” there shall be inserted the following

There shall be substituted for paragraph (4) of regulation 8 the following

In this regulation “audit” means systematic assessment of the adequacyof a management system to achieve the purpose referred to in paragraph (1) (a)carried out by persons who are sufficiently independent of the system (but who may beemployed by the duty holder) to ensure that such assessment is objective. ”.

14

References

1HMSO 1992 ISBN 0 11 025869 X

21996 (SI 1996/913) HMSO 1996 ISBN 0 11 054451 X

3OffshoreInstallations and Wells (Design and Construction etc) Regulations 1996HSE Books 1996 ISBN 0 7176 1164 7

4Construction etc) Regulations 1996 HSE Books 1996 ISBN 0 7176 1194 9

5on Regulations (L30) HSE Books 1992 ISBN 0 11 882055 9

6Administration) Regulations 1995 (L70) HSE Books 1995 ISBN 0 7176 0938 3

7installations. Offshore Installations Regulations 1995 and Approved Code of Practiceand Guidance (L65) HSE Books 1995 ISBN 0 7176 0874 3

8(SI 19741289) HMSO 1974 ISBN 0 11 040289 8

9the European Communities No. L348, 28.11.92, p. 9, [available from HMSOBooks (Agency Section)]

10Department of Energy HMSO 1990 ISBN 0 10 113102 X (2 volumes)

11Regulations (L22) HSE Books 1992 ISBN 0 7176 0414 4

121992 ISBN 0 11 025719 7

13

The OffshoreInstallations (Safety Case) Regulations 1992 (SI 1992/2885)

The Offshore Installations and Wells (Design and Construction etc) Regulations

A guide to the integrity, workplace environment and miscellaneousaspects of the

A guide to the well aspects of the Offshore Installations and Wells (Design and

A guide to the Offshore Installations (Safety Case) Regulations 1992 Guidance

A guide to the Offshore Installations and Pipeline Works (Management and

Prevention of fire and explosion, and emergency response on offshore

The Offshore Installations (Construction and Survey) Regulations 1974

The Extractive Industries (Boreholes) Directive 92/91/EEC, Official Journal of

The Public Enquiry into the PiperAlpha Disaster (Cullen Report) Cm 1310

The Provision and Use of Work Equipment Regulations 1992 and Guidance on

The Supply ofMachinery (Safety) Regulations 1992 (SI 199213073) HMSO

The National Certification Scheme for In-service Inspection Bodies1 Birdcage Walk, Westminster, London, SWlH 9JJTel: 0171 973 1271Fax: 0171 973 0449

The Interpretation Act 1978 HMSO 1978 ISBN 0 10 543078 1

The Health and Safety at Work etc Act 1974 HMSO 1991 (reprint)

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15ISBN 0 10 543774 3

Printed and published by the Health and Safety Executive ISBN 0-7176-1193-0 C50 6/9 6

15