Safety Case Assessment

initial REVIEW – Dismantlement of an Installation Safety Case

Work Instructions

The purpose of initial review of a dismantlement safety case submission is to determine:

1.  If the essential components that SCR 2015 Schedules 6 (or 7) and 8 are present in the submitted safety case;

2.  If the submitted case is adequate to give it a good prospect of acceptance in the subsequent assessment process.

The initial review is not a consideration of the quality and detailed justifications made-out in the case, this is undertaken later in topic specialists’ individual assessments.

IMT Focal Point Inspectors should use this template to record the initial review of a safety case against the requirements of SCR 2015 Schedules 6 (or 7) and 8. When complete, it should accompany the Assessment Instructions sent to topic specialists.

Duty holders should be encouraged to complete the table column labelled “Safety Case Reference” and include appropriate comments to identify the section where the relevant information is to be found within the Safety Case. This will assist Inspectors to quickly locate relevant information, thus making the assessment process more efficient, which is a mutual benefit.

For dismantlement revisions – the initial review should determine if the information required by Schedule 6 (or in exceptional circumstances Schedule 7) and the information required by Schedule 8 of the regulations is present and where it appears in the case. The information that was present in the ’current’ safety case is likely to have been modified significantly to take account of the changing hazard and risk profile during dismantlement and the duty holder must still submit a full copy of the safety case showing clearly where the proposed revisions are incorporated (Regulation 20(1)(b)). It is acknowledged that many of the requirements identified in Schedule 8 duplicate the requirements of Schedule 6 (or 7), this serves to highlight where changes are likely to be most significant.

The Initial Review template complements the guidance to the regulations and topic-specific guidance, standards and good practice. Together with topic-specific templates, it forms part of the complete record of the assessment process undertaken by the Competent Authority.

Relevant Guidance

·  APOSC Principles:

Factual information

Ø  Principle 1

The factual information should meet the [SCR15] requirements and provide sufficient detail to support the arguments made in the case

·  GASCET Chapters:

1-4 Assessment of Adequacy

Ø  In assessing the major accident hazard aspects of safety case submissions it is necessary to determine the adequacy of, inter alia:

·  Hazard identification

·  Risk evaluation

·  Risk management measures [barriers and performance standards]

·  The demonstration of compliance with relevant statutory provisions.…

TRIM: 2015/077658 Revised: 22/12/2015 Page 1 of 4

Owner: ED7

Safety Case Assessment - initial REVIEW – Dismantlement of an Installation Safety Case

SCR2015 / Schedule Detail
& Required Content / Safety Case Section Reference / Comments to Assist Topic Assessors
For Example: Has text changed from the current (previously accepted) safety case. Are there multiple sections that provide information to address the requirements etc. / Content is sufficient to proceed to assessment? (Y/N) /
Production Schedule 6 / Non-production Schedule 7 / Dismantle-ment Schedule 8 /
1 / 1 / 1 / Name and address of Owner / Operator
·  Identification of Owner, or DECC/OGA approved Operator
·  contact address
2 / 2 / 2 / Maximum number of persons on board
·  expected / max / accommodated
3 / 3 / CMAPP
·  CMAPP to be present in case
4 / 4 / 3 / Summary of worker involvement
·  worker & safety reps involvement
5 / 5 / 4 / Description of the SEMS
·  sufficient content to presume all regulatory requirements have been covered
5 / Proposed arrangements, methods and procedures for dismantling the installation & connected pipelines
·  sufficient content to presume adequate account has been taken of the design & method of construction
6 / Information on the following:
·  the means of isolating all hazardous substances
·  the risks of a MA to the workers and the environment, the total exposed population the risk control measures
·  emergency response arrangements for evacuation and rescue and for maintaining control
6 / 6 / Description of verification scheme
(incl. well examination scheme – Well Operators only)
·  sufficient content to presume all regulatory requirements have been covered
7 / Matters raised during design notification (Production only)
·  pNAIs and DH response to them
8 / 7 / Main requirements of design
·  limits to safe operation, compliance with DCR Reg 4 (general integrity) & PSR reg 11 (safe operation of a pipeline), suitability of SECEs.
8 / Environmental limitations (Non Production only)
·  environmental / meteorological, seabed/subsoil & location stationing limitations
9 / Risks from seabed and marine hazards (Non Production only)
·  seabed / marine hazards for pipelines / moorings / wells / subsea equipment
9 / Meaning of Operator – no requirement for information (Production only)
10 / Plan of location (Production only)
·  meteorological / oceanographic / seabed / subsoil
11 / 10 / Description of installation
·  primary & secondary structure / plant / layout & configuration / connections to pipelines, installations, wells / transfer means
12 / 11 / Particulars of types of operation
·  capability and actual
13 / 12 / Particulars of plant and arrangements
·  well control / process safety / containment of hazardous substances / prevention of fire & explosion / protection of environment
14 / Description of pipelines (Production only)
·  fluid conveyed / dimensions & layout / max volume / apparatus & works to secure safety
15 / 13 / 7 / Compliance with PFEER 4(1)
·  assessment, measures and arrangements for protection from fire & explosion
16 / Particulars of PFEER and MAR (Production only)
·  aspects of fire, explosion, emergency response and management for control of major accident hazards
17 / 14 / Information relating to the prevention of major accidents resulting in significant / serious damage to the environment
·  potential environmental effects, technical / non-technical measures to prevent, reduce, offset & monitor
18 / 15 / 8 / Plant used and arrangements made to protect persons
·  from hazardous substance & toxic gas
19 / 16 / Measures taken and arrangements to protect persons
·  from fire, heat, smoke, toxic gas, fumes including: TR, escape routes, means of evacuation, monitoring & control station
20 / Maintenance of control systems on evacuation (Production only)
·  arrangements made
21 / 17 / 9 / Description of the internal emergency response arrangements
·  PFEER & OPEP
22 / 18 / Assessment of oil spill response effectiveness
·  Description of OPRC assessment
23 / 19 / Particulars of combined operations
·  arrangements for: co-ordinating SEMS, reviewing safety aspects including identification of hazards & assessment of risk, plant used, impacts on installations
24 / 20 / Other relevant details

TRIM: 2015/077658 Revised: 22/12/2015 Page 4 of 4

Owner: ED7