Performance standards for safety critical elements

SPC/ENFORCEMENT/42

Version No:

1

OG Status:

Fully Open

Subject File:

261

Author Section:

OSD 5.3

Issue Date:

1 November 2002

Review Date

1 April 2010

To

All OSD Inspectors (Bands 0-3)

Purpose

To provide Inspectors with the means by which to assess whether an appropriate verification scheme has been prepared, in accordance with the Offshore Installations (Safety Case) Regulations 2005 (SCR05) r.19, ensuring that all Safety Critical Elements (SCEs) are suitable and remain in good repair and condition. This guidance supplements the existing interpretative and other guidance.

Action

Inspectors should follow this guidance when inspecting verification schemes.

Background

SCR r.19 obliges a duty holder to ensure that a verification scheme is drawn up. By regulation 2(5), such schemes must ensure that SCEs:

Are, or will be suitable, and remain in good repair and condition; failure to do so is a criminal offence.

Appropriate performance standards should be set in respect of the obligations owed by each duty holder in respect of SCEs, not least the duty to ensure that each SCE is suitable and remains in good repair and condition. The duty holder's verification scheme provides an additional check on the performance standards required of each SCE by putting arrangements in place, in accordance with SCR r.2(6) (and, by sub-paragraph (e), 19(2)(b) and Schedule 7), to see that each SCE is suitable and is maintained; schemes must also ensure that those performance standards are monitored on an ongoing basis as often as is appropriate by both the duty holder and an independent and competent person. Suitability and good repair and condition are ensured in part by the keeping of records in accordance with paragraph 5 of Schedule 7 to the SCRs.

In addition to what is suitable for the purposes of a verification scheme under the SCRs, 'work equipment' (which can include SCEs) must be constructed or adapted so as to be fit for its purpose in accordance with regulation 4 of PUWER; in addition, regulation 5 of PUWER requires that work equipment is maintained in an efficient state, in efficient working order and in good repair.

Non-compliance could mean that the SCEs do not meet the required standards of performance that have been assumed in the safety case and consequently greater risks are likely to persons from major accident hazards.

NB. This SPC only concerns potential breaches of the SCR verification requirements. Failure to ensure that work equipment (which is not also an SCE) is suitable should be dealt with under the appropriate primary regulations (eg PFEER, DCR, PUWER etc.)

Enforcement action

In determining the level of enforcement action to take in individual cases, Inspectors should be guided by the OSD Intervention Guide. Reference should also be made to the Enforcement Management Model.

In cases where insufficient effort has been made to comply with the above requirements and it is thought that a significant breach of regulations has occurred and is ongoing, an improvement notice is likely to be the most appropriate response.

Examples

Examples of typical failings include lack of linkage between the risk assessment assumptions of the safety case and the standards of performance of relevant elements. These can include lack of information regarding fire and gas detection limits, reliability of blowdown systems, reliability of Temporary Refuge (TR) protection systems etc.

Further information

Further information and advice regarding the likely significance of particular omissions can be obtained from OSD 5.3 (VPN 522 6849).

Further information and guidance can be found in SPC/Enforcement/158, and A guide to the Offshore Installations (Safety Case) Regulations 2005 (L30) para 97