The Offshore Emergency Response Inspection Guide Open Government Status Fully Open Publication Date October 2023 Review Date October 2026

(Inspection guides should be reviewed every three years – it may be necessary to review sooner in the event of legislative changes)

Review History Date Changes

October 2023 Reformatting and periodic content review – some operational standard and guidance updates June 2020 10 June 2020 Reformatting and revision of content, particularly regarding emergency command and control. Addition of Appendix on “Arrangements for Recovery and Rescue” October 2014 First Publication as Inspection of Evacuation Escape and Rescue (EER)

Target Audience OMAR Inspectors / ED Offshore Inspectors / ED Specialist Inspectors

Contents • Summary • Introduction • Relevant Legislation • Action • Background • Other relevant Inspection Guides • Specialist Advice Organisation Targeting Resources Recording & Reporting • Appendices Appendix 1: PFEER Regulation 5 assessment Appendix 2: Preparation and arrangements for command and control Appendix 3: Emergency response plan Appendix 4: Alarms and communication Appendix 5: Control of emergencies Appendix 6: Access / egress routes and mustering Appendix 7: Evacuation Appendix 8: Means of escape Appendix 9: Arrangements for recovery and rescue Appendix 10: Emergency PPE and life-saving appliances Appendix 11: Example Pre-visit Information request Appendix 12: Example Emergency Response Offshore Agenda Appendix 13: Glossary of terms, abbreviations and definitions Appendix 14: Application of the Enforcement Management Model (EMM) and dutyholder performance assessment

Summary This IG outlines an approach to the inspection of dutyholder’s arrangements with respect to the Offshore Emergency Response topic and the key areas that inspectors should consider when inspecting this topic. It also sets out the criteria for satisfactory and unsatisfactory performance factors against which dutyholder performance will be rated. Reference are made to technical standards and guidance that inspectors will use to form and opinion of legal compliance.

For convenience of analysis and action, it is normal to consider the management of ER under two headings. First, there are the overarching command and control capabilities of those charged with the management of emergencies; and second, there are issues of team and personal competence, ER equipment and external support arrangements that each form vital parts of the system.

This inspection guide (IG) outlines an approach to inspection of dutyholder arrangements for emergency response, and the key areas that inspectors should consider when inspecting this topic offshore.

Introduction The aim of this IG is to provide information and guidance to OMAR 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, and by 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 Enforcement Policy Statement (EPS) and Enforcement Management Model (EMM). References are made to technical standards and guidance that inspectors will use to form opinion for legal compliance.

Relevant Legislation • Offshore Installations (Prevention of Fire, Explosion and Emergency Response) Regulations 1995 (PFEER) • Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015 (SCR2015)

Action Inspectors should review relevant documentation (see Annex 13 Pre-visit Information Request) prior to the installation visit and test compliance during the installation visit against the “Success Criteria“ given in relevant Appendices)

Inspection of this topic should include not only the ten core areas themselves, but also an overview of the onshore and offshore emergency response plans to ensure a consistent and complete evaluation of the control measures in place.

In accordance with SCR2015 there should be in place suitable performance standards (PS), verification schemes and, where necessary, written schemes of examination (WSE) for the systems and equipment that fall within the scope of the ER topic.

Success criteria for each core inspection area are contained in the Appendices. 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 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 OMAR inspectors should • Check the key issues against their success criteria in Appendices 1 to 10 • Use the generic performance descriptors in Appendix 11 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.

Where ER-related concerns are encountered during an inspection, such issues should be dealt with by applying existing legal requirements/other relevant standards to determine what action to take in each case according to HSE's EPS and EMM.

Background

Offshore ER systems should be designed to mitigate the immediate aftermath of a lowfrequency event that has either escalated, or has the potential to escalate, into a major accident. ER systems

also have relevance to other high-consequence events that might affect only one or a small number of persons, for example, a person-overboard situation.

Lord Cullen’s report of the findings of the Public Inquiry into the Piper Alpha disaster raised a total of 106 recommendations - 41 of these relating directly to the ER topic area. The key Cullen recommendations were subsequently implemented in offshore-specific legislation.

Among 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 dutyholder.

• Regulation 4 places a general duty on a dutyholder 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 dutyholder to anticipate and be prepared for emergencies. ER preparations should include arrangements for o development and assessment of an effective emergency command structure (ECS) o provision of sufficient competent personnel to fulfil critical ER roles, and o provision of adequate training and instruction to all personnel in appropriate actions to take in an emergency

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

• Regulation 11 requires the dutyholder to make arrangements for giving warning in the event of an emergency.

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

• Regulation 14 requires the dutyholder to make provision of safe areas for people on the installation to be able to muster in the event of an emergency.

• Regulation 15 requires the dutyholder to have in place arrangements to make a safe evacuation of the installation.

• Regulation 16 requires the provision of means of escape should the evacuation system or parts of it fail.

• Regulation 17 requires the dutyholder 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 dutyholder to provide appropriate personal protective equipment (PPE) and lifesaving appliances (LSA) for use in the event of an emergency.

• Regulation 20 requires that sufficient life-saving appliances such as survival craft, life rafts, life buoys, life jackets etc. are made available for immediate use in sufficient numbers for the number of persons on board the installation.

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

An emergency response system can be considered to comprise two parts. 1. Emergency command and control, and 2. Emergency response systems including procedures, plant, and emergency response equipment.

ER procedures and provisions must reflect the ability of an installation to withstand an emergency, the risks from which are required to be demonstrated as reduced to ALARP under the safety case

assessment and acceptance procedures. ER arrangements must reflect the performance standards of the accepted safety case for mustering, for the endurance times of egress routes and temporary refuges, and for the for evacuation, escape and recovery / rescue of personnel.

Other relevant Inspection Guides There is significant overlap of the issues addressed in this IG with the those relating to controlling risk arising from offshore marine and aviation operations. The content of this guide should be considered alongside that included in OMAR Offshore Marine Operations and Offshore Aviation Operations IGs.

Specialist Advice Specialist advice should be sought from ED Emergency Response, Marine and Aviation Operations (ERMA) discipline in the following when considering enforcement / debate over relevant standards.

Organisation

Targeting

Inspections should be planned within the timescales set out by Energy Division (ED) divisional management. 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 emergency response such as

• Combined operations • Major work-over and construction projects • Sharing of recovery and rescue arrangements between installations, and • Changes in staffing arrangements and operating parameters such as during decommissioning and dismantling.

It is essential to ensure that dutyholders are robust in their assessment of the implications of these factors, that suitable mitigations are in place and that cumulative risk factors have been considered.

Timing

ERMA Topic Inspectors should undertake ER 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

ED Emergency Response, Marine and Aviation Operations (ERMA) discipline has overall ownership of this IG and takes the topic lead on inspecting ER. Resource for the undertaking of ER interventions will come from discipline specialist inspectors supported by OMAR inspection management team (IMT) regulatory inspectors as appropriate.

Recording & Reporting

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

Further References

1. Offshore Installations (Prevention of Fire and Explosion, and Emergency Response Regulations 1995 & ACOP L65

2. Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015 & Guidance L154 3. HSE Offshore Technology Report OTO 2002/021 Compatibility test protocol for lifejackets and immersion suits on offshore installation HSE Books 2002 4. HSE Offshore Technology Report OTO 2001/091 Inspecting and auditing the management of emergency response HSE Books 2001 5. HSE Research Report RR599 Overview of TEMPSC performance standards 6. HSE Offshore Information Sheet 10/2007 Testing of TEMPSC release gear 7. HSE Safety Notice 01/2006 Ensuring adequate safety during davit lifeboat drills testing and maintenance Revised 2017 8. HSE Offshore Information Sheet 6/2008 Ensuring the wearing of immersion suits in helicopter evacuation or escape to sea 9. HSE Offshore information sheet 12/2008 Big persons in lifeboats 10. HSE Offshore Information Sheet 1/2014 Training for Emergencies on Offshore Installations 11. Oil & Gas UK Guidelines for the Management of Emergency Response Issue 3, 2010 12. Oil & Gas UK Guidelines for the Management of Competence and Training in Emergency Response for Offshore Installations Issue 3, February 2010 13. Oil & Gas UK Emergency Response & Rescue Vessel Survey Guidelines Issue 7, May 2018 14. Oil & Gas UK Emergency Response & Rescue Vessel Management Guidelines Issue 6, May 2018 15. Oil & Gas UK Technical Note on Operations Assessment during Emergency Response and Rescue Vessel Unavailability HSTN005, January 2019 16. OEUK Guideline on Assurance of Evacuation Times by TEMPSC from Offshore Installations 17. Emergency Preparedness Offshore Liaison Group (EPOL) Integrated Offshore Emergency Response Version 4, August 2021 18. Energy Institute Guidelines for offshore oil and gas installations that are not permanently attended 2nd edition, November 2018 19. UK Search and rescue framework (UKSAR) 20. Step Change in Safety Totally enclosed motor propelled survival craft (TEMPSC) familiarisation guidance

Appendix 1

PFEER REGULATION 5 ASSESSMENT

1. Fundamental Requirement The dutyholder should have undertaken an assessment or assessments in accordance with PFEER Reg. 5; a summary of which should be in the installation’s safety case (Schedules 6 & 7, SCR2015). Until an effective assessment has been undertaken, the measures required to control and mitigate emergencies, and to provide effective muster, evacuation and escape, cannot be assured. This assessment should be re-visited and updated when a thorough review of the safety case has been undertaken.

2. Success Criteria The assessment record might be a single document, or, more likely, a series of related studies and analyses that together form the PFEER Reg. 5 assessment. It should demonstrate that all credible foreseeable major incident events, and their potential consequences, that could lead to the need for emergency response have been identified; and that measures necessary to controlling / mitigating those events are identified.

Onshore inspection might include the request for and review of documentary evidence of the PFEER Reg. 5 assessment itself, or of the section of the installation safety case addressing the assessment’s summary findings and updates.

Offshore inspection should be planned and undertaken using the information from the assessment. • The output of the assessment should include the determination of o satisfactory emergency access and egress routes, o the appropriate location of a temporary refuge and muster areas for all personnel, and o the type, number, capacity and location of evacuation and escape systems, appropriate PPE, and the arrangements for recovery and rescue.

• Performance standards: PSs are required for those measures to protect persons from fire and explosion and to ensure effective evacuation, escape, recovery and recovery / rescue [PFEER Regulation 5(2)(c)]. These PSs should include measurable elements which demonstrate the suitable functionality, reliability, availability and survivability of the

specific SECEs to ensure effective emergency response, evacuation, escape and recovery / rescue.

• There should be evidence that the assessment is reviewed as often as necessary to accommodate changes during the life cycle of the installation.

3. Key Regulations HSWA Sections 2 and 3 – Require (as a minimum) that risks be eliminated SFAIRP (equivalent of ALARP) PFEER Reg. 5 SCR2015 Reg. 16(1)(d) and (e) - L154 Para 211

4. Supporting Standards, ACoP or Guidance Paragraph 57 of the PFEER Guidance L65 provides a definition of a performance standard.

Paragraphs 62 to 71 of the PFEER ACoP give guidance to undertaking the assessment.

SCR2015 Regulations & Guidance L154 - Schedules 6 & 7 (and Schedule 8 for dismantling safety cases) specify particulars to be included in the safety case, including a summary of the assessment made as required by PFEER Reg. 5.

SCR2015 Guidance L154 Paragraphs 210-217 provides an indication as to the required depth of assessment and control.

Oil & Gas UK Guidelines for the Management of Emergency Response for Offshore Installations Issue 3, 2010

Appendix 2

PREPARATION AND ARRANGEMENTS FOR EMERGENCY COMMAND AND CONTROL

1. Fundamental Requirement PFEER Reg. 6 requires the dutyholder to establish appropriate organisation and arrangements to deal with emergencies.

In the report of the Public Inquiry into the Piper Alpha Disaster Lord Cullen was critical of the offshore installation manager (OIM) for not exercising effective command as the disaster developed. However, the Inquiry recognised the OIM had been given insufficient training in emergency command and that the installation emergency command and control systems had never been subject to realistic testing or assessment. There are many other historic offshore major incidents that provide examples of poor decision making by offshore management, under pressure during a developing major incident. Preparation of effective emergency arrangements, and the provision of effective training for offshore managers, might have resulted in greatly improved outcomes.

The dutyholder should provide an emergency command structure (ECS), with enough competent people to implement an emergency response plan (ERP) and to continue to do so, so far as is reasonably practicable, throughout an emergency. There should be arrangements for communication and coordination with the UK SAR framework.

The dutyholder must also prepare and provide adequate instruction and training to ensure all persons are sufficiently trained in appropriate action to be taken in the event of an emergency. In addition to training and competence, sufficient numbers of personnel should be in attendance for helicopter movements and lists of personnel with specific emergency duties published.

2. Success Criteria The dutyholder is required to have appropriate organisation and arrangements in place in anticipation of an emergency. These arrangements require an ECS staffed by competent people in sufficient numbers to be able to undertake emergency duties and operate relevant equipment.

Onshore inspection might include the request for, and review of, ER training and competency records.

This might include evidence of the OIM and deputy OIM OPITO approved or equivalent training and assessment in major emergency management (with periodic revalidation as deemed necessary). There should be a well understood onshore emergency support structure which should be well integrated with offshore ERP.

• does the dutyholder have a selection policy for onshore and offshore critical personnel who will have ECS duties that includes an assessment of leadership and installation familiarity as well as technical, engineering, and day-to-day operational management? • has OIM / deputy successfully attended OPITO-approved major emergency management (or equivalent emergency command) training and assessment courses? • Has OIM / deputy completed 3-yearly emergency command refresher training?

Offshore inspection might include, but not necessarily be limited to, the following: Competency: Instruction / training provision to all on the installation, including offshore safety induction

• review the content and delivery of the offshore safety induction for new arrivals on the installation and for periodic refresher training of core crew. This