1. The safety case regulations require the duty holder to carry out a thorough review of a safety case at least once every five years, and to send HSE a summary of the review. HSE does not accept or approve the summary, but inspects it to check whether the Regulation 13 requirements of SCR05 have been fulfiled. HSE then uses the conclusions from the review and the inspection, along with other sources of intelligence, to inform interventions.
2. The purpose of a thorough review is to provide a duty holder check that the safety case (which exists for the lifetime of the installation) continues to be fundamentally sound. HSE's inspection of the thorough review summary is not to confirm that the duty holder has made a case for safety for another five years. Nor is it to address HSE's current inspection concerns, as these may distort the duty holder's objectives in carrying out the review. Any such concerns should be dealt with by normal intervention methods.
3. This procedure describes how compliance with the review requirement is regulated by HSE. It is in three stages:
4. Stages (i) and (ii) are carried out at intervals of at least once every five years. Stage (iii) is undertaken for each initial thorough review submitted and subsequent submissions.
5. Operations Notice 74 gives guidance to duty holders on submitting thorough review summaries. Proformas are used to acknowledge receipt of the summary and for IMT reports. TRIM folder 1.9.3.337 contains standard forms and letters, which should always be used for these actions. Completed forms and letters are recorded on COIN. The safety case plan is used to keep track of summary due dates and progress.
6. All work with thorough reviews is chargeable inspection. The performance standard is for all work with respect to the adequacy of the review to be completed within twelve weeks of receipt of the summary.
7. Whilst carrying out a review, a duty holder may conclude that a safety case revision is required. If this constitutes a material change, the revised case is submitted under regulation 14(2) and assessed in the normal manner.
8. Alternatively, a review may result in safety case revisions that are not material changes and do not require assessment. The revised case may however contain information that would affect HSE's inspection plans. IMTs should consider if they need to see the revised case.
The objectives are:
9. This stage is carried out typically twelve months before the first thorough review is received from the duty holder. It is repeated at least every five years, or as required, to ensure that the procedure remains consistent with current guidance and with any changes in the duty holder's management arrangements.
10. Obtain a copy of the duty holder's thorough review procedure and inspect it using the guidance in Annex 1, in booklet L30 paras.187-195, and in Offshore Information sheet 4/2006. Check in particular that full account has been taken of legal requirements, and that all relevant major hazards and technical topics are covered.
11. Consult appropriate topic teams as required for a view on whether, for their particular topic, the procedure indicates that the duty holder has a good understanding of what is needed, and has an adequate process for undertaking thorough reviews.
12. Visit the duty holder's head office to discuss the findings and agree any improvements required. Confirm by letter any significant deficiencies in the duty holder's arrangements for undertaking a review.
13. Complete a report of the inspection and of any topics raised, using template TRS1, and attach the report, the procedure and any letter to an appropriate duty holder COIN case.
14. If consulted by an IMT over the duty holder's procedure consider whether, for the particular topic, it indicates that the duty holder has a good understanding of what is required, and has an adequate process for undertaking thorough reviews. Respond via email to the IMT inspector with any issues within the timescale requested.
15. Approve the COIN record.
The objectives are:
16. This stage is an inspection of the duty holder's thorough review process in its entirety, not just an inspection of the summary. This more detailed inspection is to be undertaken for one installation per duty holder at least every 5 years.
17. It is a periodic exercise for each duty holder. In many cases it will be done after, or during the first thorough review. However, to ensure that the duty holder is maintaining an effective and up-to-date thorough review process, an inspection of this type is carried out at least once every five years. This frequency may be increased (but not decreased) depending on HSE's level of confidence in the duty holder's ability to carry out adequate thorough reviews. This may include how well the duty holder appears to be responding to changes in health and safety standards, guidance or new knowledge or technology.
18. If the duty holder operates different types of installations which present significantly different hazard profiles (for example floating and fixed installations) then this stage may need to be carried out for each type of installation. This is at the judgement and discretion of the IMT and is based on their confidence in the duty holder's thorough review process and procedures.
19. There may be occasions where OSD wishes to test the thoroughness of a review while it is in progress. The relevant Topic Specialist and IMT should agree a protocol for their intervention. Care should be taken by Inspectors not to participate in the review itself. Where this type of intervention takes place, Inspectors are to complete a report of the inspection using template TRS2, and attach it along with any letter to the appropriate duty holder COIN case.
20. Obtain copies of the duty holder's current thorough review procedure, implementation plans, and review summary. Acknowledge the summary using template TRS3.
21. Inspect the implementation plans and deliverables, including the review summary for evidence that the duty holder's procedure and HSE's guidance has been followed. Consider if the review has been sufficiently thorough, looking in particular at scope, resources and independence. Inspection of additional review documentation will be required.
22. Consult relevant topic teams for a view on whether, for their particular topic, the review is rigorous and appropriate. Include the COIN number for the relevant inspection case for the installation, to facilitate recording issues.
23. Consider whether, for the particular topic, the procedure, implementation plans and summary are rigorous and appropriate. Inspection is required of technical aspects detailed in documents, studies, minutes of meetings etc. produced by the duty holder while undertaking the review. This will primarily involve onshore inspection but may also involve offshore inspection.
24. Respond to the IMT inspector with any issues, using parts A and B of template TRS4 and identifying any topics of high priority. This is done within ten weeks of receipt of the summary by HSE. Record these as COIN issues against the relevant inspection case for the installation.
25. GASCET and topic teams' own guidance should be used, in addition to that in para.10. Topic teams/Units may wish to use their own issue numbering system, as COIN issue numbers are not unique.
26. Decide, on the basis of the above inspection activity, if the duty holder needs to amend their procedure. If so, write to the duty holder. Collate any inspection topics and update the intervention plan accordingly.
27. If there are significant concerns about the thoroughness of the review, its content, and outcome consider directing a further review or revision.
28. Complete a record of the intervention, using template TRS5 and attach it to the appropriate COIN case.
29. Approve the COIN record.
The objectives are to:
30. Acknowledge receipt of the summary using template TRS3.
31. Send a copy of the summary via email to all relevant topic teams asking them to inspect the summary. Include the COIN number for the relevant inspection case for the installation.
32. Inspect the thorough review summary. Consider if the review has been sufficiently thorough.
33. The depth of inspection should be informed by the results of previous inspections of the duty holder's procedure, sample implementation plans and summaries. As a minimum, the summary should contain the relevant information in paras.193 and 194 of booklet L30, and confirmation of safety representative consultation.
34. If the evidence of a thorough review is insufficient, discuss the deficiencies with the duty holder and consider if a Direction under SCR05 Reg 13(1) is appropriate.
35. Consider the summary and identify any topics for future intervention. Advise the inspection team accordingly using part A of template TRS4 and identifying any topics of high priority. This is done within ten weeks of receipt of the summary by HSE. Record these as COIN issues against the relevant inspection case for the installation.
36. If a Topic Inspector has significant concerns about the thoroughness of the review they may inspect the technical aspects detailed in documents, studies, minutes of meetings etc. produced by the duty holder while undertaking the review. Any significant issues are recorded using part B of template TRS4.
37. Topic inspectors do not make COIN service order entries for this activity.
38. Collate any inspection topics and update the intervention plan accordingly. Less urgent matters can await discussion at the next annual planning event.
39. Topics for intervention may include checking that any recommendations from the review, such as hardware or management changes, or updates to the safety case, have been implemented. Topics may be held over for consideration at the next duty holder planning event. Where the duty holder has a number of similar small installations, intervention plans may be updated as a group.
40. Complete a record of the inspection using template TRS5 and attach it to the appropriate COIN case. This is to be done within twelve weeks of receipt of the summary by HSE.
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