Thorough Reviews

Since the UK left the EU, the Offshore Major Accident Regulator (OMAR) is now the UKs Offshore Competent Authority (previously known as the Offshore Safety Directive Regulator (OSDR). How HSE regulate the offshore industry stays the same. Our guidance will be updated to reflect this change.

The purpose of a thorough review is to provide duty holders, the workforce, and the competent authority with a level of confidence that the current safety case, which exists for the lifetime of the installation, continues to be fundamentally sound.

Regulation 23(1) of the Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015 (SCR2015) requires duty holders to thoroughly review their safety cases, and submit a summary to the competent authority no more than five years after the date on which the safety case was first accepted, or the date of the last thorough review.

This means that the five year timescale begins from the date of acceptance following the last full assessment of the safety case, or after each subsequent thorough review. It is not five years from when a material change revision is made to a current safety case. HSE assesses and makes a decision as to the acceptance of those parts of the case which cover the material change only.

A summary of the review must be sent to HSE within 28 days of its conclusion. 

SCR2015 also gives HSE the powers to direct a thorough review of a current safety case. HSE is most likely to direct such a review if for example,  it is concerned that the case may not reflect the true situation on the installation, or that the management system being operated may not be as described in the safety case.

A thorough review should not be confused with the requirement in regulation 24(1) to revise the case when appropriate, to reflect the current state of the installation and its operations.

The arrangements for thorough review of the safety case should be a part of the safety management system. HSE may inspect to ensure that this is the case, and that the arrangements are up to date and are being implemented effectively. 

 The arrangements should ensure that 

  • those carrying out the review are suitably qualified and experienced
  • a degree of objectivity is achieved, for example by including in the review team staff not involved in operating the installation or maintaining the case for safety
  •  the installation safety representatives are consulted
  •  full account is taken of any conclusions and recommendations from the review
  •  any necessary changes to the safety case identified during the review are implemented. This may involve a revision of the case
  • an accurate summary of the review is sent to HSE, within 28 days of its conclusion, and
  • it should consider how its demonstrations might be improved, taking account of all relevant changes and new knowledge since acceptance or the last review to ensure that they remain valid

Guidance

Important Note:  

The regulations referenced here relate to the Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015.  The Offshore Installations (Safety Case) Regulations 2005, although still current,  now only apply to  “internal waters”, which means tidal waters and parts of the sea in, or adjacent to, Great Britain up to the landward limits of the territorial sea e.g. river estuaries, sea lochs, the Minches. The guidance and principles to follow will broadly remain the same as that for our arrangements for SCR2015 however, regulatory responsibility for the 2005 regulations is with HSE and not OMAR.

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Updated: 2024-01-03