Case Title - [Safety Case Title]COIN Numbers - [Case] / [SVC Number]
Operator – [Company Name]Environmental Topic Assessor – [Name]
EnvironmentalOPERATIONAL CONTROL ASSESSMENT TEMPLATE
Work Instructions
Topic specialists should use this template to record their assessment of the Environmental Operational Control aspects of a safety case. Assessment should be against the requirements of SCR2015.
Exemplar Approach - This template should be used in accordance with the scope of the Assessment Instructions when the topic is included for assessment. An exemplar approach may be sufficient if some material has been previously accepted and has not materially changed.
The template is one of a series covering all assessment topics, which together form a complete record of the safety case assessment and create evidence of how the decision to accept the case, or not, was reached. The templates identify the specific regulatory requirements of SCR2015 for the topic and indicate what the competent authority expects to find within a safety case to demonstrate that those requirements are met. The template complements the published guidance that supports the regulations and topic sector guidance. The templates are available to promote transparency and assist duty holders in drafting submissions.
Green text indicates regulatory requirements that are new in SCR2015.
Black text represents regulatory requirements that are contained in both SCR2005 and SCR2015.
Non Acceptance Issue - A Non Acceptance Issue (NAI) is a deficiency in the demonstration made within a safety case, which, if not resolved, will prevent the case from being accepted under the relevant statutory provisions. Non Acceptance Issues must be sent by a formal letters to the duty holderrequiring them to be dealt with in the appropriate manner, giving the duty holdera clear understanding of how to address the deficiency.
Clarification - A Clarification is an explanation provided by a duty holder on request during assessment to enable the assessing Inspectors to be confident of their interpretation of theinformationina safety case. Clarifications are a routine part of assessment work andshould be raised with aduty holderpromptly. Clarifications do not require formal letters. Communicating by telephone and email is sufficient. A meeting between the duty holder and relevant topic specialists may also be appropriatein somecircumstances for clarifications. Clarification is not a first stage before raising non-acceptance issues. Any aspect that could credibly lead to a Non-Acceptance Issueshould be raised as such in the first instance.
Relevant Pre-Existing Guidance
N/A
1. [CMAPP] Requirements
SCR2015 Schedule 6(3) / 7(3)– Particulars to be included in a Safety Case
SCR2015 Regulatory Requirement / Clarification / NAISchedule 6(3) A copy of the operator’s corporate major accident prevention policy, where the operator is required to have one.
Schedule 7(3)A copy of the owner’s corporate major accident prevention policy, where the operator is required to have one.
Assessment Criteria/ Minimum Information / SC Ref / Criteria met / Not Met – Assessment Comments
Does the Safety Case include a copy of the operator’s (production) or owner’s (NPI) CMAPP?
b) SCR2015 Regulation 7(3) & Schedule 1– Particularsto be addressed in a Corporate Major Accident Prevention Policy
SCR2015 Regulatory Requirement / Clarification / NAIRegulation 7(3)The corporate major accident prevention policy must address at least the particulars set out in Schedule 1 and must be prepared in accordance with the matters set out Schedule 2.
Schedule 1(8)Measures for maintenance of safety and environmental protection standards as an organisational core value.
Assessment Criteria / Minimum Information / SC Ref / Criteria met / Not Met – Assessment Comments
Does the CMAPP include a paragraph to describe measures for maintenance of safety and environmental protection standards as an organisational core value?
The CMAPP should demonstrate that the role of safety and environmental protection standards, in maintaining management and control of major accident hazards, is recognised and fully understood by the management board. The CMAPP may make the link with the appropriate elements of the SEMS, and other hardware and management arrangements which support and maintain these standards, to ensure this core value is reflected throughout the organisation.
2. [SEMS]Requirements
a) SCR2015 Schedule 6/7– Particulars to be addressed in a Safety Case
SCR2015 Regulatory Requirement / Clarification / NAISchedule 6(5)An adequate description of the operator’s safety and environmental management system, including information from it that is relevant to the production installation.
Schedule 7(5) An adequate description of the owner’s safety and environmental management system, including information from it that is relevant to the non-production installation.
Schedule 3(3)Integration of environmental impact into major accident risk assessments in the safety case.
Schedule 3(6) Limitation of damage to the environment.
Assessment Criteria / Minimum Information / SC Ref / Criteria met / Not Met – Assessment Comments
Does the Safety Case description of the Safety and Environmental Management System (SEMS)include details of how the potential for environmental impact has been fully integrated into the major accident risk assessment process?
An adequate description of the SEMS should include details on how the SEMS processes will ensure the potential for environmental impact has been fully integrated into the major accident risk assessment process and how the identified risks to the environment will be reduced to as low as reasonably practicable.
For NPIs, the description should include the arrangements for managing changes in operating location with well operators.
3. [Management and Control of Major Accident Hazards] Requirements
a) SCR2015 Regulation 16/17/18, Schedule 6 / 7– Particulars to be addressed in a Safety Case
SCR2015 Regulatory Requirement / Clarification / NAIRegulation 16 (1) A duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraph (2), include in the safety case sufficient particulars to demonstrate that—
(d) all major accident risks have been evaluated, their likelihood and consequences assessed, including any environmental, meteorological and seabed limitations on safe operations, and that suitable measures, including the selection and deployment of associated safety and environmental-critical elements have been, or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with
Regulation 17(1) Subject to Schedule 14, the operator of a production installation must ensure that it is not operated in external waters unless—
(a) the operator has prepared a safety case containing the particulars specified in regulation 16 and Schedule 6
Regulation 18(1) Subject to Schedule 14, the owner of a non-production installation must ensure that it is not moved in external waters with a view to its being operated there unless—
(a) the owner has prepared a safety case containing the particulars specified in regulation 16 and Schedule 7
Schedule 6 (13)Particulars of the plant and arrangements for—
(e) the protection of the environment from a major accident
Schedule 7 (12)Particulars of the plant and arrangements for the control of —
(e) the protection of the environment from a major accident
Assessment Criteria / Minimum Information / SC Ref / Criteria met / Not Met – Assessment Comments
Does the Safety Case includesufficient evidence to demonstrate that:
- theenvironment has been considered as part of the evaluation of major accident risks and that their likelihood and consequenceshave been assessed;andthat
- suitable measures,including the selection and deployment of associated safety and environmental-critical elements have been, or will be, taken to control thoserisks?
4. [OPEP] Requirements
a)SCR2015 Regulation16(4),Schedule 6/ 7– Particulars to be addressed in a Safety Case
SCR2015 Regulatory Requirement / Clarification / NAIRegulation 16(4) The Demonstration of the matters referenced by Regulation 16 (1)(d) (see Management and Control of Major Accident Hazards section above) must include the estimate of oil spill response effectiveness contained in the OPEP in respect of the installation, prepared pursuant to regulation 4(3)(a) and (c) of and Schedule 2 to the Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention Regulations 1998
Schedule 6(Particulars to be included in a safety case for a production installation)
21. The description of the internal emergency response arrangements.
22. The assessment produced pursuant to paragraph 2(j) (currently incorrectly referenced as paragraph 2(8) – will be amended) of Schedule 2 to the Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998.
Schedule 7 (Particulars to be included in a safety case for a non-production installation)
17. The description of the internal emergency response arrangements.
18. The assessment produced pursuant to paragraph 2(8) (currently incorrectly referenced as paragraph 2(8) – will be amended)of Schedule 2 to the MerchantShipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998.
Assessment Criteria / Minimum Information / SC Ref / Criteria met / Not Met – Assessment Comments
Regulation 16(4)
Does the demonstration made pursuant to Regulation 16(1)(d) include the assessment of oil spill response effectiveness?
OSDR recognises that the estimate of oil spill response effectiveness is only relevant during oil and gas operations thus operators and owners can satisfy this requirement by:
1. The inclusion of a link to the oil spill response effectiveness register prepared by OGUK in the safety case with a description of the applicability of the register; or
2. The inclusion of a section in the safety case to explain:
- How OGUK have prepared a document which estimates oil spill response effectiveness for all areas of the UKCS;
- How the OGUK document details the response effectiveness in relation to different oil types for the entire UKCS by region (for a NPI) or how the OGUK document details the response effectiveness for the known oil type/region (for a Production Installation); and
- How the OGUK document may be utilised relevant to operations on the installation (such as when making a decision on whether an oil spill response technique could be used in a particular location); or
The actual assessment produced need not be included in a safety case for the case to be accepted
Schedule 6(21) & 7(17)
Does the safety case contain a description of the oil pollution emergency plan (OPEP) arrangements for the installation?
This description should cover;
a) the internal response arrangements governing oil pollution response (outlining who is responsible for all levels of the tiered response to any oil pollution incidentand a summary of how the notification and reporting process will occur); and
b)the OPEP interface arrangements (including the arrangements for combined operations, well operations, external response organisations and the interface arrangements between any separate OPEPs for other installations/subsea tie backs that are in the scope of the safety case)
Schedule 6(22) & 7(18)
Does the safety case include a statement to confirm that the assessment of the identified potential environmental effects resulting from a release of oil and a description of the technical and non-technical measures envisaged to prevent, reduce or offset them, including monitoring is included in theOPEP for the installation?
b) SCR2015 Regulation 17(4)(c)
SCR2015 Regulatory Requirement / Clarification / NAIRegulation 17
(4) Where, pursuant to paragraph (2), a safety case is to be prepared in relation to more than one production installation, each with a different operator, there must be included with the safety case -
(c) the description of the internal emergency response arrangements of each operator
Assessment Criteria / Minimum Information / SC Ref / Criteria met / Not Met – Assessment Comments
Regulation 17(4)(c)
Where a safety case is prepared in relation to more than one production installation each with a different operator, the safety case must include a description of the oil spill response arrangements for each operator.
DECC may assess other aspects of safety case submissions in conjunction with relevant HSE topic specialists, e.g.:
•Verification requirements(Regulation 17(3) / 18(2));
•Arrangements for the maintenance of control systems to prevent damage to the installation and the environment in the event that all personnel are evacuated (Schedule 6 (20));
•Arrangements to maintain control systems for preventing an MEI (Schedule 8(6)(c)).
The scope of such assessments will be agreed in liaison with the HSE.
Owners/Operators should ensure protection of the environment is considered for such aspects.
Safety case EnvironmentalOPERATIONAL CONTROL Requirements - Assessment Summary
NAI – Non Acceptance Issue
Regulatory Requirement / ClarificationRequired / NAI Required / Conclusion
1. CMAPP Requirements (SCR2015)
a)Schedule 6(3) / 7(3) – Particulars to be included in a Safety Case
b)Regulation 7(3) & Schedule 1 – Particulars to be addressed in a Corporate Major Accident Prevention Policy
2). SEMS Requirements (SCR2015)
a)Schedule 6/7 – Particulars to be addressed in a Safety and Environmental Management System
3. Management and Control of Major Accident Hazards (SCR2015)
a)Regulation 16 / 17 / 18
4. OPEP (SCR2015)
a)Regulation 16 (4),Schedule 6/7, Schedule 6(22) & 7(18)
b)Regulation 17 (4)(c)
Environmental Operational Control Assessment Template – Revised Nov 2015