Management System & Verification - Safety Case Assessment Template Work Instructions

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Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

MANAGEMENT SYSTEM & VERIFICATION – SAFETY CASE ASSESSMENT TEMPLATE

Work Instructions

Topic specialists should use this template to record their assessment of the Management System and Verification aspects of a safety case, including the
Corporate Major Accident Prevention Policy (CMAPP). Assessment should be against the requirements of SCR2015. Management System aspects that
relate specifically to environmental management are excluded. They are covered in a separate Environmental Operational Control template.

Exemplar Approach - This template should be used in accordance with the scope of the Assessment Instructions when the topic is included for assessment.
An exemplar approach may be sufficient if some material has been previously accepted and has not materially changed. For example a CMAPP or SEMS
from an existing, accepted safety case.

The template is one of a series covering all assessment topics, which together form a complete record of the safety case assessment and create evidence of
how the decision to accept the case, or not, was reached. The templates identify the specific regulatory requirements of SCR2015 for the topic and indicate
what the competent authority expects to find within a safety case to demonstrate that those requirements are met. The template complements the published
guidance that supports the regulations and topic sector guidance. The templates are available to promote transparency and assist duty holders in drafting
submissions.

Non Acceptance Issue - A Non Acceptance Issue (NAI) is a deficiency in the demonstration made within a safety case, which, if not resolved, will prevent the
case from being accepted under the relevant statutory provisions. Non Acceptance Issues must be sent via the portal to the duty holder requiring them to be
dealt with in the appropriate manner, giving the duty holder a clear understanding of how to address the deficiency.

Clarification - A Clarification is an explanation provided by a duty holder on request during assessment to enable the assessing Inspectors to be confident of
their interpretation of the information in a safety case. Clarifications are a routine part of assessment work and should be raised with a duty holder promptly.
Clarifications do not require formal communications. Communicating by telephone and email is sufficient. A meeting between the duty holder and relevant
topic specialists may also be appropriate in some circumstances for clarifications. Clarification is not a first stage before raising non-acceptance issues. Any
aspect that could credibly lead to a Non-Acceptance Issue should be raised as such in the first instance.

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

Relevant Pre-Existing Guidance

 APOSC Principles:
Factual information

 Principle 1
The factual information should meet the SCR2015 requirements and provide sufficient detail to support the arguments made in the case

Management of health and safety

 Principle 2
The safety case should demonstrate that the management system is adequate to ensure compliance with the relevant statutory provisions

 Principle 3
The management system should show an appropriate level of control during each phase of the installation life cycle, including design,
construction, commissioning, operation, decommissioning and dismantlement

Control of major accident hazards - Major accident hazard identification

 Principle 4
A systematic process should be used to identify all reasonably foreseeable major accident hazards that apply to the installation, together with
potential initiating events or sequences of events

Control of major accident hazards - Major accident risk evaluation

 Principle 5
The methodology and evaluation criteria adopted for major accident risk assessments should be clear

 Principle 8
The major accident risk evaluation should take account of human factors

 Principle 13
In deciding what is reasonably practicable, the case should show how relevant good practise and judgement based on sound engineering,
management and human factors principles have been taken into account

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

 Principle 12
Risk reduction measures identified, as part of the risk assessment, should be implemented if they are reasonably practical

Combined operations

 Principle 28
The management system should address the additional risks associated with combined operations

 Principle 30
A systematic approach should be taken to identifying and assessing any additional major accident hazards arising from combined operations.
These can be new hazards or changes to existing hazards.

 GASCET Chapters:
2.1 Safety management

 Safety management
The key features of a safety management system (SMS) are establishing a policy, linking objectives with this policy, making arrangements for
delivering the policy/objectives and measuring performance…

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

1. Corporate Major Accident Prevention Policy (CMAPP) Requirements

To comply with SCR2015 a duty holder must prepare a Corporate Major Accident Prevention Policy (CMAPP) in accordance with Schedule 2, which fulfils the
requirements of Regulation 7 and Schedule 1. The CMAPP must be included in the Safety Case, as per Regulation 17/18 and Schedule 6/7. The CMAPP
contained in the Safety Case must meet these legal requirements.

Assessment by the Management System & Verification Topic Assessor will make reference to these relevant regulatory requirements, aspects that are
specific to the Environment will be assessed by the Environmental Operational Control discipline.

a) SCR2015 Regulation 7 – Major accident prevention policy

NAI
Clarification
SCR2015 Regulatory Requirement
7—(1) This regulation applies only to a duty holder which is a body corporate or unincorporate.
(2) The duty holder must prepare in writing a policy (referred to in these Regulations as the “corporate major accident prevention policy”) which—
(a) establishes the overall aims and arrangements for controlling the risk of a major accident and how those aims are to be achieved and those
arrangements put into effect by the officers of the duty holder;
(b) covers the duty holder’s installations—
in external waters; and
outside the European Union.
(3) The corporate major accident prevention policy must address at least the particulars set out in Schedule 1 and must be prepared in accordance with the
matters set out Schedule 2.
(4) The corporate major accident prevention policy may in addition outline the commitment of the duty holder to mechanisms for effective tripartite
consultation.
(5) An operator, in preparing a corporate major accident prevention policy, must take account of the operator’s primary responsibility for, among other
things, the control of risks of a major accident that are a result of the operator’s operations and for continuously improving control of those risks so as to
ensure a high level of protection at all times.
(6) A duty holder must—
(a) implement the corporate major accident prevention policy throughout its offshore oil and gas operations; and
(b) set up appropriate monitoring arrangements to assure effectiveness of the policy.
(7) In this regulation and Schedule 1, “officer of the duty holder” in relation to—
(a) a body corporate, other than a limited liability partnership, means a director or secretary;
(b) a limited liability partnership, means a member;
(c) a partnership or a limited partnership, means a partner of that partnership or limited partnership; and
(d) a body unincorporate (other than a partnership or limited partnership), means a member of the body.
(8) In paragraph (7)(a) “director” has the meaning given in section 250 of the Companies Act 2006(1).
(9) In this regulation (but not this paragraph) a reference to a duty holder or operator includes a reference to a well operator.

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

(10) Paragraph (2)(b) does not apply to a well operator.


Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Has the duty holder prepared a CMAPP which establishes the overall aims
and arrangements for controlling the risk of a major accident and how
those aims are to be achieved and those arrangements put into effect by
the officers of the duty holder
Are the requirements of Schedule 1 met. Details of assessment to be recorded in Sections 1 c)
Is there a commitment for tripartite consultation between the competent
authority, duty holders and workers’ representatives? e.g. OMAHAC
(previously OIAC) or equally as effective route (NB This is not an absolute
legal requirement)
(APOSC Principle 2)

b) SCR2015 Regulation 17(4) - Safety case for production installation – multiple installations / operators

SCR2015 Regulatory Requirement


17(4) Where, pursuant to paragraph (3), a safety case is to be prepared in relation to more than one production installation with different operators, there
must be included with the safety case—
(a) where one is required under regulations 7, a copy of the corporate major accident prevention policy of each operator;

Clarification
(a) …

NAI
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Where there is more than one production installation with different
operators covered by a single safety case the assessment outlined in
section 1, parts a) to d) must be repeated for each operator’s CMAPP.

Is more than one installation / operator covered by the safety case, if so do


all the CMAPPs meet the requirements?
(APOSC Principles 1&2)
c) SCR2015 Schedule 1 - Particulars to be addressed in a Corporate Major Accident Prevention Policy

Clarification

NAI
SCR2015 Regulatory Requirement
Schedule 1 - Particulars to be addresses in a Corporate Major Accident Prevention Policy

1. The responsibility of officers of the duty holder for ensuring, on a continuous basis, that the corporate major accident prevention policy is suitable,
implemented, and operating as intended.
2. Formal command and control systems that include officers and senior management of the duty holder.

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

3. Measures for building and maintaining a strong safety culture with a high likelihood of continuous safe operation.
4. The approach to competency at all levels of the duty holder’s organisation.
5. Measures for rewarding and recognising desired behaviours.
6. The evaluation of the duty holder’s capabilities and goals.
7. The extent and intensity of process auditing.
8. Measures for maintenance of safety and environmental protection standards as an organisational core value.
9. The extent to which the particulars in paragraphs 1 to 8 are applied in the duty holder’s offshore oil and gas operations conducted outside the
European Union.
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Are the particulars identified in Schedule 1 included in the CMAPP?

d) SCR2015 Schedule 2 - Matters in accordance with which the Corporate Major Accident Prevention Policy … must be
prepared

SCR2015 Regulatory Requirement


Schedule 2 - Matters in accordance with which the Corporate Major Accident Prevention Policy … must be prepared

1. The need to take appropriate measures to ensure as far as reasonably practicable that there is no unplanned escape of hazardous substances from
pipelines, vessels and systems intended for their safe confinement. In addition, the need to ensure that no single failure of a containment barrier can
lead to a major accident.
2.  The need to pay particular attention to evaluation of the reliability and integrity requirements of all safety and environmental-critical systems and
base inspection and maintenance systems on achieving the required level of safety and environmental integrity.

Clarification
3. …

NAI
4. The need to ensure there is a suitable framework for monitoring compliance with all relevant statutory provisions by incorporating statutory duties
in respect of major hazards control and environmental protection into standard operating procedures.
5. The need to pay particular attention to building and maintaining a strong safety culture with a high likelihood of continuous safe operation,
including with regard to securing cooperation of employees and contractors through, among other things—
(b) visible commitment to tripartite consultations and actions arising from them;
(c) encouraging and rewarding reporting of accidents and near-misses;
(d) working effectively with elected safety representatives; and
(e) protecting whistleblowers.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Does the Safety Case contain a statement relating to the aspects that
were considered when the CMAPP was developed and does it address

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

the matters identified in Schedule 2?

Where the safety case does not contain such a statement is it apparent
that the matters identified in Schedule 2 were considered when the
CMAPP was prepared?

e) SCR2015 Schedule 6 / 7 - Particulars to be included in a safety case for the operation of a production / non production
installation

 Sch 6-3 / Sch 7-3: Corporate major accident prevention policy (CMAPP)

SCR2015 Regulatory Requirement

Clarification
A copy of the operator’s / owner’s corporate major accident prevention policy.

NAI
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Is there a copy of the operator’s / owner’s corporate major accident
prevention policy in the safety case?

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

2. Management System Requirements

To comply with SCR2015 a duty holder must prepare a Safety and Environmental Management System (SEMS) in accordance with Schedule 2, which fulfils
the requirements of Regulation 8 and Schedule 3. An adequate description of the SEMS must be included in the Safety Case, as per Regulation 17/18 and
Schedule 6/7. The description contained in the Safety Case should demonstrate that these legal requirements are being met.

Assessment by the Management System & Verification Topic Assessor will make reference to these relevant regulatory requirements, aspects that are
specific to the Environment will be assessed by the Environmental Operational Control discipline.

a) SCR2015 Regulation 8 – Safety and environmental management system

SCR2015 Regulatory Requirement


8—(1) The duty holder must prepare a document setting out its safety and environmental management system.
(2) In the case of a body corporate or unincorporate, the safety and environmental management system must include the organisational structure,
responsibilities, practices, procedures, processes and resources for determining and implementing the corporate major accident prevention policy.
(3) The safety and environmental management system is to be integrated with the overall management system of the duty holder.
(4) The safety and environmental management system must address the particulars in Schedule 3 and must be prepared in accordance with the matters set
out in Schedule 2.

Clarification
(5) The document setting out the safety and environmental management system must include a description of—

NAI
a) the organisational arrangements for the control of major hazards;
b) the arrangements for preparing and submitting documents under the relevant statutory provisions; and
c) the verification scheme (which description must comply with regulation 13(1)).
(6) This regulation applies to a well operator—
a) as if the reference to the duty holder in paragraph 1 were a reference to a well operator; and
b) as if the reference to the description of the verification scheme in paragraph 5c were a reference to the description of the well examination
scheme (which description must comply with regulation13(2)).
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Assessment against the requirements of Regulations 8 is limited to management aspects, the detail of the issues requiring managed will be covered by other relevant disciplines.
This whole section is a new requirement of the 2015 regulations. Some aspects may have been previously covered in a safety case as a result of the operator addressing SCR05 Regulation 12, and
guidance such as APOSC and GASCET. The inspector should confirm the case addresses these specific aspects to ensure it is acceptable under the new regulatory regime.
Does the description of the SEMS contained in the safety case
demonstrate that the duty holder has a document setting out the safety
and environmental management system?
Does the description of the SEMS demonstrate that the following are
addressed in order to implement the CMAPP:
 organisational structure,
 responsibilities practices,

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

 procedures,
 processes and
 resources
(APOSC Principle 2)
Does the description of the SEMS demonstrate that it is integrated with the
overall management system of the duty holder?
Does the safety and environmental management system address the Detail of assessment to be recorded in Sections 2 g)
particulars in Schedule 3.
Does the description of the SEMS demonstrate that the following are
addressed:
 organisational arrangements for the control of major
hazards
(APOSC Principles 2-7)
 arrangements for preparing and submitting documents
under the relevant statutory provisions
 a verification scheme, the description of which complies Detail of assessment to be recorded in Sections 3 a)
with Reg 13(1)

b) SCR2015 Regulation 16 - Management and control of major accident hazards

SCR2015 Regulatory Requirement


16.—(1) A duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraph (2), include in the safety case sufficient
particulars to demonstrate that—
(a) the duty holder’s management system is adequate to ensure—
(i) that the relevant statutory provisions will, in respect of matters within the duty holder’s control, be complied with; and
(ii) that the management of arrangements with contractors and sub-contractors is satisfactory;
(b) the duty holder has established adequate arrangements for audit and for the making of reports thereof;

Clarification
(c) all hazards with the potential to cause a major accident have been identified;
(d) all major accident risks have been evaluated, their likelihood and consequences assessed, including any environmental, meteorological and seabed

NAI
limitations on safe operations, and that suitable measures, including the selection and deployment of associated safety and environmental-critical
elements have been, or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with; and
(e) in the case of a non-production installation, that all the major hazards have been identified for all operations the installation is capable of performing.
(2) Paragraph (1) only requires the safety case to include the particulars referred to in that paragraph to the extent that it is reasonable to expect the duty
holder to address them at the time of sending the safety case to the competent authority.
(3) In this regulation, “audit” means systematic assessment of the adequacy of the management system to achieve the purpose referred to in paragraph (1)(a)
carried out by a person is sufficiently independent of the system (but who may be employed by the duty holder) to ensure that such assessment is objective.
(4) …
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Assessment against these criteria is limited to management aspects, the detail of the issues requiring managed will be covered by other relevant disciplines.

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

The following criteria include new aspects to existing requirements relating to environmental considerations. The duty holder will need to have reviewed their systems and the content of their safety
case to confirm it meets the full requirements. The inspector should confirm the safety case addresses these specific aspects to ensure it meets the requirements and is acceptable under the new
regime.
Does the safety case demonstrate that the management system is
adequate to ensure:
 relevant statutory provisions will be complied with?
(APOSC Principle 2)
 there is satisfactory management of contractors and
subcontractors?
(APOSC Principle 2)
 there are arrangements for auditing and reporting those audits? Detail of assessment to be recorded in Sections 2 g)
(APOSC Principle 2)
 all hazards with the potential to cause MAs have been identified by Detail of assessment to be recorded in Sections 2 g)
the use of a systematic approach which includes all initiating and
sequence events?
(APOSC Principle 4)

c) SCR2015 Regulation 17(4) - Safety case for production installation – multiple installations / operators

SCR2015 Regulatory Requirement


17(4) Where, pursuant to paragraph (2), a safety case is to be prepared in relation to more than one production installation, each with a different operator,

Clarification
there must be included with the safety case—

NAI
a) …
b) an adequate description of the safety and environmental management system of each operator; and
c) …
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Where there is more than one production installation with different
operators covered by a single safety case the assessment outlined in
section 2 must be repeated for each operator’s management system.

Is there more than one installation / operator and do the descriptions of


each management system meet the requirements?
(APOSC Principles 1&2)

d) SCR2015 Regulation 27 – Keeping of documentation (Non-production cases only)

NAI
SCR2015 Regulatory Requirement
27.—(1) A duty holder must—
(a) ensure that, when the duty holder sends—

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

Clarification
(i) …
(ii) the safety case, in the case of a non-production installation,
to the Competent authority, it is notified of an address in Great Britain for the purposes of sub-paragraphs (b) and (e) below;

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Is a UK address identified in either the Safety Case, or with any
information supplied with the submission, that will be used for the keeping
of relevant documentation?

e) SCR2015 Regulation 29 – Duty to Control Risk

SCR2015 Regulatory Requirement


29 — (1) Where an activity carried out by a duty holder significantly increases the risk of a major accident the duty holder must take suitable measures to
ensure that the risk is reduced as low as is reasonably practicable.

Clarification
(2) The measures referred to in paragraph (1) include, where necessary, suspending the relevant activity until the risk is adequately controlled.

NAI
(3) The duty holder must notify the competent authority where it has taken measures under paragraph (1).
(4) The duty holder must comply with paragraph (3) immediately after, and in any event no later than 24 hours after, adopting the measures.
(5) In this regulation (but not this paragraph) a reference to a duty holder includes a reference to a well operator.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met – Assessment Comments
Has the DH confirmed that, in the event an activity significantly increases
the risk of a major accident, a system exists to ensure suitable measures
will be taken to reduce that risk to ALARP?

These measures include, where necessary, suspending the relevant


activity until the risk is adequately controlled.
Does the DH have arrangements in place to ensure such events are
notified to the Competent Authority (OSDR)?

f) SCR2015 Schedule 2 - Matters in accordance with which the … Safety and Environmental Management System must be
prepared

Clarification

NAI
SCR2015 Regulatory Requirement
Schedule 2 - Matters in accordance with which the … Safety and Environmental Management System must be prepared

1.  The need to take appropriate measures to ensure as far as reasonably practicable that there is no unplanned escape of hazardous substances from

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

pipelines, vessels and systems intended for their safe confinement. In addition, the need to ensure that no single failure of a containment barrier can
lead to a major accident.
2.  The need to pay particular attention to evaluation of the reliability and integrity requirements of all safety and environmental-critical systems and
base inspection and maintenance systems on achieving the required level of safety and environmental integrity.
3. …
4. The need to ensure there is a suitable framework for monitoring compliance with all relevant statutory provisions by incorporating statutory duties
in respect of major hazards control and environmental protection into standard operating procedures.
5. The need to pay particular attention to building and maintaining a strong safety culture with a high likelihood of continuous safe operation,
including with regard to securing cooperation of employees and contractors through, among other things—
a) visible commitment to tripartite consultations and actions arising from them;
b) encouraging and rewarding reporting of accidents and near-misses;
c) working effectively with elected safety representatives; and
d) protecting whistleblowers.
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
This whole section is a new requirement of the 2015 regulations. Some aspects may have been previously covered in a safety case as a result of the operator addressing SCR05 Regulation 12, and
guidance such as APOSC and GASCET. The inspector should confirm the case addresses these specific aspects to ensure it is acceptable under the new regulatory regime.
Does the Safety Case contain a statement relating to the aspects that
were considered when the SEMS was developed and does it address the
matters identified in Schedule 2?

Where the safety case does not contain such a statement is it apparent
that the matters identified in Schedule 2 were considered when the SEMS
was prepared?

g) SCR2015 Schedule 3 - Particulars to be addressed in a Safety and Environmental Management System

Clarification

NAI
SCR2015 Regulatory Requirement
Schedule 3 – Particulars to be addressed in a Safety and Environmental Management System

1. Organisational structure and personnel roles and responsibilities.


2. Identification and evaluation of major hazards as well as their likelihood and potential consequences.
3. …
4. Controls of the major hazards during normal operations.
5. Emergency planning and response.
6. ….
7. Management of change.
8. Monitoring of performance.

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

9. Audit and review arrangements.


10. The measures in place for participating in tripartite consultations and how actions resulting from those consultations are put into effect.
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
This whole section is a new requirement of the 2015 regulations. Some aspects may have been previously covered in a safety case as a result of the operator addressing SCR05 Regulation 12, and
guidance such as APOSC and GASCET. The inspector should confirm the case addresses these specific aspects to ensure it is acceptable under the new regulatory regime.
Does the description of the SEMS show that the following have been Detail of assessment to be recorded in Sections 2 a)
addressed:
 the organisational structure and the personnel roles and
responsibilities
(APOSC Principle 2)

 the identification and evaluation of major hazards as well as


their likelihood and potential consequences (management
aspects only)
(APOSC Principle 2)
 controls of the major hazards during normal operations (eg
maintenance management, CoW, ORA)
(APOSC Principle 2)
 emergency planning and response
(APOSC Principle 2)
 management of change
(APOSC Principle 2)
 monitoring of performance
(APOSC Principle 2)
 audit and review arrangements
(APOSC Principle 2)
 measures are in place for participating in tripartite
consultations and actions resulting from those consultations
are put into effect?
(APOSC Principle 2)

h) SCR2015 Schedule 6 / 7 - Particulars to be included in a safety case for the operation of a production / non production
installation

 Sch 6-4 / Sch 7-4: Summary of worker involvement

NAI
Clarification
SCR2015 Regulatory Requirement
A summary of any worker involvement in the preparation of the safety case, including how any safety representatives for that installation were consulted with
regard to the revision, review or preparation of the safety case pursuant to regulation 23(2)(c)(i) of the Offshore Installations (Safety Representatives and
Safety Committees) Regulations 1989(a).

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Does the Safety case contain a summary of the worker involvement in the
preparation of the safety case and does it demonstrate that the Safety
Representatives were consulted during the preparation, review or revision
of the case?
Whilst this is an existing requirement for all submissions the duty holder
must have involved the workforce in the preparation of the transitional
case and the consultation undertaken should be clear in the submission.

 Sch 6-5 / Sch 7-5 Description of safety and environmental management system (SEMS)

SCR2015 Regulatory Requirement

Clarification
An adequate description of the operator’s / owner’s safety and environmental management system, including information from it that is relevant to the

NAI
production / non-production installation.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Is there an adequate description of the safety and environmental Detail of assessment to be recorded in Sections 2 a), 2 f) & 2 g)
management system, including information that is relevant to the
production installation?

As the assessment of the adequacy of the SEMS has been based on the
description contained in the safety case, compliance with this section
should refer to the assessment conducted under Regulation 8 and
enforced under regulation 17.

 Sch 6-7: Matters raised during Design Notification / Relocation Notification (Production Installation ONLY)

SCR2015 Regulatory Requirement

Clarification
A description of the extent to which the operator has taken into account any matters raised by the competent authority pursuant to regulations 15(2) and

NAI
or19(2).
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
In the description of the matters raised by the competent authority when
the Design or Relocation Notification was submitted, are there any items
that are specific to the CMAPP, management system and/or verification
scheme?
Is the DH response to these items adequate?

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Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

 Sch 6-23 / Sch 7-19: Particulars of combined operations (CO)

IMT Focal Point Inspector


SCR2015 Regulatory Requirement
Particulars of any combined operations which may involve the installation, including

SC Co-ordinator
a) a summary of the arrangements in place for co-ordinating the management systems of all duty holders involved in any such combined operation;
b) a summary of the arrangements in place for a joint review of the safety aspects of any such combined operation by all duty holders involved, which
must include the identification of hazards with the potential to cause a major accident and the assessment of risks which may arise during any such
combined operation;
c) …
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Do the particulars relating to combined operations include:
 the arrangements in place for co-ordinating the management
systems of all duty holders involved?
( APOSC Principle 28)
 the arrangements in place for the joint review of the safety
aspects by all duty holders involved?
 the identification of hazards with the potential to cause a
major accident and the assessment of risks which may arise?
(APOSC Principle 30)

i) SCR2015 Schedule 8 - Particulars to be included in a current safety case in respect of the dismantling of a fixed
installation

 Sch 8-1: Name and address (Dismantlement cases ONLY)

SCR2015 Regulatory Requirement

Clarification
The name and address of the operator of the installation.

NAI
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Is the name and address of the operator given for dismantlement given &
does it give rise to any concerns? E.g. is it different from that expected?

 Sch 8-2: Persons on board (Dismantlement cases ONLY)

NAI
SCR2015 Regulatory Requirement

TRIM: 2018/0389937 Revised: 30/11/2018 Page 15 of 19


Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

Clarification
The maximum number of persons expected to be on the installation at any time during its dismantling.

Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Is the maximum number of persons expected to be on the installation at
any time during its dismantling given & does it give rise for concern? e.g.
will it increased or decrease? How are roles and personnel managed?

 Sch 8-3: Worker involvement (Dismantlement cases ONLY)

SCR2015 Regulatory Requirement

Clarification
A summary of any worker involvement in the revised safety case, including how any safety representatives for that installation were consulted with regard to

NAI
the revision of the safety case pursuant to regulation 23(2)(c)(i) of the Offshore Installations (Safety Representatives and Safety Committees) Regulations
1989.
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Is there a summary of worker involvement in the dismantlement safety
case, including how any safety representatives for that installation were
consulted with regard to the revision of the safety case and does it give
rise for concern?

 Sch 8-4: Dates (Dismantlement cases ONLY)

Clarification
SCR2015 Regulatory Requirement
The dates on which dismantling is expected to commence and finish.

NAI
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Are the dates on which dismantling is expected to commence and finish
contained in the safety case & do they give rise for concern?

TRIM: 2018/0389937 Revised: 30/11/2018 Page 16 of 19


Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

3. Verification System Requirements

To comply with SCR2015 a duty holder must prepare a Verification Scheme which fulfils the requirements of Regulations 9 and 10 and Schedule 4, Part 1. A
description of the scheme must be included in the Safety Case, as per Regulation 17/18 and Schedule 6/7. The description must fulfil the requirements of
Regulation 13 and demonstrate that the legal requirements are being met.

Assessment by the Management System & Verification Topic Assessor will make reference to these relevant regulatory requirements, aspects that are
specific to the Environment will be assessed by the Environmental Operational Control discipline.

a) SCR2015 Regulation 13 – Description of verification scheme

SCR2015 Regulatory Requirement


13-(1) For the purposes of these regulations, a description of the verification scheme complies with this regulation if it includes—
(a) a description of the criteria for selection of the verifier to carry out functions under the scheme;
(b) a description of the means of verifying that the safety and environmental-critical elements and any specified plant remain in good repair and
condition; and

Clarification
(c) details of the arrangements to carry out the functions under the scheme including—

NAI
(i) the examination and testing of the safety and environmental-critical elements by the verifier;
(ii) the verification of the design, standard, certification or other system of conformity of the safety and environmental-critical elements;
(iii) the examination of work in progress;
(iv) the taking of remedial action by the duty holder;
(v) the reporting of any instances of non-compliance of the duty holder with the standards of the scheme; and
(vi) the review of the scheme throughout the lifecycle of the installation.
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Is there a description contained in the safety case of the criteria for
selecting the verifier?
Is there a description of the means of verifying that the SECEs and
specified plant remain in good condition and repair?
Are details of the arrangements to carry out the functions under the
scheme included in the Case?
Do the arrangements described refer to all of the following functions:

 the examination and testing of the SECEs by the verifier?


 the verification of the design, standard, certification or other
system of conformity of the SECEs?
 the examination of work in progress?
 the taking of remedial actions by the duty holder?

TRIM: 2018/0389937 Revised: 30/11/2018 Page 17 of 19


Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

 the reporting of any instances of non-compliance?


 the review of the scheme throughout the lifecycle of the
installation.

b) SCR2015 Regulation 17(3) / 18(2) - Safety case for production / non-production installation – suitability of verification

SCR2015 Regulatory Requirement

Clarification
17(3) / 18(2) The operator / owner of a production / non-production installation must include with the safety case sent to the competent authority a statement,

NAI
made after considering any reports or reservations by the verifier under regulation 9(2)(d), (3)(b) and (4)(c), that the record of safety and environmental-
critical elements and their scheme of maintenance are or will be suitable.
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
This is a new regulatory requirement however verification schemes and specifically ‘suitability’ was included in SCR05 Regulation 2(5) although it did not extend to environmental aspects. The
inspector should confirm the case addresses this specific matter to ensure it is acceptable under the new regulatory regime.
Does the Safety Case include a statement by the operator / owner that,
after considering any reports or reservations by the verifier, the record of
SECEs and their scheme of maintenance are or will be suitable?

c) SCR2015 Schedule 6 / 7 - Particulars to be included in a safety case for the operation of a production / non production
installation

 Sch 6-6 / Sch 7-6: Verification

Clarification
SCR2015 Regulatory Requirement
A description of the verification scheme pursuant to regulation 13(1).

NAI
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
Is there a description of the verification scheme in the safety case that Detail of assessment to be recorded in Section 3 a)
meets the requirements of regulation 13(1)?

 Sch 6-8 / Sch 7-7: Main requirements of design

NAI
SCR2015 Regulatory Requirement
A description of the main requirements in the specification for the design of the installation and its plant, which must include—
a) …

TRIM: 2018/0389937 Revised: 30/11/2018 Page 18 of 19


Owner: ED7
Document Title : Management System & Verification – Safety Case Assessment Template

Case Title - [Safety Case Title] References - [COIN Case] / [CAP reference No]
Duty Holder – [Company Name] Topic Assessor – [Name]

Clarification
b) …
c) a description of how the duty holder has ensured, or will ensure, the suitability of the safety and environmental-critical elements;
d) …
Assessment Criteria / Minimum Information SC Ref Criteria Met / Not Met - Assessment Comments
 Is there a description of the main requirements in the specification for the
design of the installation and its plant?
Does that description include how the duty holder has ensured, or will
ensure, the suitability of the safety and environmental-critical elements?

TRIM: 2018/0389937 Revised: 30/11/2018 Page 19 of 19


Owner: ED7

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