Health and Safety Executive

Safety Case Handling and Assessment Manual - Combined Operations Notification submitted under Regulation 10

1.1 Summary of combined operation notification procedure

1.1.1 HSE has three objectives when dealing with combined operations notifications (CONs) submitted under Regulation 10 of the Offshore Installations (Safety Case) Regulations 2005 (SCR05); these are to:

  1. Check that the notification meets the requirements of SCR05 particularly those detailed in Regulation 10 and Schedule 4.
  2. Confirm that the combined operations proposed are within the scope of the accepted safety cases of each installation involved.
  3. Decide if an inspection of the combined operation activity is required.

1.1.2 Inspection Management Teams (IMTs) or Topic Specialist Inspectors (TSIs) may decide to inspect the combined operation to check that the dutyholders are fulfilling their statutory duties.

1.1.3 The IMT Inspector shall involve the TSI when the IMT inspector identifies:

  • Significant health and safety concerns;
  • Novel risk reduction measures; 
  • Unusual operations; or
  • Operations that may lead to increased risk.

in a combined operation notification. This will lead to an inspection of the activity. 

1.1.4 A notification cannot be processed for an operation out with the scope of that described within the production installation’s safety case. Should this arise, the dutyholder of the production installation must submit a safety case under Regulation 14(2) detailing a material change that will bring the proposed combined operation within the scope of the case. This safety case will be assessed and a decision made as to its acceptability, only then can the notification be processed.

1.1.5 In the case of most notifications, eg those involving a production installation and a drilling rig, there will be two Focal Point IMT inspectors involved. The IMT Inspector allocated to the dutyholder of the production installation shall take the lead in processing it in accordance with this procedure.

1.1.6 When work recording, HSE’s activities in processing CONs should be categorised as chargeable inspection, as described in the annual work recording SLC.

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1.2 Relevant requirements of the regulations

1.2.1 SCR05 Regulation 2(4) has a new definition of combined operation which is significantly different from the 1992 Regulations. This definition determines whether a notification needs to be sent. IMT inspectors should ensure that dutyholders recognise this difference so that unnecessary notifications are not sent to HSE.

1.2.2 SCR05 Regulation 10 requires notification at least 21 days (or such shorter period as HSE specifies) in advance of a combined operation. This notification has to contain the particulars specified in Schedule 4 of SCR05. Any of the dutyholders involved in the combined operation may submit the notification.

1.2.3 Combined operations notifications are not required to be accepted by HSE. However each dutyholder must have an accepted safety case that covers the generic aspects of combined operations. Should the proposed combined operation being proposed exceed the scope of the existing accepted safety case, the dutyholder must submit a safety case revision under Regulation 14(2). This must be accepted by HSE before the necessary CON is submitted.

1.2.4 Notification is intended to ensure that adequate consideration is given by the dutyholders to reducing the risks from a major accident arising from the combined operations and that there will be effective co-ordination of their management arrangements. 

1.2.5 In most cases it is anticipated that consideration of the notification will be straightforward. However, timely action will be required should there be a health and safety concern. Should the Focal Point Inspector responsible be unavailable, the relevant Team Leader shall appoint another Inspector to be responsible for the process.

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1.3 Procedure

Safety Case Receipt Officer

1.3.1 On receipt of a Combined Operations Notification (CON) the Safety Case Receipt Officer (SCRO) shall identify the appropriate IMT Inspector to manage the CON on behalf of the Division. The appropriate IMT Inspector will normally be the Focal Point for the production installation associated with the CON. They are identified from the Safety Case Plan. Where the Focal Point Inspector is unavailable, the IMT Team Leader shall take the lead until they have identified and delegated the responsibilities to another Inspector.

1.3.2 The SCRO shall create a ’Case’ for the CON in COIN against the production installation.

1.3.3 The SCRO shall send the CON to the appropriate IMT Inspector and advise them of the COIN Case number. When a CON is sent electronically to HSE, it can be attached to the COIN case. The SCRO shall advise the relevant IMT Administrator that the CON has been received.

1.3.4 The SCRO shall send an email to the IMT Inspector who acts as the Focal Point of the non-production installation(s) advising them that a CON has been received.

1.3.5 The SCRO shall send to the dutyholder, who submitted the CON, a letter (Annex CN1) acknowledging receipt.

IMT Focal Point Inspector

1.3.6 The IMT Focal Point Inspector shall notify, by e mail, the relevant Topic Specialist Inspectors that a notification has been received by OSD. The email will include a brief summary of the proposed combined operation.

1.3.7 The IMT Focal Point Inspector shall send a copy of the CON to the Mobile(s) IMT Focal Point Inspector.

1.3.8 The IMT Inspector for the production installation along with the IMT Inspector(s) for the mobile installation(s) shall review the CON and:

  • Check that it is within the scope of the dutyholder’s accepted safety case:
  • Meets the requirements of Schedule 4 of the Safety Case Regulations:
  • Identify any significant concerns, unusual operations, or novel risk reduction measures; and
  • Decide and plan any on or offshore inspection as appropriate.

1.3.9 The IMT or the TS Inspector may decide to inspect the combined operation to ensure that the dutyholders are fulfilling their duties under the Safety Case Regulations. This would be a normal compliance inspection offshore involving the appropriate TS Inspectors, as required.

1.3.10 Where the IMT Inspector for the production installation identifies any non compliance with the information requirements of Schedule 4 they should contact the dutyholder to ask them to send in any further information required.

1.3.11 Where the IMT Inspector has identified any:

  • Significant health and safety concerns;
  • unusual operations;
  • novel risk reduction measures; or
  • operations that lead to increased risks;

they should undertake an inspection and involve the appropriate Topic Specialist Inspectors. A timely intervention, on or offshore, of the IMT and TS Inspectors should be planned depending on the nature or urgency of any concerns.

Topic Specialist Inspector

1.3.12 A TS Inspector, on receiving an email from the IMT Focal Point Inspector indicating that a notification has been sent to OSD, may decide to pursue an inspection of the combined operation as in 1.3.11 above. This should be discussed and agreed with the IMT Inspector. TS Inspectors shall record any inspection time in COIN and produce an Inspection Report following any intervention with the dutyholder.

Scope of inspections

1.3.13 Inspections should be considered in the broadest sense. It can include all phases of the activity, eg planning, preparation, approach, the operational activity, and move off.

COIN audit trail – IMT and Topic Specialist Inspectors

1.3.14 IMT and Topic Specialist Inspectors shall ensure that any inspection activities pursued result in reports or HSE letters that are a sufficient audit trail of HSE’s intervention, recorded and attached to the appropriate COIN case. 

1.3.15 The lead IMT Inspector shall complete the Inspection Report proforma in Annex 2 to indicate:

  • The CON is within the scope of the two safety cases;
  • The CON meets the requirements of Schedule 4 of the Safety Case Regulations;
  • That the IMT Inspector has emailed TSIs and recorded any outcome of any dialogue or decisions to inspect or not to inspect.

1.3.16 The Coin case to which documents are attached may be different depending on the timing of the intervention.

1.3.17 Documents associated with the inspection of the notification are to be attached to the Notification CON case. This will be, as a minimum, the;

1.3.18 Additionally, any correspondence or other documents generated from the immediate Inspection of the Notification are also to be attached. Following this approach allows the CON COIN Case to be closed out. It is the responsibility of the Team Leader to close the Case. The performance standard for close out is 4 weeks from the receipt of the CON.

1.3.19 Where it has been decided to pursue an onshore or offshore inspection(s) of the combined operation activity the reports and closeout letters etc are to be attached to the Inspection Case in Coin for the installation in question.

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1.4 Abbreviations

IMT Inspection Management Team
SCRO Safety Case Receipt Officer
SCR05 Offshore Installations (Safety Case) Regulations 2005
TSI Topic Specialist Inspector

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1.5 References

  1. Operations Notice 70 What particulars relating to combined operations, should be provided in the safety case for an installation? January 2006

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Annex 1 – Acknowledgement letter for use with combined operations notifications

The following is a template for use with the standard HSE letterhead.

Anything in carat marks e.g.<name>, should be replaced by specific details in an actual letter.

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Updated 19.06.09