Health and Safety Executive

Goals for the provision of accommodation on offshore installations

  • Operations notice: 62
  • Issue date: Feb 2005

Purpose

1. This revised notice provides supplementary guidance on the provision of accommodation on offshore installations, in compliance with the requirements of regulation 12 and Schedule 1 of the Offshore Installation and Wells (Design and Construction, etc) Regulations 19961, 2 (DCR). The annexes to this notice have now been updated to clarify the reference to 'reasonable practicability' in Schedule 1 paragraph 61(c), and to address issues arising from temporary increases in personnel, eg during modification, repair or maintenance activities.

Background

2. DCR regulation 12 and Schedule 1 paragraphs 59-66 contain provisions with the aim of continuous improvements to accommodation standards offshore. The Schedule contains some non-prescriptive requirements, and the guidance to the Regulations is limited.

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

Annex 1: Goals for the provision of accommodation offshore

Background

DCR regulation 12 and Schedule 1 paragraphs 59-66 contain provisions with the aim of continuous improvements to accommodation standards offshore. Paragraphs 59-66 cover: the provision of sufficient beds for the numbers of people expected to sleep on installations; overcrowding; storage space; privacy and comfort. The Schedule does not detail prescriptive requirements and the only indication of what these objectives mean is contained in the guidance. However, the offshore industry was fully consulted in the preparation of the guidance and paragraphs 115 and 116 should be regarded as industry 'good practice'.

Enforcement guidance

DCR regulation 12 requires compliance with the requirements of Schedule 1 on an installation while it is 'in use' unless, in the case of any such requirement, it would not prejudice the health, safety or welfare of any person if it were not complied with.

'In use' in this context means people 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 that people are onboard an offshore installation, from its initial placement at site until final site removal. The caveat in DCR regulation 12(1) is unlikely to be applicable to provisions regarding accommodation, as in most cases facilities which do not meet the Schedule requirements will prejudice the welfare, and possibly the safety and health, of people involved.

Reasonable practicability

Paragraph 61(c) makes reference to reasonable practicability. This is not a concept which can be applied to welfare matters and is only included to deal with installations built before the Regulations came into force and where there are technical limitations preventing full remedial implementation of the two-berth cabin goal. This is made clear in the answer to Question 17. Further guidance on how the term can be applied is contained in the answer to Question 18.

Multiple occupancy

The DCR Schedule requirements are not prescriptive. The guidance to the Schedule (paragraphs 114-116) indicates what is considered reasonably practicable with regard to numbers of occupants. The clear objective for sleeping accommodation is two-berth cabins, with en-suite shower, toilet and washroom facilities shared between two cabins (over the full life cycle of the field). Where this cannot be achieved, because of lack of space or other technical limitations, dutyholders should get as close to the goal as is reasonable in the circumstances.

Sufficient beds

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 2 for further information concerning NUIs.

The requirement for sufficient beds means that 'hot bunking' is not acceptable and HSE will consider formal enforcement action if it is taking place.

HSE is of the view that a mattress on its own, made up appropriately with bedclothes, does not constitute a bed or bunk. Therefore simply changing the mattress and bedding with two people sharing a bed or bunk still constitutes 'hot bunking' and is not acceptable.

Comfort

Comfort is a state of physical well-being, excluding mental well-being, and the parameters used to establish reasonable comfort are both environmental and physical. These parameters are not defined in this document.

Temporary living accommodation

Temporary living accommodation onboard, such as container-based accommodation, must fully meet all the goals of the Regulations.

Temporary increases in persons on board (POB)

The sleeping accommodation provision needs to take into account temporary increases in POB such as those that occur during planned shutdown, maintenance campaigns, or major modification work. The planning and design of new installations should carefully consider these foreseeable increases in manning levels. This will remove the need to consider alternatives such as temporary living accommodation or normally unacceptable options such as helicopter shuttling.

[back to top]

Questions and answers

Question 1:

What is the goal for provision of suitable sleeping accommodation?

Answer 1:

The goal, agreed with the industry, is two-berth cabins with en-suite shower, toilet and washroom facilities shared between two cabins. Cabins with higher standards than this are encouraged.

Question 2:

Are four-berth cabins acceptable?

Answer 2:

Although the Regulations do not forbid four-berth cabins, ie cabins occupied by four people, in most circumstances they will not provide reasonable privacy and comfort. Where four people are allocated to any one cabin by whatever configuration (eg four people on one shift, or two people on day shift and two people on night shift) it is unlikely that there will be reasonable privacy and that the other requirements of the Schedule will be met. It is therefore unacceptable on new installations, or where it is possible to upgrade the existing accommodation. It is acceptable on installations that cannot be further upgraded because of lack of space or other technical limitations.

Some existing installations also have communal toilets/showers and washing facilities remote from cabins. Again this is considered acceptable for installations that have been upgraded within limits of space or other technical limitations, but is unacceptable for new installations or for additional cabin accommodation.

It is recognised that the design of some mobile offshore drilling units may not lend itself to major redesign and could require major structural alterations to fully meet the provisions of DCR. The Regulations allow for this and it is up to the dutyholder to present to HSE, in discussion and in writing, a reasoned and logical plan (on an installation-by-installation basis) on how far they believe it is reasonably practicable and possible to go to meet the objectives.

Any refurbishment of the installation should include, where this is not prevented by space or technical limitations, upgrading the sleeping accommodation to achieve the goal of DCR, eg when mobile offshore drilling units are having major modifications undertaken inshore or in dry dock. Where it is not possible to achieve the goal, dutyholders should get as close to it as is reasonable in the circumstances.

Note 1: On installations where four-berth cabins still exist and manning levels have been reduced, the dutyholder should have arrangements in place to ensure the four-berth cabins are being used as two-berth cabins as far as reasonably practicable.

Note 2: Accommodation flotels entering the UK continental shelf (UKCS) are required to fully meet the same goals of the Regulations as other installations.

Question 3:

Are six-berth cabins acceptable?

Answer 3:

There is no limit imposed by the Regulations on the maximum number of berths per cabin, but six-berth cabins will not comply with the requirements for reasonable privacy, reasonable comfort or overcrowding. Formal enforcement action will be considered where problems are identified.

Question 4:

If a dutyholder wishes to convert rooms to six-berth cabins, is this acceptable?

Answer 4:

See Q3 above, the intent of the Regulations is to allow for continuous improvement in accommodation; proposals of this type are contrary to that goal. Formal enforcement action will be considered if overcrowding or a lack of reasonable privacy or comfort is identified.

Question 5:

Are lower standards of accommodation or cabin occupancy allowed while the installation is being completed (commissioned) at the place it is to be operated?

Answer 5:

Yes - regulation 12(2) requires that while there are people on a fixed installation that is being completed at the place where it is to be operated, the dutyholder shall ensure that Schedule 1 is complied with as far as reasonably practicable in the circumstances. Therefore, a lower standard of compliance with Schedule 1 may be acceptable during the completion (commissioning) period, as well as during the decommissioning and dismantling period. The Schedule requirement includes all parts of the installation, including work areas as well as accommodation.

It may be acceptable for lower standards to apply to the workplace, but the dutyholder should be able to demonstrate good reasons why any lower standards should extend to the cabin accommodation on the installation. It should be feasible to complete the accommodation modules prior to occupation, have them fully operational with the appropriate services, and occupy the cabins with the numbers they were designed for, ie a maximum of two per cabin. Dutyholders must satisfy themselves that they have taken all reasonable steps to achieve satisfactory standards of accommodation.

This is a known problem area and inspectors will require full justification of any proposed temporary reduction in accommodation occupancy standards, ie has the practicability of other methods been fully explored, eg provision of additional temporary accommodation or flotel use?

Question 6:

Can additional beds be placed temporarily in existing designated sleeping accommodation, eg to overcome foreseen manpower peaks, annual maintenance shutdowns, etc?

Answer 6:

This is generally considered unacceptable, as it is likely to breach reasonable privacy and comfort requirements. It is considered that temporary additional beds will only be acceptable during unforeseen circumstances, eg shuttling personnel fogged in, major unforeseen safety problem onboard requiring additional personnel. Annual maintenance shutdowns and other planned activities do not come into the category of unforeseen events and the provision of adequate accommodation to the appropriate standard must be included in planning for such work.

Question 7:

Can extended helicopter shuttling be used as an alternative means of ensuring sleeping accommodation meets the DCR goals?

Answer 7:

If a dutyholder proposes extended helicopter shuttling because the accommodation normally provided is inadequate or insufficient to meet DCR requirements, then the increased risks associated with shuttling have to be taken into account. This should include the impact of longer working hours and the potential for cumulative fatigue. Shuttling must be regarded as a last resort. If circumstances mean the required standards of sleeping accommodation cannot be met, all reasonably practicable accommodation alternatives must have been explored with a view to eliminating or minimising any shuttling. These include provision of temporary accommodation, a flotel or extending the period of work to reduce POB.

Question 8:

Can additional beds be placed temporarily in non-designated sleeping areas, eg cinemas, libraries, rest rooms, corridors, etc?

Answer 8:

Accommodation must include a sufficient number of showers and washing facilities, equipped with clean hot and cold running water, together with a sufficient number of toilets and washbasins. Non-designated sleeping accommodation is unlikely to comply with these requirements. Only in exceptional unforeseen circumstances would it be considered acceptable to place additional beds in non-designated sleeping accommodation - see A6 above.

Question 9:

Are there any special circumstances where lower standards of accommodation would be accepted.

Answer 9:

The accommodation goals can generally be met with effective planning. However, on some installations the size and nature of the accommodation is such that three or four occupants could utilise the cabins without compromising provisions in DCR Schedule 1 paragraphs 61(a) and 61(b). In such circumstances the cabins may be occupied by more than two people for limited periods of time (eg not more than three weeks in any period of 52), provided that only two occupants are sleeping in the cabin at any one time.

Question 10:

What has double occupancy to do with safety?

Answer 10:

Accommodation is primarily a welfare issue, but it is also a safety issue. Sleep deprivation, tiredness and fatigue can adversely affect safety on the installation.

Question 11:

Double occupancy has been defined as two people occupying a cabin during a 24-hour work and rest period. What is the difference if four men share it but on different shifts (eg two men on days, two men on nights), is this not also double occupancy? Four-berth cabins are bigger and therefore the two occupiers during any one 12-hour shift will have more space.

Answer 11:

The goal of two-berth cabins with shared en-suite facilities between two cabins was agreed with the industry prior to the implementation of the Regulations as a reasonable and realistic objective. Using four-berth cabins occupied by two people on night shift and two people on day shift does not meet this objective, nor that of continuous improvement.

Question 12:

If an improvement notice is issued, will the dutyholder be required to stop all operations?

Answer 12:

A dutyholder issued with an improvement notice for accommodation improvements under DCR would not be required to stop operations. They have the following options:

  • comply with the requirements of the improvement notice in the time specified;
  • appeal to an employment tribunal; or
  • make a written application for an extension of time giving appropriate reasons.

Failure to comply with an improvement notice is a prosecutable offence.

Question 13:

Are the volume and space requirements for the Workplace Regulations3 suitable for offshore accommodation?

Answer 13:

There are no definitive legislative requirements for offshore accommodation space and volume. The onshore Workplace (Health, Safety and Welfare) Regulations 19923 figures correspond with past minimum building regulations figures for bedroom accommodation. They also correlate well with similar maritime accommodation space and volume figures, architectural book standards and Norwegian offshore standards.

Question 14:

What assurance do dutyholders have that accommodation changes asked of them by individual inspectors will not change, eg due to change of allocated inspector?

Answer 14:

All correspondence to/from the dutyholder and minutes of meetings etc will be held on file. Agreements reached will be followed by letters/faxes of the discussions that have taken place and the decisions arrived at. In the event of a dispute, the matter can be raised with the inspection management team leader, operations manager or at a higher level if appropriate.

Question 15:

Might accommodation that does not meet the DCR goal be a factor leading to non-acceptance of a safety case?

Answer 15:

The Offshore Installations (Safety Case) Regulations 19924 have the objective of assessing the risks of major accident hazards. Assessment does not involve examining compliance with general safety and welfare issues. Inadequate accommodation provision identified during the assessment process is not a safety case 'non-acceptance' issue.

Inadequate accommodation provision identified during the assessment process will be raised and discussed with the dutyholder (independent of, although possibly in parallel with, safety case issues), who will then be advised in writing of the potential DCR breach if they proceed to operate their installation in this condition. Any enforcement action would be undertaken during future planned offshore inspections.

Question 16:

Do installations brought in from abroad, with or without a currently accepted safety case, need to comply with the accommodation goals of DCR?

Answer 16:

All installations on the UKCS or Great Britain territorial waters and intending to operate there should comply with the DCR requirements, regardless of whether they have an accepted safety case.

Installations working overseas with a currently accepted safety case intending to operate in future within the UKCS or territorial waters should comply with DCR at the earliest opportunity, and meet the accommodation goal so far as is reasonably practicable.

Installations that have never previously worked in the UKCS or territorial waters but intend to operate in this area in future will need to comply on entering the UKCS or territorial waters. Where those installations existed at 30 June 1996 they need to meet the agreed objective so far as is reasonably practicable. All other installations will need to have accommodation provision at least equivalent to the agreed goal.

Question 17:

What does 'reasonably practicable' mean in the context of the number of occupants of sleeping accommodation?

Answer 17:

The guidance to the regulation indicates that for new installations, and for existing installations where there is no lack of space or other technical limitations meaning the provision cannot be met, two-berth cabins with en-suite facilities shared between two cabins is considered reasonably practicable.

Question 18:

What does 'technical limitation' mean?

Answer 18:

Any costs incurred above direct accommodation refurbishment plus ancillary costs (eg associated shipyard or mooring costs) to enable refurbishment to fully meet the goal of two-berth cabins with en-suite facilities, could be considered to fall within the technical limitation region.

It is entirely up to the dutyholder to decide how much they are willing to spend, but additional costs above 100% of the direct accommodation plus associated ancillary costs of accommodation refurbishments to fully meet this goal could be considered subject to 'technical limitation'.

Any additional costs in the region 10%-100% of direct accommodation plus ancillary costs would support arguments from the dutyholder that the provision cannot be fully met.

[back to top]

Annex 2: Goals for the provision of accommodation offshore on normally unattended installations

DCR regulation 12 and Schedule 1 paragraphs 59-66 contain provisions with the aim of continuous improvement of accommodation standards offshore. The Schedule does not detail prescriptive requirements for normally unattended installations and this guidance addresses the issue.

There is no specific mention of emergency accommodation within the above Regulations. They 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 the DCR provisions (regulation 12 Schedule 1 paragraph 59).

Accommodation provided on an installation must also contain sufficient beds or bunks for the number of people expected to sleep on the installation (DCR Schedule 1 paragraph 60).

HSE's enforcement policy would consider the following minimum accommodation standards adequate for various work patterns and visit frequency scenarios, on normally unattended installations (NUIs):

Scenario 1: Short duration visits on a periodic or irregular basis with no expected overnight stays

Example: People attending an 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 manned installation). Toilet and basic eating facilities need to be available nearby eg on the attendant craft.

Accommodation provisions:

  • accommodation is not required because of the nature, scale and duration of the operations;
  • beds or bunks are not required if accommodation is not provided.

Scenario 2: Full day visits on a periodic or irregular basis with no planned overnight stays but emergency overnight stays could be expected

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 manned 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:

  • rest room accommodation with dining area, complete with tables and chairs with backs;
  • separate food preparation area;
  • changing area with clothes storage facilities which enable male/female separate use, eg lockable;
  • toilets, washbasins, and shower facilities which enable male/female separate use, eg lockable;
  • as people may be expected to stay overnight on the installation in a genuine emergency, beds or bunks should be provided that should meet the following minimum standard:
    • a bed or bunk for each person on the installation (Z-beds or similar temporary beds are acceptable);
    • bed or bunk accommodation facilities that enable male/female separate use, eg lockable separate facilities. Rest room accommodation area can be temporarily used as emergency sleeping accommodation.

Overcrowding is not permissible; see Annex 1 for guidance (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.

Scenario 3: Visits of a few days duration on a periodic or irregular basis with planned overnight stays

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:

  • requirements as per fully manned installation, DCR regulation 12 Schedule 1 and the guidance given in Annex 1.

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 (Management of Health and Safety at Work Regulations 19996 regulation 3, see also regulation 23(2)). Although the following Regulations do not apply, they may contribute to the risk assessment: Workplace (Health, Safety and Welfare) Regulations 19923 regulation 13 and Construction (Health, Safety and Welfare) Regulations 19967 regulation 6.

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.

[back to top]

References

Further information

Any queries relating to this notice should be addressed to:

Health and Safety Executive
Hazardous Installations Directorate
Offshore Division
Lord Cullen House
Fraser Place
Aberdeen
AB25 3UB

Tel: 01224 252500
Fax: 01224 252615

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

Quick links

Ask an expert 0845 345 0055

Health and Safety Executive
Caerphilly Business Park
Caerphilly CF83 3GG

DirectGov - Business Link

Updated 19.06.09