This page explains why occupational health is so important, what you must do as a dutyholder in the offshore industry, how to manage health risks such as food and water hygiene, and dangerous substances like asbestos.
Occupational health is about protecting the physical and mental health of workers and ensuring their welfare in the workplace. This includes a wide range of activities, but the key priority is to prevent ill health arising out of conditions at work by identifying, assessing and controlling health risks. Other important aspects include:
- ensuring initial and continued fitness to perform a job safely
- providing first aid and emergency medical services
- health education and promotion
- rehabilitation after illness or injury
Why occupational health matters
Many more people become ill as a result of their work than are killed or injured in industrial accidents. Most diseases caused by work do not kill, but they can involve years of pain and suffering for those affected. They include:
- musculoskeletal disorders (manual handling, ergonomics)
- work-related lung disease
- hearing loss caused by noise at work
There can also be health risks associated with psychosocial hazards (stress) and physical hazards, such as:
As well as the human cost, there are potential production costs from sickness absence, staff turnover and, in extreme cases, dealing with medical emergencies and compensation claims.
What the law requires
The Health and Safety at Work etc Act 1974 (HSW Act) requires employers to ensure the health and safety of their employees and others who may be affected. Specific regulations on health hazards such as noise, chemicals and radiation have been made under the HSW Act. Most of these regulations apply offshore or set standards that help to comply with the broad duties under the Act.
All offshore employers have a legal duty to protect workers' health. The main responsibility for controlling risks lies with those whose operations create them, so the owner or operator of an installation has responsibilities to everyone working on the installation.
Contractors also have responsibilities for health risks to their employees or others arising from their activities. These responsibilities overlap, so the law requires dutyholders to co-operate with each other in ensuring health and safety. Employees also have duties not to endanger themselves or others.
Working in the offshore oil and gas industry can involve exposure to a wide range of hazardous substances, radiations, noise, vibration, extremes of heat and cold and ergonomic hazards. All have the potential to harm the health of workers, immediately or in later life. This page will help you develop a comprehensive and systematic occupational health programme for your offshore operations. Ensuring such programmes are properly implemented and maintained by everyone offshore is essential to reducing the risk of ill health.
Information, instruction and training
Health- related legislation places an emphasis on information, instruction and training. The aim of this is to ensure employees are equipped with the relevant knowledge and skills to enable them to effectively carry out any duties they have been assigned, for example being a COSHH a ssessor.
Training on its own does not make people competent. It must be consolidated so the person becomes knowledgeable, skilful and confident in carrying out the job they have been given. Training can take many forms, from on-the-job training to classroom and practical exercises.
Find out more
- The British Occupational Hygiene Society (BOHS) website provides information on a variety of courses and qualifications, as well as the BOHS Course Approval Scheme.
- Offshore Installations and Pipeline Works (First-Aid) Regulations
- List of approved training organisations delivering offshore first aid courses and offshore medic courses
Hazardous substances
The Control of Substances Hazardous to Health (COSHH) Regulations apply to all locations and activities in the offshore industry where the HSW Act applies. This covers:
- offshore installations and pipeline works (including pipe-lay barges) on the UK sector of the Continental Shelf (UKCS)
- vessels working in connection with offshore installations to carry out activities such as construction, maintenance, diving operations etc
COSHH aims to protect workers and others from adverse effects of exposure to substances hazardous to health. It does this by requiring assessment of risk, control of exposure, monitoring and maintenance of controls, health surveillance and the provision of information, instruction and training.
The main duties under COSHH fall on employers. This means that owners, operators and contractors all have responsibilities which cover both their own employees and others who may be affected by their activities.
Management of COSHH
Effective control of health risks depends on co-operation and co-ordination of activities. This is particularly important offshore where a number of employers and their employees may be involved in an operation. Although management arrangements offshore are often complex, the simple, guiding principle is that whoever is in control of an operation must ensure adequate arrangements are in place. Management arrangements might include appointment of COSHH co-ordinators.
Employers will need to ensure appointed people are competent to carry out their functions. Anyone with duties under COSHH may make arrangements with others to carry out those duties but l egal responsibility remains with the employer (the operator, owner or contractor as appropriate) – they must ensure the duties are carried out properly.
COSHH risk assessments
COSHH risk assessments are a key part of ensuring worker safety by helping you to assess the risks to your workers from hazardous chemicals. Assessments should consider:
- substances used – information on the hazardous properties of a substance and its risk potential is essential. You can find out by checking safety data sheets, asking the supplier, looking at industry guidance or checking on the internet, for example HSE's website
- work and working practices – if the substance is harmful, how workers might be exposed, for example breathing in gases, fumes or dusts, contact with the skin or eyes, and swallowing. Bear these in mind when you look at the tasks.
Find out more about how to carry out a COSHH risk assessment.
Prevention and control of exposure
COSHH requires exposure to be prevented or, where this is not reasonably practicable, adequately controlled. Control measures are always a mixture of equipment and ways of working to reduce exposure. The right combination is crucial and no measures, however, practical, can work unless they are used properly.
The Approved Code of Practice on the COSHH Regulations gives a hierarchy of preferred control measures and sets out how adequate control may be achieved.
Offshore COSHH Essentials
Offshore COSHH Essentials was prepared in partnership by an HSE, industry, unions working group and describes good control practice for controlling exposure to chemicals, for a range of common processes and tasks in the offshore industry. The guidance is aimed at managers, safety practitioners, offshore medics and safety representatives in the offshore oil and gas industry, who have responsibility for managing the control of substances hazardous to health.
The sheets are not your COSHH assessments, but will help you assess the risks for named tasks and identify good control practice as well as reviewing existing control practice.
Health surveillance
Employers have a duty to provide health surveillance for their employees only – an installation operator would not be under a duty to provide health surveillance for a contractor's employees. Contractors who do not have good access to specialist advice and services could ask the client company to agree to provide the necessary facilities, providing copy records for the contractor, or they could use an independent, recognised occupational health centre.
Information, instruction and training on COSHH
Operators and owners need to ensure the management on each installation is competent to apply COSHH requirements. When a number of employers are involved, information, instruction and training needs to be co-ordinated to ensure everyone is competent. Employers should also ensure information provided for COSHH is made available to employees' safety representatives.
Safety representatives and the workforce
Involvement of employees in identifying and assessing COSHH hazards is very important. Individual employees have legal duties to take care of their own and others' health and safety and co-operate with management in meeting their obligations. They can only do this if they are involved.
There is more guidance on consulting and involving workers.
Asbestos offshore
Offshore installations built before 1999 can contain asbestos-containing materials (ACMs). The older the installation the more likely that the higher risk materials such as lagging and boarding will be present. Other ACMs liable to be found offshore include external sheeting, brake linings, arc shields for electrical switchgear, and gaskets.
Increased maintenance and fabrication activities, required to deal with the ageing offshore infrastructure, have resulted in a greater potential for exposure to asbestos. There have been several incidents where asbestos has been poorly managed and subsequently disturbed. This has led to exposure to asbestos fibres, costly and disruptive clean-ups and in several cases formal enforcement action by HSE:
- a duty holder failed to identify ACMs under a freezer floor before ripping it up. The white material contained up to 25% amosite (brown) asbestos, and was removed without any control measures. Airborne asbestos fibre levels are likely to have been very high with contamination spread around surrounding areas
- compressed asbestos fibre gaskets not being identified before work began and subsequently removed without any precautions
- maintenance work on external panelling, which turned out to contain asbestos
- cutting penetrations through accommodation walls, which turned out to contain asbestos
- widening a freezer door – the walls were metallic but because an intrusive (refurbishment and demolition) survey was not carried out the internal asbestos insulating board was not identified before the wall was cut with a power saw
Find out more
Comprehensive information and guidance on managing the risk from asbestos can be found at the HSE asbestos site.
Although most work with ACMs must be carried out by somebody who holds a licence from HSE, not all work requires this. The ask sheets in Asbestos essentials will be particularly helpful for installation maintenance and allied trades on how to safely carry out non-licensed work involving ACMs such as:
Food and water hygiene
Poor food safety controls on offshore installations can lead to cases of food poisoning.
Noroviruses are the most common viral cause of food poisoning and can be transmitted from water, shellfish, vegetables contaminated by faeces, as well as person to person contact. Outbreaks are more common in densely populated areas and present a significant risk to offshore installations.
Guidance on good practice to ensure the management, control and monitoring of all aspects of food safety and hygiene is given in Offshore COSHH essentials OFE1 - Food safety and hygiene.
Health concerns regarding drinkable water quality may include physical, chemical, and bacteriological parameters. All drinkable water for consumption offshore has to be disinfected, but even then risks to health can arise from a failure in the disinfection process, or through post disinfection contamination. Failures can be attributed mainly to human error or inadequate operating systems.
Managing occupational health
The framework for managing occupational health risks is based on the same principles used to manage safety for any other business area. The key elements of successful occupational health management is based on 5 steps:
Step 1: Setting your policy
Your company should have a clear policy for health and safety. Every level of management should be committed to achieving the policy – top management commitment is essential.
It is also important to integrate health and safety functions with other management functions. The health and safety policy should therefore influence all your activities including selecting people, equipment and materials, the way work is done and how you design and provide goods and services.
Although the same principles apply to health as safety, it is important to recognise that health risks are often not as obvious as safety issues. Cases of ill health arising from exposure to hazardous substances may take years or even decades to show up. So it is even more important to adopt a proactive approach to managing health issues.
Step 2: Organising your staff
To make your health and safety policy effective you need to get your staff involved and committed. This is often called 'creating a positive health and safety culture' and is essential as offshore workers are closest to the hazards and it is their health which will benefit. The 4 Cs of positive health and safety culture are:
- Competence: recruitment, training and advisory support
- Control: allocating responsibilities, securing commitment, instruction and supervision
- Co-operation: between individuals and groups
- Communication: spoken, written and visible
Workers can play a part in protecting their health by:
- helping to identify health risks and jobs/tasks with potential for exposure
- suggesting improvements to the way jobs are done
- reporting problems or symptoms
- providing feedback on the effectiveness of controls
Find out more about worker involvement
Step 3: Planning and setting standards
Planning is the key to ensuring successful implementation of your health and safety policy. This involves setting objectives, identifying hazards, assessing risks and implementing standards of performance. It is important to record your plans in writing. Your planning should provide for:
- identifying health hazards and assessing risks, and deciding how they can be eliminated or controlled
- complying with relevant health legislation
- agreeing health targets with managers and supervisor
- a purchasing and supply policy that takes health into account
- design of tasks, processes, equipment, products and services, safe systems of work
- arrangements to mitigate the effects if the control measures fail or if problems arise which could not have been foreseen
- co-operation with contractors and suppliers
Standards help to build a positive culture and control risks. It is therefore important to set standards against which performance can be measured. These should set out what people in your organisation will do to deliver your policy and control risk. They should identify who does what, when and with what result.
Step 4: Measuring your performance
You need to measure your health performance to find out if you are being successful. Active monitoring involves regular inspection/checking to ensure your standards are being implemented and management controls are working. Reactive monitoring involves learning from incidents.
You will need to ensure information from active and reactive monitoring is used to identify situations that create risks and do something about them. Give priority to where the risks are greatest, and refer information to the people with the authority to take remedial action, including organisational and policy changes.
Step 5: Learning from experience - audit and review
Audits complement monitoring activities by looking to see if your policy, organisation and standards are achieving the right results. They tell you about the reliability and effectiveness of your management system. The results from measuring performance and audits should be used to improve your approach to occupational health management by reviewing the effectiveness of the policy, with particular attention to:
- the degree of compliance with health performance standards (including legislation)
- areas where standards are absent or inadequate
- achievement of stated objectives within given timescales
- illness, injury and incident data – analyses of immediate and underlying causes, trends and common features
These indicators will show you where you need to improve.
This approach to managing health and safety is tried and tested. It has strong similarities to quality management systems used by many successful companies. It can help you protect people and control loss. All 5 steps are fundamental.
Risk assessment for managing health risks
A systematic approach to managing health risks associated with work activities in the offshore industry will require a risk assessment for each of the occupational health risks using the following approach.
Identify the health hazards
Managers can do much of the hazard identification based on their knowledge of the work activity, although they may need access to specialist advice (for example from occupational hygienists, nurses or physicians) . Developing an inventory of health hazards may be a useful and systematic way of gathering this information.
It is important to include hazards created by work activities, such as welding fumes, exhaust gases or hydrogen sulphide, noise/vibration from use of power tools, growth of legionella in water systems and psychosocial stressors, such as the way that work is organised. For most health hazards there are specific regulations with supporting guidance which will help to identify significant hazards.
Assess the health risks
A risk is the likelihood that someone will be harmed by the hazard in the circumstances in which it is met. You will need to:
- determine the nature of the hazard
- identify who may be affected and when
- measure the extent and duration of exposure to the hazard
The assessment should show whether the control measures in use are successful in reducing the risk to an acceptably low level. If this is not the case, you will need to select and implement further control measures.
Control the risks to health
If the risk assessment shows you need further control measures, you will need to select the most appropriate type. This ‘hierarchy’ of control measures can help you select the most effective measures for any situation:
- elimination or substitution
- engineered controls
- procedural controls
- personal protective equipment (PPE)
The removal of any health hazards, if possible, would be the option of choice. Failing that, the approach should be to use the highest control in the hierarchy where reasonably practicable. PPE only protects the wearer and only when worn properly all the time. It should only be used as a last resort or as a stop gap measure until something better can be put in place. All control measures need to be properly maintained, and workers need to be trained and supervised in their use.
Mitigate the risks to health
The main aim of health risk assessments is to prevent workers’ health being affected by their job. However, you will need to put in place arrangements to act quickly, if there is a failure in control, to minimise any ill- health effects.
Health surveillance should be put in place to look for early signs of ill health caused by work. Medics and first-aiders should be provided, trained and equipped to deal with the full range of health problems that may arise. There should also be arrangements to transport sick or injured workers to shore promptly to seek medical attention.
Workers who have recovered from illness or injury may have difficulty in adjusting again to work, especially after a long period. They will need assistance and advice to rehabilitate them into the work environment.