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Sec.1: General [Table of Contents] Sec.3: Written Schemes (Verification Services)

DNV-OSS-202 Verification for Compliance with UK Shelf Regulations

[-] Sec.2: Hazard Management and Safety Case (Consultancy Services)

SECTION 2
Hazard Management and Safety Case
(Consultancy Services)

Sec.2
A. General

Sec.2
A 100   Introduction

Sec.2 A
101   DNV has gained substantial experience throughout the development of UK offshore legislation, and can provide consultancy services to designers, builders, owners and operators requiring UK compliance.

Sec.2 A
102   These consultancy services include matters such as risk assessment, technical studies, and safety case management as indicated in this section. Further general consulting services can be offered.

Sec.2
B. UK Requirements

Sec.2
B 100   Hazard management

Sec.2 B
101    UK regulations require the systematic identification and avoidance of hazards. Where they cannot be avoided they must be controlled in order to reduce risks to be acceptable and as low as reasonably practicable (ALARP). This process will be demonstrated by risk assessment.

ALARP is particularly important for fixed installations and floating installations located at a fixed location. However, mobile units coming to the UK will also have to demonstrate an acceptable level of safety including reasonable application of the ALARP principle.

Sec.2 B
102   The basic principles for hazard management are:
—systematic identification of major hazards on the installation
—taking action to design out, avoid and reduce hazards at source
—risk analysis and assessment of major accident hazards, including PFEER Regulation 5 assessment
—inclusion of ergonomics and human factors issues within the risk assessment process
—establishing appropriate prevention, detection, control and mitigation measures, including safety-critical elements and their performance standards, to manage remaining hazards
—linking to an acceptable verification scheme covering the SCEs identified
—providing suitable evacuation, escape and recovery resources
—demonstration of fulfilment of the ALARP principle.

The above work forms the basis for development of the safety case(s).

Sec.2
B 200   Safety cases

Sec.2 B
201   A safety case is the formal demonstration of the safety of the unit or installation by design, construction and operation. Detailed requirements for the content of the safety case are stated in the SCR and Guidance.

Sec.2 B
202   The safety case must be submitted to, and accepted by the HSE prior to operation in UK waters, as shown in Table B1. It is against UK law to operate a unit/installation in UK waters without written HSE acceptance of the safety case.

Sec.2 B
203   Safety Cases must be revised in the event of any material change to operation of the unit/installation in UK waters, as directed by the HSE or within 5 years of the previous safety case acceptance. It should be subject to a thorough review at this time with a view to ensuring that the installation will remain fit for the next 5 years.

Sec.2 B
Table B1 Safety case requirements 
Statutory Safety Case SI 2005/3001 Reference 1) Minimum submission period 
Fixed Offshore Installations, including FPS 
Design Notification 2) Regulation 6 1) 2) In sufficient time before completion of design as will enable account of issues raised by HSE within 3 months of safety case submission 3). 
Operational Safety Case 4) Regulation 7 3) 6 months prior to operation 5) 
Mobile Offshore Units 
Operational Safety Case 6) Regulation 8 3 months prior to entry into UK waters with intention to operate 6),7) 
  1. Modifications or amendments under other regulations may also apply as necessary
  2. There is no requirement for this to be formally accepted, but the Duty Holder should ensure that any HSE issues are addressed prior to submission of the operational safety case.
  3. HSE assessment of design notification may result in design modifications. Late submission should be avoided in order to reduce the effect of design changes.
  4. It is an offence to operate a fixed offshore installation in UK waters without HSE acceptance of a governing Operational Safety Case.
  5. "Operation" of the installation is taken as defined in SCR Regulation 7(2).
  6. It is an offence for a mobile unit to enter UK waters, with a view to operating there, without an accepted Operational Safety Case.
  7. Mobile units in transit or only entering UK waters for repairs or refitting do not require to satisfy these regulations.
 

Further details of the required content of safety cases and supporting documents can be found in SCR and associated HSE guidance.

Sec.2
C. Consultancy Services

Sec.2
C 100   General

Sec.2 C
101   DNV can provide consultancy services to assist the client with UK hazard management compliance issues. These include:
—directing of HAZID, HAZOP and hazard reviews
—concept assessment and assistance in selection of options and issues
—risk, reliability, survivability and other safety related analyses and assessments, including the specific PFEER assessment
—identification of safety-critical elements and performance standards *)
—identification of improvements and demonstration of ALARP
—audits, incident and/or accident investigations.
*Can also be performed as a verification service.

Sec.2 C
102   DNV can provide safety case related services such as:
—safety case preparation, co-ordination, and management
—safety management systems and audit
—demonstrating assessment and control of major accidents, and ALARP within the safety case
—safety case review and revision
—communication and discussion of safety matters with HSE on behalf of the client.


Sec.2 C
103   DNV can also provide comprehensive safety engineering services, including attachment to the duty holder's organisation to deal with lifecycle safety compliance issues for offshore assets.

Sec.2 C
104   DNV can provide assistance with Safety Management Systems, and assistance before or following audits.

Sec.2
C 200   Interface with classification

Sec.2 C
201   DNV Classification will contribute to UK compliance in terms of recognised good practice, and is particularly valuable for demonstrating adequacy of marine systems.

Traditional prescriptive classification does not require risk assessment or safety case documentation. All the above assessment and safety case activities therefore need to be documented. It should be noted that deviations from traditional class which are acceptable in the UK regime are likely to be acceptable under class.

Risk-based classification based on DNV-OSS-121 will considerably contribute to requirements for hazard management, but will need additional emphasis on evacuation, escape, rescue and recovery and demonstration of ALARP. A formal safety case will also be required.

Sec.1: General [Table of Contents] Sec.3: Written Schemes (Verification Services)