Procedure for dealing with thorough review summaries submitted under Regulation 13 of the Offshore Installations (Safety Case) Regulations 2005

Introduction

The 2005 safety case regulations move the legal framework from three-yearly resubmissions of safety cases to five-yearly thorough reviews. The dutyholder is required to send HSE a summary of their review. HSE does not need to accept the document for the installation to continue operating, but uses it to update the dutyholder intervention plan.

This procedure describes how compliance with the review requirement is regulated by OSD. The objectives are:

1. to ensure that the dutyholder has an adequate process for thorough review,
2. to ensure that the review has been sufficiently thorough, with action taken to address issues arising from the review, and
3. to update the dutyholder intervention plan, based on the review findings and other sources of intelligence relating to the installation and the dutyholder.

The templates referred to are in TRIM folder 1.9.3.337. The OSD COIN procedures should be used for recording actions with thorough reviews.

Procedure

Before receipt of the summary

1. Before a dutyholder undertakes a thorough review, the IMT focal point inspector consults with the appropriate specialist inspectors to identify any significant matters particular to the installation that should be included in the review. This should occur at a sufficient period of time before the summary is due for the dutyholder to have time to take account of HSE advice.

2. Inspectors then meet the dutyholder to;

• discuss the timing of the review;
• check that the dutyholder has a good understanding of what is required in undertaking a review, taking account of the guidance in HSE booklet L30¹ paras.187–195 and Offshore Information Sheet 4/2006²;
• ensure that the dutyholder takes account of any significant matters relating to the installation; and
• confirm that the dutyholder has the appropriate management arrangements, competent resources and measure of independence required to undertake the thorough review successfully.

3. The IMT inspector records matters raised, discussions and any outcomes using template TRS_0. Any significant deficiencies in the dutyholder’s arrangements for undertaking a review should be confirmed in writing. Inspectors monitor progress of the review and provide advice as necessary.

4. During the review, the dutyholder may conclude that a safety case revision is needed, for example where additional risk reduction measures are found to be required. Where this amounts to a material change, the revised case should be submitted under reg.14(2) and assessed in the normal manner.

On receipt of the summary

5. OSD admin. acknowledge receipt of the summary using template TRS_1, and send copies to the IMT inspector and to the relevant specialist inspectors and their admin.

6. The IMT inspector advises the specialist inspectors (template TRS_2) that the summary has been received, requests them to inspect it and provides them with any necessary background information. By agreement, some topics may be omitted from the process, for example where there is little activity on the installation in the topic area and the specialist team concerned has arrangements to inspect the relevant contractors centrally. For installations with the same operator or owner, it may be appropriate to inspect certain topics (such as generic management systems) only once, and ensure that any remedial actions are applied universally.

7. Inspection includes checking that the summary is in accordance with booklet L30 and information sheet 4/2006, and that any specific matters raised previously by OSD are covered. Requests for clarification can be made to the dutyholder, but detailed technical review is not normally appropriate.

8. Inspectors should form a view on the completeness of the thorough review process in their topic area and identify any issues arising from the review. They should prepare a completion report (template TRS_3) within 10 weeks of receipt of the summary by HSE.

Outcomes

9. There are several possible outcomes from OSD’s inspection of the summary;

1. the review appears to have been thorough in the topic area(s) inspected, possibly with some matters identified for future inspection;
2. the review does not appear to have been thorough. A further review may be required, by a formal direction under reg.13(1); or
3. HSE concludes that the safety case no longer adequately describes the installation, the management systems, the major accident hazards or the precautions to deal with those hazards, such that a revision is required. If the dutyholder is unwilling to do this, direction under reg.15(1) may be appropriate. The matters to be covered in any material change revision may in themselves require separate enforcement action to ensure they are effectively dealt with.

10. Further guidance on outcomes (b) and (c) is being prepared. Broadly, direction of a further review is likely to be indicated if the thorough review process has been inadequate and the five-year review limit has not been reached. This can be done by a letter. However if the five year period is exceeded without submission of an adequate thorough review summary, an improvement notice for breach of reg.13(2) may be appropriate.

11. Adequate records should be kept of the decision process, for reference in the event of an appeal by the dutyholder against direction of a revision or against a notice.

12 A review may result in safety case revisions that are not material changes and do not require assessment. The revised case may however contain information that would affect HSE’s inspection plans. HSE should obtain a copy of such a revised case and inspect it appropriately.

Completion

13. The IMT inspector prepares a close-out report (template TRS_4) and updates the dutyholder intervention plan in the light of issues arising from the summary, and other sources of intelligence. This is done within twelve weeks of receipt of the review summary by OSD. The IMT team leader then approves the report. The existing COIN intervention plan service order is closed and a new one opened to cover the five-year period for which the thorough review will be current.

14. The IMT operations manager then considers HSE’s response to the thorough review summary, and the planned future activities, and approves the proposed action (template TRS_5). This is also recorded on COIN.

15. Processing thorough reviews is categorised as chargeable inspection, as described in the annual work recording SLC.

References

1. A guide to the Offshore Installations (Safety Case) Regulations 2005 L30 Third edition HSE Books 2006 ISBN 0 7176 6184 9
2. Offshore Information Sheet 4/2006 Offshore Installations (Safety Case) Regulations 2005 Regulation 13 Thorough Review of a Safety Case