This document provides guidance on the diving topic assessment of safety cases, including a background to diving as a major hazard, and the approach to the diving topic assessment. It also includes the diving topic assessment record pro-forma.
This document is provided to assist diving specialists carrying out safety case assessment and is a supplement to the guidance provided by Assessment Principles Offshore Safety Cases (APOSC), and the Safety Case Handling And Assessment Manual (SCHAM). It will assist in providing a common approach to the assessment of the diving elements of safety cases by providing a topic assessment record pro-forma.
Guidance to be used for safety case assessment by diving topic specialists
Diving operations and equipment can affect the safety of an installation by causing or contributing to a major accident as defined in the Offshore Installations (Safety Case) Regulations 2005 (SCR). The defined major accidents include (amongst others): the failure of life support systems for diving operations in connection with the installation; and collision of diving support vessels (DSV) with the installation.
All safety cases should consider the potential for diving operations from the installation, as a connected activity, or both. If diving is specifically excluded then the duty holder would be required to submit material change to the safety case should diving need to take place.
The diving topic assessment will consider the effectiveness of the duty holder’s safety management system (SMS) in relation to diving.
SCR Regulation 12 requires that the duty holder's management system is adequate to ensure that the relevant statutory provisions are complied with, that all hazards with the potential to cause a major accident have been identified and the risks assessed, and that measures have been or will be taken to control those risks. This would include diving activities undertaken in connection with the installation as well as the specific major accident hazards related to the dive system.
The diving topic assessment will also consider the effectiveness of the duty holder’s control and management of diving contractors.
The information to be assessed must all be contained within the safety case. Merely referring to other documents that are intended to be an integral part of the case for safety is not acceptable. There should be sufficient information within the safety case itself to provide satisfactory answers to the questions in the topic assessment record (TAR) contained within this SPC.
Additional supporting material may be referenced within the safety case, and the diving topic specialist may wish to see that documentation to establish that it exists.
Any issues identified within the additional documents should not be raised as part of the Safety Case assessment process, but will form a separate inspection topic.
Safety case major accident identification and risk assessment: A key part of a safety case is a demonstration that all hazards with the potential to cause a major accident have been identified. If diving is identified as an activity within the safety case then the safety case should discuss how risks related to diving have been evaluated, and what measures will be taken to control those risks.
Danger to the installation from the diving system: Diving systems (both permanent and temporary) that are mounted on an offshore installation should be assessed for inclusion in the verification schemes for the installation. Additionally, the relevant Independent Competent Person (ICP) should be informed that the diving system is being brought onto the installation because these systems include items of plant and equipment that could cause or contribute substantially to a major accident. The process for ensuring this should be included in the safety case.
Evacuation of divers whilst diving from an installation: There should be suitable arrangements for all persons to leave the installation in the event of an emergency. Divers that are deployed directly from the installation are placed at greater risk than the average person on the installation because the time to recover the diver from the worksite can be significant. If the potential for installation based diving operations is identified in the safety case, the performance standard for evacuation and escape should consider divers.
Risk to the installation from a diving support vessel (DSV): Collision is a foreseeable risk which may have major consequences. Duty holders should include an overview of the management of DSVs within their safety case submission. The overview should explain the way in which vessels that will work as a connected activity will be audited to recognised standards and to best industry practice.
Evacuation of divers from a DSV: The duty holder may be required to provide assistance to the diving contractor in co-ordinating an emergency response to an incident involving a DSV. Depending on the operational circumstances this emergency response may take various forms. There will need to be a detailed and specific supporting document produced prior to diving commencing, however a simple statement of intent by the duty holder will generally be acceptable in the safety case.
The attached Topic Assessment Record (TAR) should be used to record the assessment process and identify any matters raised with the duty holder. Once suitable responses have been received from the duty holder these should be recorded on the TAR and the completed document should be attached to the COIN record for the safety case.
Assessment Principles Offshore Safety Cases (APOSC)
The Safety Case Handling And Assessment Manual (SCHAM)
A guide to the Offshore Installations (Safety Case) Regulations 2005