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SCE management and verification inspection expectations

SPC/ENFORCEMENT/183

Content

Purpose

To set out the new expectations for SCE Management and Verification.

Background

SCE management and verification throughout an installation’s lifecycle is critical to preventing low frequency high consequence catastrophic events. Given the nature of the division (OSD), a major hazard division, it needs to be an integral part of what we do.

Following completion of the Verification Inspection Project the DMM have endorsed the following strategy:

The importance of these areas in our regulatory regime has been further highlighted following the Macondo Well blowout and other events.

Thus in order to ensure greater embedment throughout the division, the DMT requested the production of this SPC to help clarify roles and responsibilities for inspection management teams (IMT), topic specialists (TS) and operations managers. It is recognised that many inspectors already carry out work in these areas with the main aim being to improve consistency.

Expectations for inspection management team (IMT) inspectors

SCE management expectations:

  1. Inspect management processes both onshore and offshore. Undertake dedicated inspection every 2-3 years for each installation / duty holder / business unit. Ensure the installation intervention plans address SCE management and their suitability;
  2. Ensure during the assessment of safety cases, inspection of thorough reviews etc. that SCE management is adequately addressed (see checklist TRIM reference 2011/64418);
  3. For investigations, inspections, queries relating to SCEs use the lead topic team as given in the SCE matrix (TRIM reference 2010/357419 HID OSD Safety Critical elements (SCE) Matrix) to ensure state of an SCE is adequately covered;
  4. Sample the risk assessments associated with deferred safety critical maintenance and degraded SCEs;
  5. Routinely examine duty holder’s leading and lagging SCE KPIs;
  6. Witness, and require, sample specified plant and, or SCE testing during inspections (for example deluge drops).

Verification expectations:

  1. Installation intervention plan addresses inspection of verification management arrangements. Prior to the planning meeting obtain and circulate to the relevant TSs the ICP’s open findings and comments, letters of concern and reservation. Follow up open findings etc. that meet the Oil and Gas reporting criteria. Use this information to plan offshore;
  2. Ensure during the assessment of safety cases, inspection of thorough reviews etc. that verification is adequately addressed (see checklist TRIM reference 2011/64390);
  3. Hold annual meetings with the ICP by duty holder (possibly alone);
  4. Ensure that the ICP attends the duty holder’s annual review;
  5. Prior to offshore inspections obtain and circulate to the relevant TSs the ICP’s latest reports and a list open findings and comments, anomalies, letters of concern and reservation. Use this information to plan offshore intervention and change TS if important issue arise;
  6. Request that SCE lead TSs follow up open ICP findings etc. that meet the Oil and Gas UK reporting criteria, namely that have not been closed in a timely fashion: and
  7. Sample offshore risk assessments associated with ICP’s findings.

Expectations for topic specialists (TS) inspectors

SCE management expectations:

  1. Act as focal point within OSD for assigned SCE(s) and seek assistance from other TSs with respect to issues concerning the assigned SCE(s) (TRIM reference 2010/357419 HID OSD Safety Critical elements (SCE) Matrix);
  2. Incorporate SCE inspection strategies, where you are the lead, within your topic strategies. Do it in consultation with other TSs;
  3. Assess the suitability of performance standards including measurable criteria and the associated assurance routines and;
  4. Witness SCE testing during inspections.

Verification expectations:

  1. Prior to offshore inspections obtain the ICP’s latest reports and a list of open findings, anomalies, letters of concern and reservation from the IMT. Use this information to assist in the planning of the offshore intervention;
  2. Follow up open ICP findings etc. that meet the Oil and Gas UK reporting criteria and monitor substantive unresolved issues;
  3. Examine ICP verification activities to ensure they are appropriate to determining the suitability of SCEs; and
  4. Examine offshore sample risk assessments associated with ICP’s findings.

Expectations for the SCE lead topic specialist / team

  1. Develop and implement a strategy for inspecting their SCE in consultation with other associated TSs;
  2. Lead in consultation with associate TSs OSD’s response to issues with their SCE arising from inspections (i.e. provide a one-stop shop for queries relating to their SCE): and
  3. Consider annual meetings with their ICP counterparts to discus their SCE(s).

Expectation for the Verification and Design team

SCE management expectations:

  1. Act as focal point to collect and then share good and best practice;
  2. Provide coaching / mentoring / advice as required;
  3. Assist in the allocation of SCEs to topic specialists and the development and management of a set of internal KPIs relating to SCE and verification management;
  4. Provide an annual status report

Verification expectations:

  1. Act as OSD’s focal point on verification;
  2. Provide advice to IMTs and TSs as required and identify both generic issues and best practice;
  3. Participate in inspections as required;
  4. Provide an annual status report.

SCE management and verification expectations for operations managers

  1. Provide leadership in the areas of SCE management and verification;
  2. Encourage the use of the SCE allocation matrix;
  3. Promote the increasing focus on SCE management and verification;
  4. Review SCE management and verification annual status report and act on its findings.

Further information

Please contact the Verification and Design team on 01603 828030 or 07946 722 874 for further advice.

Appendix: Definitions

Updated 2012-11-03