Recovering costs for inspection related activities overseas

SPC/Admin/79

OG status:

Fully open

Author unit / section:

HID HQ 1A

Target audience:

OSD Inspectors

Version:

1

Purpose

There are special procedures and arrangements for recovering costs associated with cost recoverable activities outside Great Britain and the UKCS. The following does not affect current formal treaty arrangements where the duty holder currently pays for work. This SPC replaces SPC/Admin/55 which is withdrawn.

Background

1. Inspectors have no legal powers outside the UKCS and the Fees Regulations do not apply. However, where the purpose of the overseas visit is to facilitate Safety Case assessment or early resolution of possible inspection issues, the activity falls into a cost recoverable category and the duty holder should be notified that a cost will apply. Duty holder agreement to the principle of a cost being raised must be obtained before the visit takes place and Letter to duty holder can be used for this purpose. The costs to be recovered will cover travel, subsistence and inspector time. Different cost recovery arrangements apply where the overseas visit is in connection with an installation on or entering the UKCS but with a duty holder whose primary office is outside Great Britain. Details of these are given in para 10 below.

2. In the event the duty holder is unwilling to agree to pay the costs then alternative arrangements will need to be made to conduct the necessary regulatory discussions in Great Britain.

Action

3. When the visit has been approved by the Head of Division, the staff involved should give advance notification to HID's Finance and Planning Team (HID HQ1A – Redgrave Court, Bootle) of the intended visit. A form for this purpose is at Notification . This form must be accompanied by a copy of the duty holder's written consent to recover costs for this work . On rare occasions it is possible that a company requesting a visit is not a current UKCS duty holder but a potential one. This does not affect the processes described above, but does have implications for HSE's work recording system on WR. These are dealt with below

Work recording

4. The visit should be recorded against the primary duty holder as safety case assessment or inspection. Where the company is not a current UKCS duty holder, a request should be made to the WR administrator for their name to be input to WR.

5. The time recorded should be on a similar basis as that for a normal offshore inspection. The activity time starts with check-in at the airport and concludes on return to the UK. Activity time during the visit should be recorded as the actual time worked or 7.4 hours (7.2 for London based staff) whichever is the greater. Travel to/from the British airport is recorded as travel-non assignable.

6. Occasionally to make most effective and efficient use of the overseas visit some additional non-cost recoverable work may be undertaken eg a visit to a foreign based contractor. In these circumstances a pro-rata apportionment of the travel and subsistence costs will be made to the non cost recoverable activity. To facilitate this it is essential that the non-cost recoverable time is accurately recorded as such on WR, eg Inspection-Other.

Cost recovery

7. The recovery of costs for inspectors' time will be affected through the normal cost recovery procedures and included on the duty holder's quarterly invoice. Activity reports issued with invoices will enable the duty holder to see the cost recoverable time for the visit dates.

8. The recovery of costs for travel and subsistence will be affected on the same invoice. To facilitate this staff must provide HID Finance and Planning Team (HFPT) with the following, as soon as possible after the visit:

1. A photocopy of form A\cs 34F detailing the T&S claim for the visit.
2. Cost details of any tickets pre-supplied by HSE through its travel agents, eg the passenger receipt supplied with airline tickets etc.

9. The HFPT will show the overseas T&S costs separately on the duty holder's invoice statement and this documentation may be required to validate the invoice. The HFPT is responsible for accurately invoicing the duty holder from the data supplied.

Ukcs installations

10. Where an overseas visit is required in connection with an installation on the UKCS because, for example, the Duty Holders' primary offices are not in Great Britain, the work recording and cost recovery requirements are similar to those for a normal visit to an offshore installation.

11. The recovery of costs timeframe starts from check-in at the UK airport to arrival back in the UK. Within this timeframe the following should be recorded as a cost recoverable activity under Assessment, Inspection, Investigation or Enforcement:

1. All travel time, plus any balance of time at the beginning or end of the working day when it is not possible to meet with the Duty Holder.
2. Actual time spent with the Duty Holder or 7.4 hours (7.2 - London based staff) per day, whichever is the greatest.

12. We will not recover costs separately for T&S in these cases. Prior agreement to these costs should be obtained from the duty holder in advance (A generic consent should be considered if regular visits are likely). After each visit the Notification form should be sent to the HFPT together with a copy of the duty holder's written consent to pay the costs.

Further information

Any queries should be addressed to the HID HQ 1A Finance and Planning Team in Redgrave Court Bootle. E-mail to [email protected].

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Letter to duty holder

(Two copies to be sent to Duty Holder)

Dear

Heading

With reference to your request for HSE to visit:………………………………

It is HSE policy to raise recover costs for activities overseas which would incur a fee under the Health & Safety (Fees) (Amendment) Regulations had the activity been carried out in Great Britain or on the UK Continental Shelf.

The costs for this visit will be based on HSE's incurred travel and subsistence costs, plus an hourly rate currently equivalent to £ (multiply current hourly rate by 7.4 (7.2 London staff)) per standard day, per inspector. It is proposed that xx Inspector(s) will be necessary to carry out the necessary work. The inspectors name(s) is/are:

Before the visit can be undertaken your written agreement to the costs being raised is required. I would be grateful if you would complete the acknowledgement on the copy letter attached and return it to me as soon as possible please.

Yours

Inspector

..............................................................................................................

To:

I acknowledge receipt of the above letter and agree that [company name]
will pay any costs raised by HSE in connection with this visit.

Signed:………………………………………………

For and on behalf of:………………………………………………

Date:………………………………

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Notification of a cost recoverable overseas visit

To: HID HQ1A Finance and Planning Team
5S.2 Redgrave Court
Merton Road
Bootle
L20 7HS

Signed:……………………………………………… (Lead Inspector)

Name:………………………………………………

Date:………………………………