SAFETY MANAGEMENT SYSTEM REQUIREMENTS - ASSESSMENT SUMMARY

Transcription

1 Non Acceptance Issue SAFETY MANAGEMENT SYSTEM REQUIREMENTS - ASSESSMENT SUMMARY 1. CMAPP Requirements a) Regulation 7 / 8 (aspects of) - Safety case for production / non-production installation b) Regulation 29 Major accident prevention policy Required Required Conclusion c) Schedule 10 - Particulars to be addresses in a Corporate Major Accident Prevention Policy d) Schedule 11 - Matters in accordance with which the CMAPP and SMS must be prepared 2. SMS Requirements a) Regulation 7 / 8 (aspects of) - Safety case for production / non-production installation b) Regulation 12 - Management of health and safety and control of major accident hazards c) Regulation 18 Keeping of documentation d) Regulation 30 Safety Management System e) Schedule 11 - Matters in accordance with which the CMAPP and SMS must be prepared f) Schedule 12 - Particulars to be addressed in a Safety Management System 3. Verification System Requirements a) Regulation 7 / 8 (aspects of) - Safety case for production / non-production installation b) Regulation 19 Verification Schemes c) Regulation 20 Review and revisions of verification schemes d) Regulation 31 Description of verification scheme e) Schedule 7 - Matters to be provided for in a Verification Scheme TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 1 of 18

2 Note on Purpose of Draft Template SAFETY MANAGEMENT SYSTEM ASSESSMENT TEMPLATE This document will be available to inspectors to record their assessment of the CMAPP(s), the description of the safety management system and the verification arrangements contained in a Safety Case submitted under SCR2015. It identifies the specific regulations contained within SCR2015 that relate to these topics and identifies what the CA expects to find within a safety case to meet those requirements. The document is drafted to complement the guidance being produced to support the regulations. Requirements identified by green text are new to SCR2015, those in black text were present in SCR05. It is proposed that similar templates will be developed for other disciplines that together will form the complete record of the assessment process undertaken by the Competent Authority. It is proposed to make these templates freely available to promote transparency and assist industry in drafting it s submissions. Relevant Pre-Existing Guidance APOSC Principles: Factual information Principle 1 The factual information should meet the SCR05 requirements and provide sufficient detail to support the arguments made in the case Management of health and safety Principle 2 The safety case should demonstrate that the management system is adequate to ensure compliance with the relevant statutory provisions Principle 3 The management system should show an appropriate level of control during each phase of the installation life cycle, including design, construction, commissioning, operation, decommissioning and dismantlement GASCET Chapters: 2.1 Safety management Safety management The key features of a safety management system (SMS) are establishing a policy, linking objectives with this policy, making arrangements for delivering the policy/objectives and measuring performance TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 2 of 18

3 1. Corporate Major Accident Prevention Policy (CMAPP) Requirements a) SCR2015 Regulation 7 / 8 (aspects of) - Safety case for production / non-production installation 7(6) Where, pursuant to paragraph (3), a safety case is to be prepared in relation to more than one production installation with different operators (a) a copy of the corporate major accident prevention policy of each operator must be included with the safety case; 1. Where there are multiple Operator(s) are these identified; (APOSC Principle 1 & 2) 2. Is a copy of CMAPP(s) provided for each operator? (APOSC Principle 1 & 2) b) SCR2015 Regulation 29 Major accident prevention policy 29. (1) The duty holder must prepare in writing a corporate major accident prevention policy, including in respect of installations of the duty holder outside of the European Union. (2) The corporate major accident prevention policy must address at least the particulars set out in Schedule [10] and must be prepared in accordance with Schedule [11]. (3) The corporate major accident prevention policy may in addition outline the commitment of the duty holder to mechanisms for effective tripartite consultation established between the competent authority, duty holders and workers representatives. (4) In preparing a corporate major accident prevention policy an operator must take account of the operators primary responsibility for, among other things, the control of risks of a major accident that are a result of its operations and for continuously improving control of those risks so as to ensure a high level of protection at all times. (5) A duty holder must (a) implement the corporate major accident prevention policy throughout its offshore oil and gas operations; and (b) set up appropriate monitoring arrangements to assure effectiveness of the policy. 1. Is there a CMAPP(s) present? 2. Cross reference Schedule 10 & 11 assessment to confirm all requirements met 3. Is there a commitment for tripartite consultation between the competent authority, duty holders and workers representatives 4. Does CMAPP includes reference to: a) the operators responsibility for the control of risks of a major accident Participation through representation at OIAC (or equally effective alternative) TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 3 of 18

4 b) continuously improving control of those risks 5. Is there evidence of implementation of CMAPP throughout offshore oil and gas operations? 6. Does the Safety Case demonstrate the duty holder has set up monitoring arrangements to assure effectiveness of the policy? Is communication of the policy outlined, consider recent intervention history have there been significant findings that would indicate the CMAPP has not been implemented effectively? c) SCR2015 Schedule 10 - Particulars to be addresses in a Corporate Major Accident Prevention Policy Schedule 10 - Particulars to be addresses in a Corporate Major Accident Prevention Policy 1. The responsibility at corporate board level (or in the absence of a board, at a senior level in the organisation) for ensuring, on a continuous basis, that the corporate major accident prevention policy is suitable, implemented, and operating as intended. 2. Measures for building and maintaining a strong safety culture with a high likelihood of continuous safe operation. 3. The extent and intensity of process auditing. 4. Measures for rewarding and recognising desired behaviours. 5. The evaluation of the organisation s capabilities and goals. 6. Measures for maintenance of safety and environmental protection standards as an organisational core value. 7. Formal command and control systems that include board members and senior management of the organisation. 8. The approach to competency at all levels of the organisation. 9. The extent to which the particulars in paragraphs 1 to 8 of this Schedule are applied in the company s offshore oil and gas operations conducted outside the European Union. 1. Is responsibility allocated at senior level for suitability, implementation and operation of CMAPP 2. Is there a commitment to address measures for building and maintaining a strong safety culture? 3. Is there a commitment for process auditing of an appropriate extent and intensity? 4. Is there a commitment to implement measures for rewarding and recognising desired behaviours? 5. Is there a commitment to have a system to evaluate the organisation s capabilities and goals? 6. Are standards in safety and environmental protection identified as organisational core values and is there a commitment to implement measures to maintain this? 7. Is there a commitment for formal command and control systems that includes board members and senior management of the organisation TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 4 of 18

5 8. Is there a commitment to ensure competency at all levels of the organisation and identify an approach to ensure it is achieved? 9. Is the extent to which the Policy applies to the company s offshore oil and gas operations conducted outside the European Union outlined? d) SCR2015 Schedule 11 - Matters in accordance with which the Corporate Major Accident Prevention Policy and Safety Management System must be prepared Schedule 11 - Matters in accordance with which the Corporate Major Accident Prevention Policy and Safety Management System must be prepared 1. The need to pay particular attention to evaluation of the reliability and integrity requirements of all safety and environmental-critical systems and base inspection and maintenance systems on achieving the required level of safety and environmental integrity. 2. The need to take appropriate measures to ensure as far as reasonably practicable that there is no unplanned escape of hazardous substances from pipelines, vessels and systems intended for their safe confinement. In addition, the need to ensure that no single failure of a containment barrier can lead to a major accident. 3. The need to ensure there is a suitable framework for monitoring compliance with all relevant statutory provisions by incorporating statutory duties in respect of major hazards control and environmental protection into standard operating procedures; and 4. The need to pay particular attention to building and maintaining a strong safety culture with a high likelihood of continuous safe operation, including with regard to securing cooperation of employees and contractors through, inter alia: a. visible commitment to tripartite consultations and actions arising from them; b. encouraging and rewarding reporting of accidents and near-misses; c. working effectively with elected safety representatives; d. protecting whistleblowers. 5. The need to adopt suitable measures to use suitable technical means or procedures in order to promote the reliability of the collection and recording of relevant data and to prevent possible manipulation of that data. 1. Does the Safety Case contain a statement relating to the aspects that were considered when the CMAPP was developed? 2. It is evident from the statement (and the CMAPP) that these aspects included the following: a) The need to pay attention to evaluation of the reliability and integrity requirements of all safety and environmental-critical systems? a) The need to base inspection and maintenance systems on achieving the required level of integrity. b) The need to pay attention to evaluation of the reliability and integrity requirements of all safety and environmental-critical systems? c) The need to take appropriate measures to ensure as far as reasonably practicable that there is no unplanned escape of TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 5 of 18

6 hazardous substances from pipelines, vessels and systems intended for their safe confinement d) The need to ensure that no single failure of a containment barrier can lead to a major accident. e) The need to ensure a suitable framework for monitoring compliance with all relevant statutory provisions by incorporating statutory duties in respect of major hazards control and environmental protection into standard operating procedures f) The need to pay attention to building and maintaining a strong safety culture with a high likelihood of continuous safe operation, including with regard to securing cooperation of employees and contractors through, inter alia: i. visible commitment to tripartite consultations and actions arising from them; ii. encouraging and rewarding reporting of accidents and nearmisses; iii. working effectively with elected safety representatives; iv. protecting whistleblowers. g) The need to adopt suitable measures to use suitable technical means or procedures in order to promote the reliability of the collection and recording of relevant data and to prevent possible manipulation of that data. TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 6 of 18

7 2. Safety Management System Requirements a) SCR2015 Regulation 7 (aspects of) - Safety case for production installation 7(6) Where, pursuant to paragraph (3), a safety case is to be prepared in relation to more than one production installation with different operators 7(6)(b) an adequate description of the document setting out the safety management system prepared pursuant to regulation 31 and the accepted EMS (within the meaning of regulation 3 of the Offshore Petroleum Activities (Offshore Safety Directive) (Environmental Functions) Regulations 2015; and 7(6)(c) the description of the internal emergency response arrangements of each operator must be included within the safety case. 1. Where there is more than one operator is a document identified that sets out the SMS? (APOSC Principles 1&2) 2. Is there a description of the document s content? (APOSC Principles 1&2) 3. Is the description adequate to show how the SMS works? (APOSC Principles 1&2) 4. Is there reference to each operator s internal emergency response arrangements in the SMS? b) SCR2015 Regulation 12 - Management of health and safety and control of major accident hazards 12. (1) The duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraphs (2) and (3), include in the safety case sufficient particulars to demonstrate that (a) The duty holder s management system is adequate to ensure (i) that the relevant statutory provisions will, in respect of matters within his the duty holder s control, be complied with; and (ii) the satisfactory management of arrangements with contractors and sub-contractors; (b) he has established adequate arrangements for audit and for the making of reports thereof; (c) all hazards with the potential to cause a major accident have been identified; (d) all major accident risks have been evaluated, their likelihood and consequences assessed, including any environmental, meteorological and seabed limitations on safe operations, and that suitable measures, including the selection and deployment of associated safety and environmental-critical elements have been, or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with; and (e) in the case of a non-production installation, that all the major hazards have been identified for all operations the installation is capable of performing. (2) Paragraph (1) only requires the particulars in the safety case to demonstrate the matters referred to in that paragraph to the extent that it is reasonable to expect the duty holder to address them at the time of sending the safety case to the competent authority. TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 7 of 18

8 (3) In this regulation, audit means systematic assessment of the adequacy of the management system to achieve the purpose referred to in paragraph (1)(a) carried out by persons who are sufficiently independent of the system (but who may be employed by the duty holder) to ensure that such assessment is objective. (4) The demonstration in paragraph (1)(d) must include the estimate of the effectiveness of oil spill response effectiveness contained in the oil pollution emergency plan in respect of the installation, prepared pursuant to regulation [4(1)(c)] of the [Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998]. 1. Does the safety case demonstrate that: a) the SMS is adequate to ensure relevant statutory provisions will be complied with? b) the SMS is adequate to ensure there is satisfactory management of contractors and subcontractors? c) the SMS is adequate to ensure there are arrangements for auditing and reporting those audits? d) the SMS is adequate to ensure all hazards with the potential to cause MAs have been identified? e) the SMS is adequate to ensure the MA risks have been evaluated and their likelihood and consequence assessed? i.e. Does the SMS take account of the PFEER assessment? f) the SMS is adequate to ensure that suitable measures, including the deployment of suitable SECEs, have been taken to control those risks? g) the SMS is adequate to ensure for non-production installations that all MAH been identified for all the operations the installation is capable of performing? h) the SMS must include the estimate of the effectiveness of oil spill response effectiveness contained in the oil pollution emergency plan c) SCR2015 Regulation 18 Keeping of documentation There are new aspects to this existing regulatory requirement relating to environmental considerations that will mean the Operator will need to review their evaluation and the content of their case. The inspector should confirm it now addresses these specific aspects to ensure it is acceptable under the new regulatory requirements. As above This is a requirement for the SMS but inspectors should refer to advice from Environmental topic specialists when assessing the adequacy of the information 18. (1) A duty holder must (a) ensure that, when the duty holder sends (i) the design notification, in the case of a production installation; or Clarificatio n TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 8 of 18

9 (ii) the safety case, in the case of a non-production installation, to the Competent authority, it is notified of an address in Great Britain for the purposes of sub-paragraphs (b) and (e) below; (b) keep copies, at the address referred to in sub-paragraph (a) and on the installation, of the following documents relating to the installation (i) the current safety case; (ii) any summary of any review of the current safety case prepared pursuant to regulation 13(2); and (iii) each audit report; (c) keep copies on the installation of the following documents relating to the installation (i) any relocation notification and any material changes thereto; (ii) any notification of combined operations and any material changes thereto; and (iii) any notification of well operations and any material changes thereto; (d) ensure that, in respect of each audit report, a written statement is made, recording (i) the main findings of the report; (ii) the recommendations in the report; and (iii) the action proposed to implement those recommendations, including the timescales involved, and a copy of that statement kept on the installation; and (e) ensure that a record is made of any action taken in consequence of an audit report, and a copy of that record kept at the address referred to in subparagraph (a) and on the installation. (2) The copy of the current safety case referred to in paragraph (1) and any other relevant documents must be kept for so long as they are current, and the copy of the audit report, the written statement and the record referred to in that paragraph must be kept for a period of 3 years after being made. (3) The duty holder for an installation must ensure that (a) its verification scheme, any modification of that scheme and any note made pursuant to regulation 19(2)(c) or 20(b) is kept at the address notified to the competent authority pursuant paragraph (1)(a) until the expiration of 6 months after such scheme or, as the case may be, modification of that scheme, has ceased to be current; and (b) records, sufficient to show the matters described in paragraph 55 of Schedule 7, are kept at the address notified to the Competent authority pursuant to paragraph (1)(a) until the expiration of 6 months after completion of the offshore oil and gas operations to which they relate. (4) In this regulation, audit report means a report made pursuant to the arrangements referred to in regulation 12(1)(b). 1. Is a UK address identified? 2. Is there a commitment to keep copies of relevant documents at the UK address for the stipulated timescales? 3. Is there a commitment to keep copies of relevant documents on the installation for the stipulated timescales? The relevant documents to be kept at the UK address AND on the installation and the stipulated timescales are: a) current version of the Safety Case and associated documentation - for as long as they are current; b) Thorough Review Summary - for as long as it is current; c) Audit Reports including main findings, recommendations & actions proposed, record of actions taken - for a period of 3 years after being made; d) Verification Scheme and associated records - until the expiration of 6 months after the scheme has ceased to be current. TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 9 of 18

10 Additional documents to be kept on the installation and the stipulated timescales are: a) Relocation Notifications and all associated material changes - for as long as they are current; b) Combined Operations Notifications and all associated material changes - for as long as they are current; c) Well Operations Notifications and all associated material changes - for as long as they are current. d) SCR2015 Regulation 30 Safety Management System 30. (1) The duty holder must prepare a document setting out its safety management system. (2) The safety management system is to include organisational structure, responsibilities, practices, procedures, processes and resources for determining and implementing the corporate major accident prevention policy. (3) The safety management system is to be integrated with the overall management system of the duty holder, taking into account the accepted EMS applicable to the installation under the Offshore Petroleum Activities (Offshore Safety Directive) (Environmental Functions) Regulations (4) The safety management system must address the particulars in Schedule [12] and must be prepared in accordance with Schedule [11]. (5) The document setting out the safety management system must include a description of (a) the organisational arrangements for the control of major hazards; (b) the arrangements for preparing and submitting documents under the relevant statutory provisions; and (c) the verification scheme (which description must comply with regulation 31). 1. Is there a document setting out the Safety Management System? This whole section is a new regulatory requirement. Some aspects may have been previously covered as a result of the operator addressing SCR05 Reg 12, and guidance such as APOSC and GASCET. The inspector should confirm the case addresses these specific aspects to ensure it is acceptable under the new regulatory regime. 2. Does the case demonstrate that the safety management system includes the following to allow the CMAPP to be determined and implemented: a) organisational structure b) responsibilities, c) practices, procedures, processes, d) resources 3. Is the SMS integrated with the overall management system of the duty holder? 4. Does the SMS take account of the accepted EMS? 5. Cross reference Schedule 12 assessment to confirm all requirements met. 6. Cross reference Schedule 11 assessment to confirm all requirements met. TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 10 of 18

11 7. Does the document setting out the safety management system include: a) a description of the organisational arrangements for the control of major hazards? (APOSC Principle 2-7) b) a description of the arrangements for preparing and submitting documents under the relevant statutory provisions? c) a description of the verification scheme? e) SCR2015 Schedule 11 - Matters in accordance with which the Corporate Major Accident Prevention Policy and Safety Management System must be prepared Schedule 11 - Matters in accordance with which the Corporate Major Accident Prevention Policy and Safety Management System must be prepared 1. The need to pay particular attention to evaluation of the reliability and integrity requirements of all safety and environmental-critical systems and base inspection and maintenance systems on achieving the required level of safety and environmental integrity. 2. The need to take appropriate measures to ensure as far as reasonably practicable that there is no unplanned escape of hazardous substances from pipelines, vessels and systems intended for their safe confinement. In addition, the need to ensure that no single failure of a containment barrier can lead to a major accident. 3. The need to ensure there is a suitable framework for monitoring compliance with all relevant statutory provisions by incorporating statutory duties in respect of major hazards control and environmental protection into standard operating procedures; and 4. The need to pay particular attention to building and maintaining a strong safety culture with a high likelihood of continuous safe operation, including with regard to securing cooperation of employees and contractors through, inter alia: a. visible commitment to tripartite consultations and actions arising from them; b. encouraging and rewarding reporting of accidents and near-misses; c. working effectively with elected safety representatives; d. protecting whistleblowers. 5. The need to adopt suitable measures to use suitable technical means or procedures in order to promote the reliability of the collection and recording of relevant data and to prevent possible manipulation of that data. 1. Does the safety case contain a statement relating to the aspects that were considered when the SMS was developed? 2. Is it evident from the statement and/or the description of the SMS that the following aspects were considered: a) The need to pay attention to evaluation of the reliability and integrity requirements of all safety and environmental-critical systems? b) The need to pay attention to evaluation of the reliability and integrity requirements of all safety and environmental-critical TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 11 of 18

12 systems? c) The need to base inspection and maintenance systems on achieving the required level of integrity. d) The need to take appropriate measures to ensure as far as reasonably practicable that there is no unplanned escape of hazardous substances from pipelines, vessels and systems intended for their safe confinement e) The need to ensure that no single failure of a containment barrier can lead to a major accident. f) The need to ensure a suitable framework for monitoring compliance with all relevant statutory provisions by incorporating statutory duties in respect of major hazards control and environmental protection into standard operating procedures g) The need to pay attention to building and maintaining a strong safety culture with a high likelihood of continuous safe operation, including with regard to securing cooperation of employees and contractors through, inter alia: i. visible commitment to tripartite consultations and actions arising from them; ii. encouraging and rewarding reporting of accidents and near-misses; iii. working effectively with elected safety representatives; iv. protecting whistleblowers. h) The need to adopt suitable measures to use suitable technical means or procedures in order to promote the reliability of the collection and recording of relevant data and to prevent possible manipulation of that data. Cross reference Reg 29(c) f) SCR2015 Schedule 12 - Particulars to be addressed in a Safety Management System Schedule 12 Particulars to be addressed in a Safety Management System 1. Organisational structure and personnel roles and responsibilities. 2. Identification and evaluation of major hazards as well as their likelihood and potential consequences. 3. Controls of the major hazards during normal operations. 4. Management of change. 5. Emergency planning and response. 6. Monitoring of performance. 7. Audit and review arrangements. 8. The measures in place for participating in tripartite consultations and how actions resulting from those consultations are put into effect. TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 12 of 18

13 1. Does the description of the SMS show that the organisational structure and the personnel roles and responsibilities have been addressed? 2. Does the description of the SMS show that the identification and evaluation of major hazards as well as their likelihood and potential consequences have been addressed. (APOSC Principle.2) 3. Does the description of the SMS show that controls of the major hazards during normal operations have been addressed? 4. Does the description of the SMS show that a management of change process have been addressed? 5. Does the description of the SMS show that emergency planning and response have been addressed? 6. Does the description of the SMS show that monitoring of performance has been addressed? 7. Does the description of the SMS show that audit and review arrangements have been addressed? 8. Does the description of the SMS show the measures in place for participating in tripartite consultations and how actions resulting from those consultations are put into effect have been addressed? Cross reference Reg 30 (2) Cross reference Reg 12 (c) & (d) Cross reference expectation outlined in CMAPP Schedule 10(4) Cross reference expectation outlined in CMAPP Schedule 10(3) Cross reference Reg 12 (1)(b) & (3) Cross reference expectation outlined in CMAPP - Reg 29(3) Cross reference Schedule 11 (4)(a) TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 13 of 18

14 3. Verification System Requirements a) SCR2015 Regulation 7 / 8 (aspects of) - Safety case for production / non-production installation 7(4) The operator of a production installation must include with the safety case sent to the competent authority a statement, made after considering the matters in paragraph (5), that the record of safety and environmental-critical elements and their scheme of maintenance are or will be suitable. (5) The matters are (a) reports referred to in regulation 2(6)(e); (b) comments and reservations made by independent and competent persons referred to in regulation 19(2)(a) and (c)(i); (c) findings and recommended remedial action given by such persons referred to in paragraph 5(b) and (c) of Schedule 7; and (d) reports or recommendations referred to in regulation 18(2) of the Offshore Installations and Wells (Design and Construction etc.) Regulations 1996 Or 8(2)&(3) equivalent for non-production 1. Does the Safety Case include a statement that the record of SECEs and their scheme of maintenance are or will be suitable? 2. Does this statement take account of: a) ICP reports of non-compliance? b) comments and reservations made by the ICP? c) findings and recommended remedial identified by the ICP? d) reports or recommendations by the Well Examiner? This is a new regulatory requirement however verification schemes and specifically suitability was included in SCR05 Reg 2(5) although it did not extend to environmental aspects. The inspector should confirm the case addresses these specific matters to ensure it is acceptable under the new regulatory regime. As above - the inspector should confirm the case addresses these specific aspects to ensure it is acceptable under the new regulatory regime. b) SCR2015 Regulation 19 Verification Schemes 19. (1) The duty holder for an installation must ensure that a record of the safety and environmental-critical elements and the specified plant is made. (2) After a record has been made in accordance with paragraph (1), the duty holder must ensure that, in accordance with paragraph (3) (a) comment on that record by an independent and competent person is invited; (b) a verification scheme providing for the matters contained in Schedule 7 and complying with paragraph (4) is drawn up by or in consultation with such person; (c) a note is made of any reservation expressed by such person as to the contents of (i) that record; or (ii) that scheme; and TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 14 of 18

15 (d) that scheme is put into effect. (3) The matters set out in paragraph (2) must be completed (a) in the case of a production installation, before completion of its design; and (b) in the case of a non-production installation, before it is moved into relevant waters with a view to its being operated there. (4) A verification scheme complies with this paragraph if (a) tasks under the scheme are appropriately allocated by the independent and competent person to personnel qualified to undertake them; (b) includes suitable arrangements for the flow of information between the duty holder and the independent and competent person; (c) the independent and competent person is given suitable authority by the duty holder to be able to carry out the functions under the scheme effectively; (d) material changes are referred to the independent and competent person for further comment in accordance with the scheme. (5) The outcomes of referral of the kind described in paragraph (4)(d) must be communicated to the competent authority, if it so requests. 1. Is there a record of the SECEs and specified plant? Whilst Regulation 19(1) (3) are not new regulatory requirements the scope of the verification scheme has been extended to include environmental critical elements. Assessment will need to establish that these elements have been appropriately considered and incorporated. 2. Does the DH invite comment on the SECEs and specified plant by an ICP? 3. Cross reference Schedule 7 to confirm requirements met. 4. Was the Scheme drawn up by or in consultation with the ICP? 5. Is a note made of any reservations expressed by the ICP including: a) the records, b) the scheme, c) that the scheme is in effect 6. Does the Case identify that the Scheme is to be in effect before completion of the design (production) or being moved into UK waters (non-production)? 7. Does the duty holder demonstrate how the ICP will ensure tasks are allocated to personnel qualified to undertake them? 8. Are there suitable arrangements for the flow of information between the duty holder and the independent and competent person? 9. Does the case show that the ICP has been given suitable authority to carry out the functions under the scheme effectively? 10. Are material changes referred to the ICP for further comment in accordance with the scheme? c) SCR2015 Regulation 20 Review and revisions of verification schemes Regulation 19(4) & (5) are new regulatory requirements and the inspector should confirm the case addresses this specific matter to ensure it is acceptable under the new regulatory requirements. 20. The duty holder must ensure that, as often as may be appropriate (a) the verification scheme for the duty holder s installation is reviewed and, where necessary, revised or replaced by or in consultation with an Clarifi cation TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 15 of 18

16 independent and competent person; and (b) a note is made of any reservation expressed by such person in the course of drawing it up. 1. Does the safety case show that the DH has provided for the review and revision of the verification scheme? (Assessment Guideline 19-h) 2. Does the safety case show that arrangements were in place to make a note if the ICP expressed a reservation when the scheme was drawn up? d) SCR2015 Regulation 31 Description of verification scheme Cross reference Reg 31(c) and Schedule 7 (4) 31. For the purposes of regulation 7(1)(a) and paragraph 18 of Schedule 2, regulation 8(1)(a) and paragraph 16 of Schedule 3, and regulation 30(5)(c), a description of the verification scheme complies with this regulation if it includes (a) a description of the criteria for selection of independent and competent persons to carry out functions under the scheme; (b) a description of the means of verifying that the safety and environmental-critical elements and any specified plant remain in good repair and condition; and (c) details of the arrangements to carry out the functions under the scheme and to keep the scheme under review throughout the lifecycle of the installation including (i) the examination and testing of the safety and environmental-critical elements by independent and competent persons; (ii) verification of the design, standard, certification or other system of conformity of the safety and environmental-critical elements; (iii) examination of work in progress; (iv) the reporting of any instances of non-compliance; and (v) remedial actions taken by the duty holder. 1. Is there a description contained in the safety case of the criteria for selecting the ICP? 2. Is there a description of the means of verifying that the SECEs and specified plant remain in good condition and repair? (Assessment Guideline 19-d) 3. Are details of the arrangements to carry out the functions under the scheme, and to keep the scheme under review throughout the lifecycle of the installation, included in the Case? (Assessment Guideline 19-h) 4. Do the arrangements refer to all of the following functions: a) the examination and testing of the safety and environmentalcritical elements by the ICP? This is a new regulatory requirement. Some aspects may have been covered as a result of operator s addressing SCR05 Reg 2(5)(6)&(7) and Reg 18. The inspector should confirm the case addresses these specific aspects to ensure it is acceptable under the new regulatory regime. Cross reference Reg 20(a) and Schedule 7(4) TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 16 of 18

17 b) verification of the design, standard, certification or other system of conformity of the SECEs? c) examination of work in progress? d) the reporting of any instances of non-compliance? e) remedial actions taken by the duty holder? e) SCR2015 Schedule 7 - Matters to be provided for in a Verification Scheme Schedule 7 - Matters to be provided for in a Verification Scheme 1. 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. 2. Arrangements for the communication of information necessary for the proper implementation, or revision, of the scheme to the persons referred to in paragraph The nature and frequency of examination and testing 4. Arrangements for review and revision 5. The arrangements for the making and preservation of records showing (a) the examination and testing carried out; (b) the findings; (c) remedial action recommended; and (d) remedial action performed. 6. Arrangements for communicating the matters specified in paragraph 5 to an appropriate level in the management system of the duty holder for the installation. 1. Does the description of the scheme provide the principles to be applied in selecting the persons who will: a) perform the functions of the scheme (the ICP)? b) keep the scheme under review? 2. Does the description of the scheme provide the arrangements for communication of information necessary for implementation and, revision of the scheme to the persons who will perform the functions of the scheme and those who will review it? 3. Does the description of the scheme provide the nature and frequency of examination and testing? 4. Does the description of the scheme provide the arrangements for review and revision? 5. Does the description of the scheme provide the arrangements for the Cross reference Reg 31 a) Cross reference Reg 19 (4)(b) Cross reference Reg 31 (c)(i) Cross reference Reg 20 (a) and Reg 31(c) TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 17 of 18

18 making and preservation of records showing (a) the examination and testing carried out? (b) the findings? (c) remedial action recommended? (d) remedial action performed? 6. Does the description of the scheme provide for arrangements for communication at an appropriate level in the management system? TRIM 2014/333385: SMS Assessment Template DRAFT for comment Sept 2014 Page 18 of 18