Offshore Installations (Safety Case) Regulations 2005 [SCR] A Safety Case is a
description of the procedures and arrangements that an installation duty holder
has put in place to eliminate or minimise the likelihood of a major accident or mitigate the
effects of a major accident.
Offshore Installations cannot be constructed,
operated or decommissioned in the UK or UK waters unless they have a safety
case that has been accepted by the HSE. Once the safety case has been accepted
the procedures and arrangements it contains have to be followed and they become
the basis of inspections. The SCR 2005 replace the 1992 regulations. The changes brought about include extension of the life of the safety case from 3 to 5 years. Further details of the changes are contained in Operation Notice 71 issue date May 2006 General Duty A safety case has to be
prepared by, a) the operator of a fixed installation;
prior to or during
design allowing time for him to take account of any design matters (relating to
health and safety) raised by the HSE who have 3 months to raise such matters
months before commencing decommission b) by the owner of a mobile installation,
months prior to moving into UK waters
c) the owners or operators of
installations involved in combined operations.
weeks before the operation
commences weeks before commencing operations on a well connected to (but not
underneath or immediately adjacent to) an installation. Note that no operation
of any kind (moving into relevant waters, drilling, combined operation,
decommissioning etc.) can commence until the HSE has accepted the safety case.
Once the HSE has accepted the safety case, duty holders shall ensure that the
procedures and arrangements it describes are followed. However procedures are
not to be blindly followed and it is a legal defence to demonstrate that it was
not in the best interests of health and safety to follow the procedures and/or
arrangements. Particulars to be specified
in a safety case These are given in a series
of schedules and regulation 8 of the safety case regulations.
The particulars
in the schedules include: - the duty holders particulars - description, diagrams and a
scale plan of the location (if appropriate) of the installation - particulars of types of
operations and activities - maximum PoB - particulars of the plant and
arrangements for controlling all operations with the potential to cause a
major accident - particulars of operational
limits - particulars of plant and
arrangements for detecting gases fires etc. and for protecting persons from
the effects of incidents and a statement of performance standards to be
achieved - a demonstration by way of QRA
that risks have been reduced to the lowest level that is
reasonably achievable - particulars of any remedial
work required with timescales Other particulars include a
demonstration that: - the SMS is capable of
ensuring that legal obligations are met - there are adequate
arrangements for audit and reporting the findings - all hazards with the
potential to cause a major accident have been identified - risks have been evaluated and
measures have been taken to reduce risks to the lowest level that is reasonably
practicable. Here audit means: - the systematic assessment of
the adequacy of the SMS to achieve its purposes has been carried out by
independent persons to ensure that the assessment is objective. - the independent person(s) may
be employed by the duty holder. Revision of safety cases These must be submitted: - 3 months before a material
change (such as a change of duty holder) - 6 weeks prior to implementing
the revision if it relates to combined ops but only 21 days prior to
implementation if the revision relates to well operations - after an accumulation of
small changes could constitute a material change and in any case 3 months
before the end of the 3 year life of a safety case Notification of well
operations The Duty Holder shall ensure
that the drilling of a well (and for a mobile
installation, any well
operations) shall not commence until at least 21 days after notifying the HSE. Particulars required in the
notification include: 1. Operators details 2. particulars of fluids to be used
to control the well 3. particulars of any plant not described in the safety
case which is to be used 4. particulars of type of well, its number, slot
number and name of field
5. scale diagrams and particulars of - - the location of the top of
the well - the directional path of the
well bore - the terminal depth and
location - its position, and that of
nearby wells, relative to each other 6. A description of the
operations on the well or involved in the drilling of the well, and a programme
of works which includes: - commencement and finish dates - the intended operational
state of the well at the end of the operations 7. A description of - - any simultaneous activities
with the potential to cause a major accident - the hazards associated with
such simultaneous activities 8. For a well which is to be
drilled -
geological data and any hazards with the potential to cause a major
accident - procedures for monitoring the
direction of the well-bore and minimising the likelihood and effects of
intersecting nearby wells - a description of the design
of the well, including its safe operational use 9. In the case of an existing
well - - a diagram of the well, its
state of repair and its physical condition - a summary of earlier
operations and the purposes for which it has been used - its current operational state
and its production capacity 10. For a mobile installation
- - the foreseeable
meteorological and oceanographic conditions - the depth of water and the
properties of the sea bed - particulars of the
arrangements with the operator for managing the operation For particulars to be
included in notification of well operations from a vessel that is not an
installation see schedule 6A of the Safety Case Regulations Documents The Duty Holder shall keep at
an address notified to the HSE and the installation:
a) a copy of the safety
case and any revisions, a copy also to be kept on the
installation b) a copy of
each audit report for 3 years (also to be kept on the installation) and - the main findings and
recommendations of the report - the actions and timescales
proposed to implement the recommendations c) a record of any actions
taken in consequence of an audit report d) a copy of the verification scheme
(see verification) and any modifications for 6 months after it was current e)
records to show the matters relating to a verification scheme, until 6 months
after the scheme has ceased. Records can be kept electronically or on film
provided the information can be reproduced and is secure from loss or
interference. Certification schemes See verification. Co-operation Every person shall co-operate
with the duty holder(s) including those involved in combined operations, so far
as is necessary to enable them to comply with theprovisions of the safety case
regulations. Further Recommended Reading A guide to the Safety Case
Regulations L 30 HMSO ISBN 0 11882055 9Relevant Statutes: