1. This notice provides updated guidance on the provision of accommodation on offshore installations, as required by regulation 12 and Schedule 1 of the Offshore Installations and Wells (Design and Construction, etc) Regulations 1996 (DCR)1 and replaces ON62, which is now withdrawn.
2. It clarifies the standards used to define the terms “sufficient beds”, “overcrowded”, “adequate space”, “reasonable privacy” and “comfort” referred to in Schedule 1, paragraphs 60 and 61. Guidance2 is provided on the meaning of “so far as is reasonably practicable” (paragraph 61(c)) and how HSE approaches the enforcement of these regulations.
3. DCR regulation 12(1) and Schedule 1 paragraphs 59-66 contain requirements for accommodation standards offshore. Regulation 12(3) made provision for a transition period for installations commissioned before DCR came into effect (30th June 1996). This period ended on 3rd November 1999. DCR regulation 12 and Schedule 1 requires all installations operating after this date to be compliant.
4. The DCR requirements are based on the principles of adequate space, privacy and comfort. This guidance takes into account the time which has elapsed since compliance with DCR was required.
5. Schedule 1 paragraph 60 requires there to be sufficient beds or bunks for the number of people expected to sleep on the installation, ie there must be a bed or bunk for everyone at all times. This includes personnel visiting normally unattended installations (NUIs) unless there is no possibility of them needing to sleep on the installation. See Annex 1 for further information concerning NUIs.
6. The requirement for sufficient beds means that HSE will consider formal enforcement action if there is evidence of ‘hot bunking’. A mattress on its own, made up appropriately with bedclothes, does not constitute a bed or bunk. Changing the mattress and/or bedding to allow two people to share a bed or bunk also constitutes 'hot bunking'.
7. Sleeping accommodation needs to take into account temporary increases in POB such as those that occur during planned shutdown, maintenance and drilling campaigns, or major modification work. Additional temporary beds in the accommodation to cope with staffing peaks are unlikely to meet the guidance for reasonable privacy and comfort. The design of new installations should carefully consider these foreseeable increases in staffing levels. Where this has not been the case planning will need to address potential staffing peaks. These measures will remove the need to consider alternatives such as temporary living accommodation or helicopter shuttling.
8. Any room designated as sleeping accommodation must not be overcrowded. Overcrowding occurs when cabin accommodation occupancy levels exceed the maximum allowable occupancy level, for the actual volume of the room. It also extends to the need to have sufficient space to allow for reasonable access to the facilities within the room, disturbance to sleeping occupants by others using the facilities within the room or using the adjacent corridors and rooms, and to disturbance caused by cleaning/servicing the room.
9. The ideal room volume provided for each occupant in a room designated as sleeping accommodation should not be less than 11 cubic metres/person [including all furniture and fittings, e.g. bed, desk and clothes storage space, but excluding toilets, showers or wash room]. The minimum height of room should be 2.3 metres. In making the volume calculation a room or part of a room which is more than 3.0 metres high should be counted as 3.0 metres high.
10. Minimum volume per occupant is derived from established standards – such as the 4th Edition Guidance Notes3 and onshore workplace requirements4. It is also consistent with standards used by other regulators including Norwegian NORSOK Standard C-0015. Any room providing less than 6.9 cubic metres per person is considered overcrowded.
11. Cabins providing between 6.9 and 11 cubic metres per person will be considered as having the potential to be overcrowded. In such circumstances, enforcement decisions are based on additional factors including numbers occupying the room and features of the room that may affect available space e.g. number of beds.
12. Adequate space for the storage of clothes requires a number of cupboards and/or drawers which can be individually locked. The minimum numbers required being equivalent to the number of bunks in the accommodation cabin.
13. Single occupancy of a cabin during a 24 hour period provides absolute privacy.
14. Reasonable privacy will be provided when a cabin is allocated to a maximum of two persons during a 24 hour work/rest period (double occupancy standard). The two persons can be on the same or different shifts. An exception may be crew change days when due to rotation of personnel more than two persons can be allocated to a cabin during a 24-hour work/rest period. This temporary situation does not change the intention of the double occupancy standard.
15. The double occupancy standard has been in place since the DCR regulations came into force and is consistent with other regulator standards (e.g. NORSOK C-001).
16. Comfort is a state of physical well being and the parameters that ensure reasonable comfort are environmental and physical e.g. air temperature, humidity, air quality, noise pollution, lighting levels, cabin furniture condition and ergonomic suitability (including space and layout).
17. Cabins with en-suite toilet/shower facilities shared between two cabins i.e. one toilet and one shower between four persons is considered sufficient. Any ratio worse than one shower and one toilet shared between four persons is regarded as insufficient.
18. New installations (post 1996) should not have toilets, showers or washing facilities remote from cabins. Existing installations (pre 1996) which were designed with remote facilities should be updated to include the standard of two person cabins, with en-suite toilet/shower and washing facilities when accommodation refurbishment or expansion is undertaken.
19. DCR regulation 12 and Schedule 1 paragraphs 59-66 do not detail prescriptive requirements for NUIs nor is there a specific mention of emergency accommodation. The regulations simply state that people on an installation should be provided with accommodation if the nature, scale and duration of operations so require. Any accommodation that is provided should meet DCR provisions (regulation 12 and Schedule 1 paragraph 59) and must contain sufficient beds or bunks for the number of people expected to sleep on the installation (DCR Schedule 1 paragraph 60).
20. A number of different work patterns can be adopted for visiting NUIs. Annex 1 provides guidance on the minimum accommodation standards for visits of varying duration.
21. DCR Regulation 12 requires compliance with the Schedule 1 requirements on an installation while it is 'in use'.
22. 'In use' in this context means personnel are onboard the installation at its offshore location. An offshore installation with no personnel onboard, no longer remains 'in use'. Therefore Schedule 1 of DCR applies at any time while personnel are onboard an offshore installation, from its initial placement at site, until final site removal.
23. DCR, in accordance with Council Directive 92/91/ECC, required existing installations to comply with the goal for accommodation provision as soon as possible and at the latest by 3 November 1999. All installations currently operating in the UKCS are expected to comply with all the requirements in DCR including those relating to accommodation.
24. The concept of “reasonable practicability” lies at the heart of the British health and safety system. It is a key part of the general duties of the Health and Safety at Work etc Act 1974 and many sets of health and safety legislation including DCR. Using “reasonable practicability” allows HSE to set goals for duty-holders, rather than being prescriptive. This flexibility is a great advantage but it has its drawbacks as it relies upon duty-holders and HSE to exercise judgement with reference to “good practice”. The information provided in this Operations Notice details existing “good practice” on which HSE’s judgement is based.
25. In applying DCR HSE will consider the following “short-term incidents” and “exceptional circumstances”:
Short-term Incidents: From time to time there may be short duration unplanned events that challenge compliance with the above DCR standards. These include circumstances requiring a short term deviation from DCR standards such as a helicopter breakdown or an unforeseen event requiring a raised POB to address safety imperatives.
Exceptional Circumstances: On rare occasions there may be an event that (despite good planning) could not have been foreseen or avoided. Where this involves a safety or welfare imperative HSE’s initial enforcement expectation may be revised if the longer term benefits to health, safety and welfare outweigh the costs of short term compromise of welfare standards – but only when there is no other means of achieving compliance and the impact on welfare standards are mitigated.
26 Each circumstance will require judgement in establishing whether there are sufficient factors that indicate a case for temporary non-compliance with DCR accommodation standards. HSE will consider the following factors when considering enforcement action. This list is not exhaustive and other relevant factors will be taken into account:
27 Where a decision is made to allow operation at a lower standard the duty holder will be required to demonstrate that:
28 All enforcement decisions will be subject to management review by HSE, and will be recorded in sufficient detail to make it clear how the final enforcement decision was reached. The record will include a timescale for revisiting the decision to ensure an early return to compliance.
29. For further information on enforcement and its application to accommodation please see the HSE Enforcement Management Model and SPC/Enforcement/169 Offshore Accommodation: Enforcement Guidelines.
Example: People attending a NUI for a few hours per day on a periodic or irregular basis, by vessel transfer only in good weather, with the vessel standing by during the short period people are stationed on the installation. People are not expected to stay overnight on the installation because the standby vessel is available throughout the work period and capable of returning the installation crew to suitable accommodation. In the event of the standby vessel or attendant craft breaking down, there should be contingency arrangements in place to transfer the installation crew, on the same day, either back to the shore or to other suitable accommodation (eg on an alternative vessel or attended installation). Toilet and basic eating facilities need to be available nearby eg on the attendant craft.
Accommodation provisions:
Example: People attending NUIs for full day trips (no planned overnight stays) on a periodic or irregular basis by helicopter transport, where the helicopter returns later in the day to collect them. The helicopter may park on a nearby attended installation or return to shore. Because of the possibility that the helicopter will break down, become unavailable or be prevented from flying because of bad weather, there is an increased likelihood that people might have to stay overnight on the installation. Accommodation must be provided because of the nature, scale and duration of the operations. In this scenario, where there may be no dedicated standby vessel, the Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 19955 (PFEER) regulation 17 still requires arrangements for a good prospect of recovery and rescue of personnel following evacuation or escape from the installation.
Accommodation provisions:
Overcrowding is not permissible (a volume of 6.9 m3 per person would be considered the minimum acceptable in this scenario).
The above facilities should be of a suitable size for the maximum number of people expected to be stationed on the installation at any one time, including the helicopter crew of a helicopter broken down on deck.
Example: People attending NUIs for trips of two to three days duration (planned overnight stays) on a periodic or irregular basis by helicopter transport, where the helicopter returns to collect them. Accommodation must be provided because of the nature, scale and duration of the operations.
Accommodation provisions:
Note: Three-tier-high bunks may be considered only for the particular work pattern and visit frequency described in Scenario 2 (no planned overnight stays) but, if considered, then a risk assessment should be undertaken to ensure height of bunk etc does not give undue risk of injury from anyone falling from the top bunk. Also note the requirements of PFEER, particularly regulation 14(3)(b), where two means of egress are required from accommodation areas (kick-out panels will suffice for a second means of egress).
Smoking and non-smoking personnel should be catered for, either by separate rest rooms, or prohibition of smoking in rest room accommodation areas.
This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance as illustrating good practice
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