Offshore Major Accident Regulator

Offshore Inspection Guide – Aviation (Helideck Operations) Open Government Status Fully Open Publication Date June 2019 Review Date Oct 2026 Review History Date Changes Oct 2023 Revision 1 Jun 2019 First Publication

Target Audience ED Offshore Inspectors / ED Specialist Inspectors

Contents • Summary • Introduction • Action • Background • Organisation Targeting Resources Recording & Reporting • Appendices Appendix 1: Pre Visit information request Appendix 2: Safe management of helideck operations Appendix 3: Helideck team competence Appendix 4: Helideck certification Appendix 5: Personal Protective Equipment/ Emergency PPE and life-saving appliances Appendix 6: Access/Egress routes and Muster Appendix 7: Controlled use of airspace – DRONE inspections Appendix 8: Wave off lights and ER plans Appendix 9: Application of EMM and Dutyholder performance assessment Appendix 10: Glossary of Terms, Abbreviations and Definitions • Further References

Summary

The HSE regulates the provision of suitable arrangements for a safe operating environment for helicopters on or in the vicinity of installations, including the delivery of arrangements for dealing with emergencies, in order to comply with current aviation standards. Regulating for this includes the acceptance of duty holders’ safety cases, which shows that these have been met.

Whilst most areas of aviation safety are regulated by the Civil Aviation Agency (CAA) in general terms the CAA regulate personnel in the aircraft and where it lands; whilst the HSE regulates the safety of the people working on the helideck and installation to support the aircraft operations. This is discussed in detail later in the guidance.

This guide outlines an approach to inspection of duty holder’s arrangements for Aviation safety and the current key areas that inspectors should consider when inspecting this topic offshore. It also sets out criteria for satisfactory and unsatisfactory performance against which the duty holder performance may be rated for each of these areas. References are made to technical standards and guidance that inspectors will use to form opinion for legal compliance.

NOTE - This guide does not address Marine or other Emergency Response operations, which also form part of the remit of Emergency Response Marine and Aviation. These topics are subject of a separate Inspection Guide. It should be used alongside the ED Inspection Guide Offshore: Inspection of Emergency Response (ER).

Introduction

The aim of this Inspection Guide (IG) is to provide information and guidance to offshore inspectors to support the delivery of consistent and effective safety and environmental critical element (SECE) management and assurance. It does this by highlighting key areas to be covered during inspections, providing a framework for inspectors to judge compliance, assign performance ratings, and decide what enforcement action to take should they find legislative breaches. In doing so, it complements HSE’s Enforcement Policy Statement (EPS) and Enforcement Management Model (EMM).

This guide outlines HSE’s ER: Aviation topic intervention practices undertaken during onshore and offshore inspection. The topic breaks down into eight core inspection areas as follows:

1. Prevention of Fire and Explosion, and Emergency Response (PFEER) 2. Safe management of helideck operations. 3. Emergency Response Plan 4. Personal Protective Equipment/Life Saving Appliances (PPE/LSA) 5. Helideck team competence 6. Helideck certification 7. Helideck Access/Egress Routes and Muster 8. Controlled use of airspace – DRONE inspections

This guidance is designed to promote a consistent approach to the inspection of the ER: Aviation topic. An overview of each of the core areas is provided in Appendices. The effectiveness of each of the above systems is key to securing effective aviation safety, to minimise and mitigate the impact of major accident events.

Action Inspection of this topic should include not only the eight core areas themselves but also an overview of the whole ER: Aviation Safety to ensure a consistent and complete assessment of control measures. Inspection of some core areas will require input from the ER Topic specialism where there are technical issues beyond the competence of the IMT inspector.

There should be in place suitable Performance Standards, Verification Schemes and, where necessary, Written Schemes of Examination for the systems and equipment that falls within the scope of the ER: Aviation Safety topic.

Success criteria for each core inspection area are contained in the Appendices to this guide. In some instances, certain success criteria will not be applicable, and inspectors should make a judgement regarding which are relevant in each case. If success criteria are not met, inspectors should assess how serious the consequences of failure to comply could be. This will inform their decision making in terms of the performance ratings that they assign and the enforcement action they take.

When carrying out inspections covered by this guidance inspectors should:

• Check the key issues against their success criteria in Appendices 1 to 7; • Use the generic performance descriptors in Appendix 7 to determine the appropriate performance rating and the initial enforcement expectation to use alongside the EMM if appropriate. • Consider how and when the issues raised during an inspection are to be closed out and recorded using the COIN Case issues tab;

Where occupational health, safety and welfare concerns are encountered during an inspection, deal with such issues as a matter of routine and apply existing standards to determine what action to take in each case according to HSE's EPS and EMM.

Background

Due to the uniqueness of the offshore environment where access to the landing areas are severely restricted a system has been put in place to ensure that helicopter landing areas are safe as are the teams working on them and personnel transiting them, this is achieved by a safe command and control safe system of work from the installation.

Amongst this legislation, the Offshore Installations (Prevention of Fire, Explosion and Emergency Response) Regulations 1995 (PFEER) specify the goals for preventative and

protective measures to manage fire and explosion, and for securing emergency response. They place the responsibility to put measures in place to achieve these goals on one person – the duty holder.

• Regulation 4 places a general duty on a duty holder to take appropriate measures with a view to protecting persons on the installation from fire and explosion; and to securing effective emergency response.

• Regulation 5 requires an assessment to be undertaken to identify major accident hazards, to evaluate related risks and to identify measures necessary to protect people and provide means of evacuation, escape and rescue.

• Regulation 6 requires the duty holder to anticipate and be prepared for emergencies. ER preparations should include arrangements for: o Provision of sufficient competent personnel to be in attendance at the helicopter landing area during helicopter movements. o Provision of adequate training and instruction to all personnel in appropriate actions to take in an emergency.

• Regulation 7 requires the duty holder to ensure that the correct equipment adequate to deal with a range of reasonably foreseeable accident scenarios is provided for helicopter emergencies. Any equipment that may be required in the event of an accident involving a helicopter should be readily identifiable and protected from the elements. It should be located so that it is readily accessible for rapid deployment on the helideck.

• Regulation 8 requires the duty holder to formulate a plan which documents the organisation and arrangements for dealing with an emergency on the installation.

• Regulation 12 requires the duty holder to take appropriate measures to be able to limit the impact of an emergency

• Regulation 17 requires the duty holder to ensure that effective means for the recovery and rescue of people on or near the installation are in place that these measures offer a good prospect of recovery, and that ensure persons recovered / rescued are taken to a place of safety.

• Regulation 18 requires the duty holder to provide appropriate Personal Protective Equipment (PPE) and Life Saving Appliances (LSA) for use in the event of an emergency.

The other legislation that directly relate to offshore aviation is the Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995. The regulations define certain areas that must be followed regarding helideck operations.

• Regulation 4 covers the requirements of appointing a HLO on a normally unmanned installation (NUI).

• Regulation 7 ensures that equipment necessary for use in the event of an accident involving a helicopter is kept readily identifiable and protected from the elements, near to the helicopter landing area. The equipment should be adequate to deal with a range of reasonably foreseeable accident scenarios and be located so that it is readily accessible for rapid deployment on the helideck, to enable the timely and effective rescue of persons involved in an accident.

• Regulation 8 allows the OIM to discharge part of his duty to the HLO as so far as is necessary to enable him to perform his function. By doing this it ensures that all personnel on the installation must cop-operate with the HLO to assist him to complete his duty safely. But it does not allow for the OIM to evade his responsibilities.

• Regulation 11 The duty holder must ensure that comprehensible written instructions are provided and procedures are observed on helideck operations. This must be brought to the attention of every person who is to do anything to which that part relates.

• Regulation 12 when carrying out helicopter operations on NUI, the duty holder must ensure that there are effective communications in place between the offshore installation and the shore, vessels, aircraft and other installations in the area that could provide the helicopter pilot with the operational conditions (eg wind speed and direction) on the installation involved, to assist him with the landing or take-off.

• Regulation 13 the duty holder must appoint a competent person to be in control of helideck operations on the installation (HLO). The HLO must remain in control of the helideck throughout all helideck operations and ensure that all the procedures are followed, areas secure, to ensure that all take-off and landing are as safe as possible, so far as is reasonably practicable.

• Regulation 14 the duty holder should collect and record meteorological and oceanographic information that relates to the motion of the offshore installation. This is to secure the safe helicopter operations on and near the installation.

All legislation is available to download from http://www.legislation.gov.uk/. A list of applicable HSE publications, e.g. Approved Code of Practice, is also provided with these documents available from http://www.hse.gov.uk/.

Role of the CAA

Under the Civil Aviation Act 2012 (reference 1), the CAA is responsible for the operation of the Air Navigation Order (ANO) (reference 2).

Under the ANO, the CAA regulates helicopter transport for the offshore industry within the UK Continental Shelf (UKCS) and ensures that the helicopter operators meet certain standards to be able to operate.

The airworthiness of the aircraft is governed by the issue of an Air Operator’s Certificate (AOC). For an AOC to be issued the helicopter and its operator must meet the required technical and operational standards. They must also produce detailed operational procedures in the company’s Operations Manual, demonstrating compliance with the ANO being published. All helicopter operators must hold an AOC to be able to transport members of the public.

Under the ANO, the CAA places a duty on helicopter operators to permit flights only to suitable landing areas and to satisfy themselves that a safe operating environment is in place.

The landing area offshore is known as the helideck, which must be ‘fit for purpose’ – i.e. adequately staffed and equipped for each take-off and landing to ensure so far as reasonably practicable, the safety of the aircraft and its passengers.

The equipment requirements are outlined in CAP437, which is the primary standard recognized by HSE. Secondary management and operation Guidelines are provided in the OGUK guide.

CAP 722 Unmanned aircraft System Operations in UK Airspace – guidance and policy (reference 3).

Role of the HCA

As previously mentioned, the ANO places the duty on the Helicopter operators ‘to ensure that the areas they are landing on are suitable’. Due to the remote location of the installation helidecks they are operating to, they discharge their duty of care through an inspection programme undertaken on their behalf by the Helideck Certification Agency (HCA) (reference 3).

The HCA bi-annually inspects / verifies helidecks and related their facilities against CAP 437 and certifies when these requirements are met. The HCA may also place limitations, (sometimes known as operational constraints) on the helideck, such as a restriction on landing weights and take-off directions due to an obstacle on the installation, like a crane.

Role of the HSE

HSE ER inspections should ensure that duty holders are complying with all relevant Health and Safety legislation on an around the helideck. Within the regulations there are additional requirements to ensure that there are suitable arrangements and a safe operating environment for helicopters when on the installation and within the 500 metre zone.

Due to the close regulatory boundaries in this area with the CAA, a Memorandum of Understanding (MoU) has been drawn up between the two regulators, (Reference 5). In the MoU it shows that the CAA will be responsible for setting the functional specification for offshore helidecks. The HSE will ensure that these are delivered by the installation's structure and systems, and during aviation operations, to influence the safe management of helideck operations.

The areas that the HSE inspect include items such as • The arrangements to deal with an aviation emergency, • The safety of personnel on the helideck. • The helideck and its operations comply with current aviation standards laid down by the CAA, this includes the acceptance of duty holders’ safety cases, which shows that these have been met.

In principle, the CAA regulates people in the aircraft and where it lands and the HSE regulates the safety of the people working on the helideck to support the aircraft operations. Further advise can be found in the HSE document ‘How offshore helicopter travel is regulated’, (reference 6)

Within the (Management and Administration) Regulations 1995 (MAR) (reference 7) there are a number of regulations that ensure that the installations provide certain provisions, data recording and personnel to support aviation operations.

The CAA regulations are held in Civil Aviation Publications (CAPs) the main one that details the requirements of offshore helidecks is the CAP 437 (reference 8), Standards for offshore helicopter landing areas.

Organisation

Targeting Inspections should be carried out in conjunction with planned Emergency Response Inspections. Although inspections may be carried out at any installation it is particularly important to carry this out where there are known issues that may affect ER: Aviation Safety, such as installations where

there is a low Persons On board (POB) count. It is essential to ensure that duty holders are robust in their assessment of the implications of these factors and that suitable mitigations are in place and that cumulative risk factors have been considered.

Timing Inspectors should undertake ER: aviation inspections as part of the agreed ED offshore intervention plan, when intelligence indicates intervention is necessary or when investigation due to incident is required.

Resources

Emergency Response Specialism has overall ownership of the Guide and takes the topic lead on inspecting ER: Aviation. Resource for the undertaking of ER interventions will come from Emergency Response Marine and Aviation discipline specialist inspectors supported by Inspection Management Team inspectors as appropriate.

Recording & Reporting

The duty holder performance ratings should be entered on the Inspection Rating Form (IRF) tab of the relevant installation Intervention Plan Service Order. Findings should be recorded in the normal post inspection report and letter.

APPENDICES

Appendix 1: Pre-Visit information request

Appendix 2: Safe management of helideck operations

Appendix 3: Helideck team competence

Appendix 4: Helideck certification

Appendix 5: Personal Protective Equipment/ Emergency PPE and life-saving appliances

Appendix 6: Access/Egress routes and Muster

Appendix 7: Controlled use of airspace – DRONE inspections

Appendix 8: Wave off lights and ER plans

Appendix 9: Application of EMM and dutyholder performance assessment

Appendix 10:Glossary of Terms, Abbreviations and Definitions

APPENDIX 1: PRE VISIT INFORMATION REQUEST

The information listed below is requested to inspect, prior to arriving on site.

• ICP Last 2 x reports for Emergency Response equipment relating to helideck operations

• List of currently open SECE deferrals and ERMA ORA’s relating to helideck operations

• Summary of recorded safety related near misses, incidents, and accidents for last 12 months, relating to helideck operations.

• Emergency Response Plan

• Emergency Response PS for Evacuation

• Emergency Response Drills and exercise plan relating to helideck operations

• Access to Local Register of competent persons relating to helideck operations

• PFEER 5 Assessment

• Helideck foam test certificate

• Helideck wave-off light test

• Adverse weather plan

APPENDIX 2: SAFE MANAGEMENT OF HELIDECK OPERATIONS

1. Fundamental Requirement The installation is responsible for ensuring the safety of aircraft operating within the 500-metre zone. Procedures should be established, and plant provided, as will secure, so far as is reasonably practicable, to ensure that helideck operations, including the landing and take-off of helicopters, refuelling, are without risks to health and safety. To oversee this a competent person is to be appointed as the Helicopter Landing Officer (HLO), who will be responsible for the day- to-day management of the offshore installation helideck, in control of the associated helideck operations, and the helideck crew.

2. Success Criteria To ensure that this is provided the helideck and surrounding area must be checked prior to any helicopter operations and any debris, that could potentially be caught in the down wash of the aircraft and cause damage to personnel, the aircraft or equipment, is removed. Any lose items such as trollies, (reference 9) must be secured. This duty is normally undertaken by the helideck crew overseen by the HLO. Everyone on or about the installation must co-operate with the HLO to enable him to perform his functions.

There will be restrictions on what equipment can be in use during helideck operations. The EERV must be closed up to the installation to ensure that a rapid response can be made to rescue personnel should a helicopter