Case Title - [Safety Case Title] / COIN Numbers - [Case] / [SVC Number]
Duty Holder – [Company Name] / Topic Assessor – [Name]
OccUPATIONAL HEALTH ASSESSMENT TEMPLATE
Work Instructions
The Offshore Installations (Offshore Safety Directive)( Safety Case) Regulations 2015 (SCR2015) require that duty holders wanting to operate in relevant waters must prepare, and have accepted, a safety case containing the particulars identified in those regulations. To accept a safety case the competent authority must first satisfy itself that the safety case contains the required information. A series of templates have been developed to be used by each topic discipline involved in safety case assessment to record their assessment of a safety case against legal requirements.
This template will be available to inspectors to record their assessment of the ‘Installation’ Safety Case, with respect to the management of Occupational Health risks and provision of welfare facilities contained in a Safety Case submitted under SCR2015. It will be used when assessing new safety case submissions and those submissions covering material change in these areas, including dismantlement cases. This template will also be used to inform the inspection of a Design or Relocation Notification. This template identifies the specific regulations contained within SCR2015 that relate to these topics and identifies what the competent authority expects to find within a safety case to meet those requirements. The document is drafted to complement the guidance being produced to support the regulations as well as existing topic sector guidance. Together with the similar templates completed by the other topic disciplines these will form the complete record of the assessment process undertaken by the competent authority. It is proposed to make these templates freely available to promote transparency and assist industry in drafting its submissions.
Where the template is used to aid the inspection of a Design or Relocation Notification the inspector needs to consider the submission containing the information that has been provided to comply with regulation 6 and Schedule 1 of the regulations, it does not require an inspector to assess the content against the full requirements of a safety case, however, in completing their inspection they must identify any potential Non Acceptance Issues to draw to the attention of the duty holder so reference to the full requirements may be useful.
Of particular significance to this document is the understanding of the following terms:
Non Acceptance Issue
A Non Acceptance Issue (NAI) is a deficiency in the demonstration made for health, safety and environment within the safety case, which, if not resolved, will prevent the case from being accepted under the relevant statutory provisions.
Non Acceptance Issues require formal communication with the operator to ensure they are dealt with in the appropriate manner giving them every chance to address the deficiency. The Operator will be given 14 calendar days to respond.
Clarification
A Clarification is an explanation provided to an inspector, by an operator, to allow them to be confident of their interpretation of the demonstration provided within the safety case.
Clarifications are carried out as part of the routine of assessment work and should be raised with the operator swiftly and informally and by direct means of communication (by telephone / email) and would normally expect a prompt response.
In complex cases the requirement for clarification can be pre-empted by setting up a meeting between the operator and relevant topic specialists to facilitate discussion and understanding between the 2 parties before the case is submitted or in the very early stages of the assessment.
Where any uncertainty relates to an area that has the potential to lead to a Non-Acceptance Issue a request for ‘Clarification’ would not be appropriate and the issue should be identified as a Non-Acceptance Issue and raised immediately in the appropriate fashion.
Relevant Pre-Existing Guidance
· APOSC Principles:
Factual Information
Ø Principle 1
The factual information should meet the SCR15 requirements and provide sufficient details to support the arguments made in the case.
Management of health and safety
Ø Principle 2
The safety case should demonstrate that the management system is adequate to ensure compliance with the relevant statutory provisions.
Ø Principle 3
The management system should show an appropriate level of control during each phase of the installation life cycle, including design, construction, commissioning, operation, decommissioning and dismantlement.
· GASCET Chapter:
Ø 2.2.4 Occupational health
.
· Relevant Statutory Provisions and Guidance covering Occupational Health Risks:
Ø Offshore Installations (Safety Case) Regulations 2005 (specifically Regulation 12), (L30).
Ø Management of Health and Safety at Work Regulations 1999.
Ø Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995 (specifically Regulations 17 & 18), (L70).
Ø The Offshore Installations and Wells (Design and Construction etc) Regulations 1996 (specifically Regulation 12, Schedule 1), (L85).
Ø The Offshore Installations and Pipeline Works (First-Aid) Regulations 1989, (L123)
Ø Control of Noise at Work Regulations 2005, (L108).
Ø Control of Vibration at work Regulations 2005, (L140).
Ø Control of Ionising Radiations1999, (L121).
Ø Control of Asbestos Regulations 2006, (L143).
Ø Control of Substances Hazardous to Health Regulations 2002 (as amended) (L5).
Ø Control of Lead at Work Regulations, (L132).
Ø Manual Handling Operations Regulations 1992 (as amended), (L23).
Ø Environmental Health Guidelines, Oil and Gas UK.
Ø Legionnaires’ disease: Technical guidance HSG 274 Parts 1, 2 and 3.
1. Management System Requirements
SCR2015 requires a Safety Case to demonstrate that the duty holder’s management systems are adequate to ensure compliance with the relevant statutory provisions and that there are satisfactory arrangements for the management of contractors.
It is important to note that the required demonstration of the adequacy of the management system is not restricted to the management of major hazards. It should consider the adequacy of the risks as a whole including the Occupational Health topics of physical/chemical/microbiological risks, requirements for emergency First-Aid and basic health care and the provision of welfare facilities.
SCR2015 Regulatory Requirement / Clarification / NAISCR2015 Regulation 16 Management of health and safety and control of major accident hazards
(1) 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—
(a) the duty holder’s management system is adequate to ensure—
(i) that the relevant statutory provisions will, in respect of matters within the duty holder’s control, be complied with; and
(ii) that the management of arrangements with contractors and sub-contractors is satisfactory;
(b) the duty holder has established adequate arrangements for audit and for the making of reports of the audit;
Assessment Criteria / Minimum Information / SC Ref / Criteria Met / Not Met - Assessment Comments
Physical, Chemical and Microbiological Risks
1. Does the Safety case demonstrate that the management of health issues is integrated into the installation’s Safety Management System?
2. Are there arrangements for the identification, evaluation and control of risks arising from:-
a) Chemical hazards
b) Physical hazards ie noise, vibration, radiation
c) Biological hazards ie legionella, food hygiene
d) Ergonomic hazards ie manual handling
e) Thermal environments
f) Asbestos (if relevant)
First-Aid and Basic Health Care
3. Are there adequate arrangements for the provision of emergency first-aid and basic health care in terms of facilities, equipment, medications and suitable persons?
Welfare
4. Are there sufficient changing rooms, rest rooms, recreational and catering facilities to cope with the maximum number of persons-on-board the installation?
5. Are there suitable and sufficient sleeping cabins to accommodate the maximum number of persons-on-board the installation?
6. Are adequate arrangements to ensure the well-being and comfort of people in accommodation areas in terms of ventilation, lighting and noise?
Designing, Decommissioning and Dismantling
7. Is there a process for the identification, evaluation and control of occupational health risks in the Designing, Decommissioning and dismantling of the offshore installation
[Topic] Requirements - Assessment Summary
NAI – Non Acceptance Issue
SCR 2015 Regulatory Requirement / ClarificationRequired / NAI Required / Conclusion
1. [Sub-Topic] Requirements
a)
b)
c)
2. [Sub-Topic] Requirements
a)
b)
c)
3. [Sub-Topic] Requirements
[Other] Regulatory Requirement / Clarification
Required / NAI Required / Conclusion
4. [Sub-Topic] Requirements
5. [Sub-Topic] Requirements
TRIM: 2016/78457 Revised:26/07/17 2017 Page 2 of 6
Owner: ED3.6 Offshore Occupational Health Team