Similar legislation exists in some other countries around the world, such as Australia.
However, for those countries that don't have specific legislation organisation may still need to produce a safety case because of the globalised nature of the oil and gas industry.
Other parties may also request access to an organisation's documented evidence. For
example it may be required during an application for insurance to demonstrate that the risk is as low as possible.
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4.2 - The Requirements for Documented Evidence.
Interested parties may include:
Loss adjusters and insurance companies for insurance applications and claims purposes.
Clients who may be checking that your organisation has an effective safety management system.
It may be used by the enforcing authority and any external accident investigation teams in the event of a major incident.
The employees and their safety representatives who may need access to the evidence for training, communication, and consultation purposes.
The local community and residents, particularly where they may be affected by a major incident.
4.3 - The Purpose of Documented Evidence.
As we discussed in the last page, the main purpose is to demonstrate the safety of an installation or facility. If there are legal requirements for this evidence then another purpose is to also comply with the local legislation.
The safety case or safety report covers all aspects of health and safety on an installation or facility. It is submitted at the planning stage and remains in place throughout the lifespan of the facility until it is decommissioned. It is reviewed at five yearly intervals by the enforcing authority or Regulator, or sooner if requested. It should also be reviewed if there are
significant modifications to the operation of the facility. This regular process of reviewing and updating ensures the continued safety of the facility throughout its lifespan.
4.4 - Typical Content of a Safety Case.
In the UK The Offshore Installations (Safety Case) Regulations 2005 (OSCR) came into force on April 6th 2006. As mentioned, there are significant changes to the regulatory
requirements as a result of the introduction of OSCR, including a duty on the installation operator or owner to consult safety representatives on the preparation, review or revision of safety cases. The safety case should show how this was done.
You can access the HSE's guidance document on OSCR here:
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4.4 - Typical Content of a Safety Case.
Figure 1. Frontpage of the L30 document.
An operator or owner is required by OSCR to submit a safety case to HSE for each installation. This is a written demonstration of safety that has to be updated whenever necessary, to reflect changing knowledge and operational conditions. HSE must accept the safety case before an installation can operate. In reaching a decision about acceptability, HSE assesses the content of the safety case. The Assessment Principles for Offshore Safety Cases (APOSC) guide that assessment.
APOSC is for use by HSE assessors and industry safety practitioners. In publishing this
document, the HSE aims to provide an understanding of how the HSE evaluates the
acceptability of safety cases, by setting out the principles against which cases are assessed, with explanations of what is required.
Safety cases should take account of each principle to the extent necessary to provide an adequate demonstration, and also include the factual information required by OSCR. APOSC complements the guidance on the Regulations. They should be read together. The three principal matters to be demonstrated in a safety case are that:
1. The management system is adequate to ensure compliance with statutory health and safety requirements; and for management of arrangements with contractors and sub-contractors.
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4.4 - Typical Content of a Safety Case.
3. All hazards with the potential to cause a major accident have been identified, their risks evaluated, and measures have been, or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with.
In the following pages we will look at the specific contents of a safety case which includes: Factual information on the facility.
Details of the management system.
Demonstrate that all major accident hazards have been identified, evaluated, and controlled.
How major accident risks are managed. Provisions for rescue and recovery.
Consideration of the facility's lifecycle, from design to decommissioning.
Demonstration of how safe design principles and inherent safety have been included in the design of the installation.
The safety case should be available to anyone on the installation who wishes to look at it.
4.5 - Offshore Safety Case Content - Factual Information.
The safety case will include factual information about the installation itself, the plant and systems used, the location and external environment. It should also cover the activities to be carried out on, or in connection with, the installation. Each piece of information will be linked to all identified hazards associated with the information and which have the
potential to cause a major accident. Other information includes:
Name and address of the operator of the installation.
Summary of how the employee safety representatives for that installation were consulted with regard to the preparation (or revision) of the safety case.
A description, with suitable diagrams, of:
o The main and secondary structure of the installation and its materials. o Its plant.
o Its layout and configuration of its plant.
o The connections to any pipeline or installation.
o Any wells connected or to be connected to the installation.
o The types of operation, and activities in connection with the operation, which
the installation is capable of performing.
o The maximum number of people expected to be on the installation at any
time, and for whom the accommodation is to be provided.
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4.6 - Offshore Safety Case: Details of the Safety Management System.
The safety case should show how the management system will apply appropriate levels of control during each phase of the installation's lifecycle. This will include the design,
construction, commissioning, operation, decommissioning and dismantlement stages. The safety case should include the following elements in the descriptions of the
management system in order to demonstrate that the system is adequate: Policy setting:
o Outlining the policy and its objectives.
o Demonstrating corporate acceptance of responsibility.
Organisation:
o The structure of the organisation. o Demonstration of its accountability. o Demonstration of its safety culture.
o Demonstration of how professional and safety advice will be shared. o Demonstration of how the workforce will be encouraged to be involved. o Outlining of the risk assessment systems.
Planning and standards:
o Outlining the standards and the procedures for controlling risks, including
workload and working hours.
o Outlining the permit to work system and where it will be applied. o Outlining how competency and training will be implemented. o Outlining how key personnel will be selected.
o Outlining how changes will be controlled.
o Outlining how contractors will be selected and controlled, including
subcontractors.
o Outline the planning and control for emergencies. o Outlining how occupational health will be managed.
Performance measurement:
o Outlining how the recording and investigation of incidents will be
implemented.
o Outlining how active monitoring will be implemented.
Audit and review:
o Outlining the auditing process.
o Outlining when and how any review will be applied and the process for
learning lessons.
The safety management system should clarify who is in charge of activities during normal operating conditions and in emergency situations. This would include the arrangements for communications between the 'responsible persons' both on and offshore.
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4.6 - Offshore Safety Case: Details of the Safety Management System.
The safety management system should take account of: The levels of authority.
Performance standards.
How to deal with exceptional conditions. Any lessons learnt from previous incidents.
In the situation where an installation is working in combination with another installation or vessel, the safety case should summarise any arrangements which have been put in place to coordinate both parties.
4.7 - Offshore Safety Case Content: Management of Major Risks and Hazards.