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Verification Scheme

Relevant Statutes:

  • Safety Case Regulations 1992, Reg 15 [SCR]

Main Duty

The duty holder shall for the life of an installation, from design where appropriate, to operation through to decommission, ensure that there is a suitable written scheme, called a verification scheme which is put into effect to ensure that safety critical elements are suitable and remain in good repair and condition.

Definitions

Duty holder - the operator for a fixed installation and the owner of a mobile installation

Independent person -The independent persons can work for the same organisation but they have to be sufficiently impartial and objective in their judgement and have independence from pressures, especially of a financial nature. They should not verify their own work, and their management lines should be separate from those whose work they are checking e.g. the independent person's management chain should not include the management responsible for either the work being verified or for meeting production targets.

Major accident -

  • a fire, explosion or the release of a dangerous substance involving death or serious personal injury to persons on the installation or engaged in an activity on or in connection with it
  • any event involving major damage to the structure of the installations or plant affixed thereto or any loss in the stability of the installation
  • the collision of a helicopter with the installation
  • the failure of life support systems for diving operations in connection with the installation
  • the detachment of a diving bell or other subsea chamber used for such operations, or
  • any other event arising from a work activity involving death or serious personal injury to five or more persons on the installation or engaged in an activity in connection with it

Safety Critical Elements - Any structure, plant, equipment, system (Including computer software) or component part whose failure could cause or contribute substantially to a major accident is safety-critical, as is any which is intended to prevent or limit the effect of a major accident . The term 'contribute substantially to a major accident' is intended to include within the category of 'safety-critical element' those parts whose failure would not directly cause a major accident but would make a significant contribution to a chain of events which could result in a major accident.

Consideration of safety - critical elements should include systems for the detection, control and mitigation of major accidents. Items improving reliability by providing redundancy or diversity should also be considered.

Verification scheme - would have to, in order to be regarded as a suitable written scheme, give assurance that the safety critical elements:

a) are (or, where they remain to be provided, will be) suitable; and
b) where they have been provided, remain in good repair and condition.

In this context suitable includes being appropriate for the intended use, dependable and effective when required, and able to perform as intended. The verification scheme should provide independent checks to confirm continuing suitability throughout the installation's life cycle. It should take account of maintenance work, repairs and operating practices. The scheme is complementary to, but not a substitute for, routine maintenance programmes. A verification scheme would be expected to identify errors or failures in areas such as specification, selection of appropriate performance standards, design, construction or maintenance of elements which have been identified as safety-critical, so that appropriate preventative or remedial action can be taken.

Requirements of a Verification Scheme

These apply to;
a) the operator of a fixed installation from before the completion of design, and
b) the owner of a mobile installation before it moves into relevant waters who shall ensure that:

  • a record is made of the safety critical elements
  • comment on the record by an independent person is invited
  • a verification scheme is drawn up by such a person
  • a note is made of any reservations expressed by such a person as to the contents of the record or the scheme
  • such a scheme is put into effect

Means for Achieving the Verification Scheme

  • examination, including testing where appropriate, of the safety-critical elements by independent and competent persons;
  • examination of any design, specification, certificate, CE marking or other document, marking or standard relating to those elements by such persons; examination by such persons of work in progress;
  • the taking of such other steps as may properly be needed to provide the matters needed in the verification scheme (see below).

Verification Schemes

Matters to be Provided in a Verification Scheme

The principles to be applied by the duty holder for the installation in selecting persons-

(a) to perform functions under the scheme, and
(b) to keep the scheme under review:

  • Arrangements for the communication of information necessary for the proper implementation, or revision, of the scheme.
  • The nature and frequency of examination and testing.
  • Arrangements for review and revision of the scheme.
  • The arrangements for the making and preservation of records showing-
    • the examination and testing carried out
    • the findings
    • remedial action
    • recommended remedial action performed
    • and arrangements for communicating these matters to an appropriate level in the management system.

Records

The verification scheme including any modifications or comments by independant persons must be kept at an address in the UK, notified to the HSE, until 6 months after the scheme ceases.

Relationship with Well Examination Scheme

There may be an overlap between the verification scheme and the well examination scheme when a well is attached to an installation. In this case work carried out by the well operator can be cited as part of the verification. Similarly the installation's verification scheme may be cited by the well operator as part of his well examination scheme. The HSE does not expect work to be duplicated.

Recommended further reading:

  • A guide to the installation verification and miscellaneous aspects of amendments by DCR to SC HSE L83
  • A guide to the integrity, work-place environment and miscellaneous aspects of DCR HSE L83
  • A guide to the well aspects of DCR HSE L84
  • UKOOA's Guidelines for Management of Safety-Critical Elements Sept 96