Effective implementation of offshore verification requirements

Offshore Information Sheet No. 1/2012

(Issued August 2012)

Introduction
Background
Good practice for effective verification
Relevant legal requirements
Further information

Introduction

This sheet provides examples from HSE's inspection experience of how onshore management can effectively implement the regulatory requirements for independent verification in the offshore oil and gas industry.

Background

Regulations 19-21 of the Offshore Installations (Safety Case) Regulations 2005 require operators to appoint an independent and competent person (ICP) to verify that safety-critical elements (SCEs), which provide major hazard risk control, and certain specified plant, such as emergency equipment, are suitable and will remain so.

The operator and ICP must agree a written examination scheme. The operator must act upon the findings of the ICP's examinations (regarding any problems with the initial suitability and the continuing suitability of SCEs) and record the outcome of these actions. This is a central part of the UK offshore safety regime, and a crucial part of the management of asset integrity.

Although the legal requirements are goal setting, experience from HSE's offshore intervention activities, especially a series of focused inspections on verification across the industry during 2007-10, has identified a number of key factors that characterise effective verification arrangements.

This information sheet provides a mechanism for capturing and sharing this good practice across the industry, and dutyholders can carry out a gap analysis to compare their existing approaches with it. The information sheet complements guidance in the verification sections of the regulatory guidance, L30.

Good practice for effective verification

High-level examples of good practice collated to date are set out below under a number of general headings.

Leadership

Verification is a key mechanism for senior managers to obtain independent assurance of the performance of their safety-critical equipment. Their active ownership and involvement in the verification process is crucial. Commitment to the process can be demonstrated by:

using the ICP findings as key performance indicators;
having regular verification status meetings with the ICPs; ensuring remedial action closeout dates are set, monitoring their resolution, and establishing an escalation procedure to reinforce accountability; requiring annual reports on the suitability of SCEs from the ICP and technical authorities;
establishing a clear escalation route to senior management when ICP findings cannot be resolved;
encouraging the workforce to understand the part SCEs play in major accident hazard control, and ensuring they have the capability and the necessary empowerment to take action;
establishing a process for systematic root cause investigation of significant SCE performance failures identified during ICP verification work;
using the ICP findings to support the case for safe operations.

Planning

Effective planning by establishing and maintaining a comprehensive verification scheme is a prerequisite to effective verification. This work includes:

clear identification of SCEs and the part they play in major hazard control by:
- providing a transparent link between major accident hazard scenarios and the SCEs
- ensuring the ICP reviews both the SCE identification process and the outcome; and
- forming a judgment on the relevance of major accident hazards used as the basis for the identification of SCEs;
ensuring SCE performance standards have clear measurable major hazard and installation specific criteria to aid monitoring. Transparent, auditable links to the safety case, associated major accident safety studies and assurance routines should improve understanding of how everything interrelates;
explicitly linking ICP verification activities with criteria in performance standards;
ensuring both performance standards, and changes to them, are reviewed by the ICP as part of initial and continuing suitability.

Considerable benefits can be achieved by integrating ICP verification activities into those of the dutyholder:

including the ICP's offshore activities in the dutyholders planning and maintenance systems ensures that adequate time and resources are made available to the ICP to carry out, for example, commissioning and function testing activities;
for projects and major modifications, the verification activities needed to ascertain initial suitability should be agreed and written down before work commences. Examples of such activities are design reviews, examination of equipment, and witnessing of commissioning tests prior to operation. Similar activities also need to be performed for temporary or mobile equipment;
being clear that a review of the duty holder's assurance strategy and processes is an integral part of the ICP activities.

Dutyholder implementation of ICP activity

The verification process applies throughout the asset life cycle. It needs to consider ongoing modification to SCEs as well as the effects of maintenance backlogs, inhibits, deferrals etc. Effective verification systems have been shown to operate where dutyholders:

carry out enough assurance activities to confirm that:
- the ICP's competence is relevant to the SCEs;
- the team deployed by the ICP have the necessary in-depth and cross- discipline competences;
- continuing competence is being ensured;
keep the ICP informed of all relevant changes;
ensure that the ICP makes a robust technical assessment of each SCE during each phase of the asset life cycle, eg design, construction etc;
maintain effective communications on SCE suitability between the ICP and the technical authorities.

Monitoring and auditing of the scheme by the dutyholder

Senior management monitoring and auditing of the delivery of the verification scheme activity is essential to ensure the timely and satisfactory completion of verification. Examples of such activities are:

monitoring:
- the timely and satisfactory completion of verification activities;
- the closure of actions and comments arising by the ICP;
- the performance trending of SCEs;
providing visible access to action tracking for all system participants (eg a web-based system or one which is integrated into the maintenance system with automatic actionee reminder emails);
ensuring that meaningful reviews take place at regular intervals, including all the key stakeholders and members of the leadership teams of both organisations;
conducting independent audits of the scheme, including dutyholder and ICP team competences.

Specific considerations

Give further consideration to designing and implementing the verification arrangements for the following specific situations:

where more than one ICP body is used, the interface and communications between all parties should be written down, together with clear roles and responsibilities. Confirmation should also be sought through monitoring and auditing that communication arrangements are effective and key personnel are competent;
for projects or major modifications there should be a clear reporting requirement directly back to the dutyholder, not just to the contractor;
when an asset changes ownership or the ICP changes, ICP activities should be reviewed.