Collision risk management - guidance on enforcement
SPC/Enforcement/177
Purpose
1 This SPC provides advice on enforcement in relation to the inspection of a duty holder's Collision Risk Management System. (Replaces SPC/Enf/24)
Background
2 An offshore installation is exposed to ship collision risk from both in-field and passing vessels. Both categories of collision have occurred on the United Kingdom Continental Shelf (UKCS) and both have the potential to result in catastrophic damage to the installation, although to date only severe consequences have been observed in UK waters. World-wide, catastrophic collisions with installations have occurred resulting in significant damage to vessels and installations, leading to loss of life and environmental damage.
3 The research report 'Update of the UKCS Risk Overview' (OTH 94 458 ) compares the risks from various hazards to offshore personnel and shows that collision risk is significant; as the following table illustrates:
Major Hazard Fatality Rate
| Hazard | % |
|---|---|
Process |
38.80 |
Structural (Mobile) |
23.00 |
Helicopter (Mech.) |
16.80 |
Collision |
11.20 |
Helicopter (Pilot) |
5.00 |
Blowout |
2.00 |
Structural (Fixed) |
1.70 |
Riser/Pipeline |
1.60 |
(OTH 94 458)
4 During the 27 years from 1975 through to 2001 there were 557 reported collisions between ships and offshore oil and gas installations located on the UKCS. Of these, 86 caused moderate or severe damage to the installation. Of the 557 reported collisions, only 8 involved 'passing vessels' (ie vessels not operating in connection with the installation). The majority of collisions involved 'in-field' vessels & over two thirds of these were supply vessels. Useful though this historical data is, it is important to note that the offshore industry is changing and the use of shuttle tankers on the UKCS to export oil from offshore fields has increased significantly over recent years.
5 It is clear that not only have the majority of collisions been with 'in-field' vessels but that the duty holder has a much greater degree of managerial control over these vessels than with 'passing' vessels. What is also clear is that the collision risk management of 'in-field' vessels is different to that of 'passing' vessels. These points were made clear in the research document 'Effective Collision Risk Management for Offshore Installations' (OTO 1999 052) which influenced the subsequent industry guidance published by Oil & Gas UK in February 2003. The Oil & Gas UK document is entitled 'Guidelines For Ship/Installation Collision Avoidance'.
6 The Appendix of this SPC provides some guidance on which enforcement method would be appropriate for certain failings of a duty holder's Collision Risk Management System. The guidance on enforcement contained within this document and its Appendix is designed to be used in conjunction with the guidance given in the Oil & Gas UK document 'Guidelines For Ship/Installation Collision Avoidance' which has been published separately on the intranet.
7 The 'Guidelines For Ship/Installation Collision Avoidance' contains some details of the legislation that is relevant to the management of collision risks. The legislation that is of particular interest to inspectors is that which falls under the umbrella of the Health & Safety at Work Act 1974, where breaches of which may form the basis of enforcement; especially the Management of Health and Safety at Work Regulations 1999, the Offshore Installations (Safety Case) Regulations 2005, the Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995 and the Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995.
8 This document seeks to give inspectors advice when considering enforcement measures following inspection of a duty holder's Collision Risk Management System. Notwithstanding anything contained in this document, with regard to all matters of enforcement, inspectors are advised to refer to the Offshore Division's Intervention Guide. By its very nature, the management of ship/platform collision risk is a difficult task to perform successfully; requiring as it does the integration of a number of component parts, some of which will be performed by contractors, such as SBV operators, who lie outside the remit of OSD inspectors.
9 Inspectors have at their disposal a range of enforcement methods extending from verbal action to letters, improvement and prohibition notices and prosecution. The guidance given in this document takes account of the HID Enforcement Management Arrangements, and has been configured to provide benchmarks to enable enforcement decisions to be made. The aim of this document being to encourage a consistency of approach regarding this issue.
10 The guidance on enforcement contained within this document is designed to be used in conjunction with the advice given in the 'Guidelines For Ship/Installation Collision Avoidance'. That document provides, inter alia:
- an overview of the key elements of a collision risk management system;
- advice regarding the management of in-field and passing vessel collision risks;
- an addendum containing detailed check lists, formats & references on a range of collision risk management issues.
11 In relation to the specific management of FPSO/Shuttle Tanker collision risks inspectors should contact OSD 4.3 for further advice.
Relevant legal requirements
- Health & Safety at Work Act 1974 (HSWA)
- Management of Health and Safety at Work Regulations 1999 (MHSWR)
- Offshore Installations (Safety Case) Regulations 2005 (SCR05)
- Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995 (MAR)
- Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995 (PFEER)
- Offshore Installations and Wells (Design and Construction, etc) Regulations 1996 (DCR)
Appendix – Prioritised Question Set
System Review
| Question | Comment | Enforcement Management Model Benchmark |
Guidance | Applicable Standard |
|---|---|---|---|---|
Is there clear demonstrable management commitment to the identification and assessment of collision risks and the establishment of appropriate measures to control them? |
There should be a clear management commitment to the identification and assessment of collision risks and the establishment of appropriate measures to control them. Such a level of management commitment should be considered as giving rise to the risk benchmark in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 3 |
Established |
Do senior management demonstrate visible commitment to such policies? (as indicated above) |
Senior management should visibly demonstrate commitment to such policies. Such commitment would equate to the risk benchmark in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 3 |
Established |
Has a procedure been Established for the management of vessel collision risks which specifies the overall approach to be adopted in relation to the identification of hazards, the assessment of risks and the establishment of appropriate procedures for the detection, control, mitigation and response to emergencies? |
If the duty holder has adequate procedures in place then these should be equal to the risk benchmark in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 3 |
Established |
Are appropriate communication systems and procedures in place for communication between the installation and vessels either operating within the 500m zone or encroaching within it? |
If communication systems are appropriate then such systems would be considered equal to the risk benchmark in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 4 |
Defined |
In-Field Vessels' Risk Management
| Question | Comment | Enforcement Management Model Benchmark | Guidance | Applicable Standard |
|---|---|---|---|---|
Has a clear systematic process been used to identify all in-field vessels that may pose a major accident hazard to the installation? |
A clear systematic process should have been used to identify all in-field vessels that may pose a major accident hazard. If the duty holder has used such a process then the risk benchmark should be at least equal to that in the adjacent column. |
Remote likelihood of significant injury for single casualties |
(1) Page 27 |
Defined |
Has an installation/operation specific risk assessment been undertaken for every installation operated by the duty holder? |
The duty holder should have conducted an installation or operation specific risk assessment (in relation to in-field vessels); if such an assessment has been undertaken the risk benchmark in the adjacent column will apply. |
Remote likelihood of significant injury for single casualties |
(1) Page 1, 3 & 27 |
Defined |
Does the duty holder ensure that any visiting vessel and her crew are "fit for purpose" before it enters the 500m safety zone, eg through such means as: |
If the duty holder has adequate procedures in place regarding visiting vessels then their risk benchmark should be at least equal to that in the adjacent column. |
Remote likelihood of significant injury for single casualties |
(1) Page 28 |
Established |
When letting any contract for whatever type of in-field vessel, does the duty holder, by appropriate pre-contract assessments and auditing, ensure that: |
If the duty holder has adequate procedures in place then their risk benchmark should be at least equal to that in the adjacent column. |
Remote likelihood of significant injury for single casualties |
(1) Page 30 |
Established |
In connection with the marine operations around the installation, has the duty holder ensured that a clear policy has been Established with respect to the cessation of marine operations in relation to adverse environmental conditions and that no undue pressure can be brought to bear on the master of the visiting vessel to start and/or continue operations if he considers it unsafe to do so? |
If the duty holder has adequate policies in place then they would be considered to have a risk benchmark at least equal to that in the adjacent column. |
Remote likelihood of significant injury for single casualties |
(1) Page 31 |
Established |
Do the emergency response procedures take into account the likely structural response of the installation and possible escalation following a ship impact in various environmental conditions? |
If the duty holder has adequate procedures in place regarding the likely structural response of the installation then they would be considered to have a risk benchmark at least equal to that in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 34 & 12 |
Established |
Has an appropriate risk assessment been carried out with respect to the off-loading operations, which takes account of the characteristics of both the installation and each shuttle tanker? |
If the duty holder has conducted an appropriate risk assessment then they would be considered to have a risk benchmark at least equal to that in the adjacent column. |
Remote likelihood of significant injury for single casualties |
(1) Page 35 |
Established |
Does the duty holder have a system for inspection of the shuttle tankers servicing its installations? |
If the duty holder has such a system then they would be considered to have a risk benchmark at least equal to that in the adjacent column. |
Remote likelihood of significant injury for single casualties |
(1) Page 37+ |
Established |
Has each shuttle tanker been assessed for its ability to maintain station at the FPSO location under anticipated environmental conditions? |
If the duty holder conducts such assessments then the duty holder would be considered to have a risk benchmark at least equal to that in the adjacent column. |
Remote likelihood of significant injury for single casualties |
(1) Page 37 & 36 |
Established |
Passing Vessels' Risk Management
| Question | Comment | Enforcement Management Model Benchmark | Guidance (1) | Applicable Standard |
|---|---|---|---|---|
Has the duty holder undertaken a location specific hazard identification & risk assessment for each of their installations? |
If the duty holder has undertaken a location specific hazard identification & risk assessment (in relation to passing vessels) they would be considered as having a risk benchmark equal or better than that in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 18 |
Established |
Was the specification of the detection system based on location-specific factors such as, traffic characteristics (eg speed, density, routes, etc.), warning time required by installation, standby vessel availability, and foreseeable weather conditions? |
If the specification of the detection system based on location specific factors such as indicated in the first column then they would be considered as having a risk benchmark equal or better than that in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 21 |
Established |
Can the duty holder demonstrate that the alerting measures adopted to warn off an approaching vessel, are likely to be effective and that they are undertaken early enough to provide a realistic chance that the vessel can take action to avoid a collision? |
If the duty holder can demonstrate that alerting measures are adequate then the duty holder would be considered as having a risk benchmark equal or better than that in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 21 & 24 |
Established |
Does the emergency response plan for the installation address the management of collision risk from passing vessels? |
If the emergency response plan addresses the collision risk from passing vessels then the duty holder would be considered as having a risk benchmark equal or better than that in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 24 |
Established |
Do the installation emergency procedures (for vessel collision) address the time needed for the installation to prepare for collision? Are there time based performance standards? |
If the duty holder can demonstrate that alerting measures are adequate then the duty holder would be considered as having a risk benchmark equal or better than that in the adjacent column. |
Remote likelihood of significant injury for multiple casualties |
(1) Page 24 |
Established |
- Refers to the page and section of the industry (Oil & Gas UK) guidance document 'Guidance For Ship/Installation Collision Avoidance'
- Refers to the page and section of the industry (Oil & Gas UK) guidance document 'Guidelines for the Safe Management and Operation of Offshore Support Vessels'
Further information
To pass on or receive further information relating to this matter, please contact the Emergency Response, Marine and Aviation Operations Team (OSD3.3); (Tel No:01256 404157).