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Effective implementation of offshore verification requirements

Offshore Information Sheet No. 1/2012

(Issued August 2012)

Contents

Introduction

This sheet provides examples from HSE’s inspection experience of how onshore management can effectively implement the regulatory requirements for independent verification in the offshore oil and gas industry.

Background

Regulations 19-21 of the Offshore Installations (Safety Case) Regulations 2005 require operators to appoint an independent and competent person (ICP) to verify that safety-critical elements (SCEs), which provide major hazard risk control, and certain specified plant, such as emergency equipment, are suitable and will remain so.

The operator and ICP must agree a written examination scheme. The operator must act upon the findings of the ICP’s examinations (regarding any problems with the initial suitability and the continuing suitability of SCEs) and record the outcome of these actions. This is a central part of the UK offshore safety regime, and a crucial part of the management of asset integrity.

Although the legal requirements are goal setting, experience from HSE’s offshore intervention activities, especially a series of focused inspections on verification across the industry during 2007-10, has identified a number of key factors that characterise effective verification arrangements.

This information sheet provides a mechanism for capturing and sharing this good practice across the industry, and dutyholders can carry out a gap analysis to compare their existing approaches with it. The information sheet complements guidance  in the verification sections of the regulatory guidance, L30.

Good practice for effective verification

High-level examples of good practice collated to date are set out below under a number of general headings.

Leadership

Verification is a key mechanism for senior managers to obtain independent assurance of the performance of their safety-critical equipment. Their active ownership and involvement in the verification process is crucial. Commitment to the process can be demonstrated by:

Planning

Effective planning by establishing and maintaining a comprehensive verification scheme is a prerequisite to effective verification. This work includes:

Considerable benefits can be achieved by integrating ICP verification activities into those of the dutyholder:

Dutyholder implementation of ICP activity

The verification process applies throughout the asset life cycle. It needs to consider ongoing modification to SCEs as well as the effects of maintenance backlogs, inhibits, deferrals etc. Effective verification systems have been shown to operate where dutyholders:

Monitoring and auditing of the scheme by the dutyholder

Senior management monitoring and auditing of the delivery of the verification scheme activity is essential to ensure the timely and satisfactory completion of verification. Examples of such activities are:

Specific considerations

Give further consideration to designing and implementing the verification arrangements for the following specific situations:

Offshore Installations (Safety Case) Regulations 2005

Further information

Contact:

Updated 2012-07-13