HID Inspection Guide Offshore Inspection of Maintenance Management

Contents  Summary  Introduction  Action  Background  Organisation  Targeting  Resources  Recording & Reporting  Appendix 1: Asset Register  Appendix 2: Plant Inspection  Appendix 3: Maintenance Planning  Appendix 4: Effective Review  Appendix 5: Leadership, Ownership and Coordination  Appendix 6: Dutyholder Performance Assessment

Summary

This guidance outlines an approach to inspection of dutyholders’ arrangements for maintenance management, and the current key topic areas that inspectors should consider when inspecting this topic offshore. It also sets out criteria for satisfactory and unsatisfactory performance factors against which the duty holder performance will 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.

It is intended that this document can be used by Inspection Management Teams where a discipline specialist is not available, by focussing on the safety management systems aspects of this guide. Where a specialist is present offshore the technical aspects can be covered to a greater depth.

This guide solely focuses on topsides equipment which comes under the management of offshore platform personnel. The relevant offshore personnel would be maintenance supervisors (mechanical, electrical, instrumentation) and Offshore Inspection Engineers (OIEs). For the purpose of this guide inspection of pressure systems will be included as an aspect of maintenance management. The relevant supporting specialist teams from ED would therefore most likely be mechanical engineering, material and corrosion engineering and control / electrical engineering.

Separate guides will be produced which cover structures and the verification aspects of safety critical elements (SCEs). In addition the effects of the European Safety Directive are not covered in the guide – this will be reviewed following implementation.

Introduction

The aim of this Operational Guide (OG) is to provide information and guidance to offshore inspectors to support the delivery of consistent and effective maintenance management.

The maintenance and inspection of Safety Critical Elements (SCEs) is covered in this guide. In addition equipment which may not comprise any SCEs is covered, as there remains an absolute duty under the regulations described in the following paragraphs to ensure this work equipment is safe. It is important to consider maintenance of non- SCEs as part of the overall management system, and to consider the cumulative risk effects.

This guide highlights 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).

The Provision and Use of Work Equipment Regulations (PUWER) 1998 Regulation 5 requires employers to ensure that work equipment is maintained in an efficient state, in efficient working order and in good repair. The Offshore Installations Prevention of Fire and Explosion, and Emergency Response (PFEER) Regulations 1995, Regulation 19 re-iterates this duty for plant fitted to comply with these regulations.

In addition the Provision and Use of Work Equipment Regulations 1998 Regulation 6 requires that every employer shall ensure that work equipment exposed to conditions causing deterioration which is liable to result in dangerous situations, is inspected at suitable intervals and each time exceptional circumstances occur. This is to ensure that health and safety conditions are maintained, and that any deterioration can be remedied and detected in good time.

The maintenance management described in this Inspection Guide is the process, approach and implementation that the employer and/or duty holder used to fulfil these statutory obligations.

Maintenance, and its management, addresses how equipment is kept at or restored to an acceptable level of capability. The benchmark for ‘acceptable’ has components of safety, environmental impact, risk of subsequent failure and economic concerns.

This guide breaks the topic down into five core intervention areas as follows:

1. There is an accurate Asset Register that records all equipment installed. 2. There is a plant inspection regime which is being effectively delivered and on schedule

3. There is a planned maintenance system which is also being delivered on schedule. 4. There is an effective review process for maintenance that allows the plant to be resilient to changing operating profile and ageing of plant. 5. There is co-ordination, leadership, ownership and senior management engagement in maintenance management.

What is a Maintenance Management system?

A maintenance management system should deliver the effective inspection, maintenance and testing activities that assess the condition of plant, detect deterioration and remedy the identified shortcomings. The legislative foundation is illustrated in figure 1 and described on page 7 of this guide.

A maintenance management system is a living document requiring regular review to ensure it remains relevant to the maintained assets. Offshore plant maintenance has to evolve as the plant ages and should take account of the following considerations (amongst others):

 Changes to operating parameters and other relevant modifications.  Experience gained in the operation of equipment should be incorporated into maintenance schemes (condition findings, failures, efficiency of performance etc).  Improvements in technology through the equipment’s life-cycle (eg equipment design, maintenance and inspection techniques).  The tolerability and acceptance of failure and risk may change.

MAINTENANCE MANAGEMENT SYSTEM OSCR Reg 2 (SCEs definition),12 PUWER Regs 4, 5 and 6 PFEER Regs 5, 9 and 19

Risk Based Assessment (RBA) Identify degradation mechanisms. Use to develop risk based inspection (RBI) scheme. Failure Modes and Effects Analysis (FMECA) Identify failure and deterioration Operational modes for critical equipment. faults Dutyholder procedures / original equipment manufacturer recommendations

Planned Corrective Defect / anomaly maintenance, Maintenance reporting inspection and testing Repair.

Modification. PUWER 5 PUWER 6(2) Change PFEER 5(2)(c) Maintenance Management. PFEER19(1)(b), performance (3) and (4) KPIs PUWER 5

Plant Integrity Review

Review process conditions. Assess plant condition from outcomes of maintenance and inspection activities. Review the deterioration mechanisms found in service Review PMRs for effectiveness in detecting deterioration. Review compliance with performance standards (PFEER equipment). Fitness For Service and life extension reviews.

PUWER 4, 5 AND 6(2) PFEER 5(2)(c) PFEER 19(1)(b),(3), (4) MHSWR 5 (1)

Figure 1 Legislative Basis for Maintenance Management

The HSE implemented Key Programme 3 (KP3) in 2007. The aim of KP3 was to ensure that duty holders effectively manage the risk of any failure of structure, plant, equipment or systems, which could either cause or contribute to, or prevent or limit the effect of, a major accident and/or cause fatalities. Its aims were as follows:

 For HSE to use all its regulatory and specialist resources to make an in-depth appraisal of duty holders' abilities to manage the integrity of their installations in a manner that takes adequate account of health and safety;  To identify deficiencies in maintenance and other activities that underpin life- cycle integrity;  To use HSE influence and, where necessary, formal enforcement powers, to ensure that legal requirements are met and that any deficiencies threatening integrity are remedied;  To work with industry in a way that ensures good practice in integrity management, encourages continuous improvement and minimises the potential for accidents.

The underpinning question is, ‘Is the maintenance function adequately targeted and adequately resourced in terms of people, time and finance?’. From a Major Accident Hazard perspective, this means;

 Is the planning of SCE maintenance efficient?  Is the quality of maintenance acceptable?  Is the performance of SCEs reliable?  Are inspection and audit standards optimal?  Is supervisory and engineering support solid?

There should be in place suitable Performance Standards, Verification Schemes and where necessary Written Schemes of Examination for systems and equipment.

This guide reinforces the aims of KP3 but also goes further to consider the whole maintenance and inspection management function, not just on SCEs.

Action

Inspection of this topic should include both inspection of the individual sections of this guide (listed as Appendices 1 to 5) and taking an overview of the sum of the individual sections, to establish a consistent and complete coverage of the topic.

In inspecting individual sections it may be necessary to have input from the relevant specialist inspectors where there are technical issues beyond the competence of the IMT inspector.

Success criteria are listed under the inspection topics (see Appendices 1 to 5); these cover the key issues that inspectors should consider when carrying out inspections against each section. In some instances, not all of the success criteria will apply so inspectors should make a judgement regarding which of these are relevant in each case. If the relevant success criteria cannot be 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 any enforcement action they take based on the findings of the inspection.

When carrying out inspections covered by this guidance inspectors should:

 check the key issues against their success criteria in Appendices 1 to 5;  use the generic performance assessment descriptors in Appendix 6 to: o determine the appropriate performance rating; and o the initial enforcement expectation to use alongside the EMM.  consider how and when the issues raised during an inspection are to be closed out and recorded using the COIN issues tab;  assess the extent to which senior management leadership influences front-line safety  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.

Inspectors should use the generic performance assessment descriptors in Appendix 6 to determine the appropriate performance rating for each of the five sections of this guide. The appendices also give guidance on the initial enforcement expectation and should be used alongside the Enforcement Management Model (EMM). The local factors that apply in each case will ultimately determine the whether there should be any enforcement action. Consideration should be given as to how and when the issues raised during an inspection should be closed out. Inspectors must adhere to the relevant operational guidance (e.g. on use of the COIN issues tab).

Background

Relevant Legislation  Offshore Installations (Safety Case) Regulations 2005  Regulation 2 Interpretation describes a ‘safety-critical element’ (SCE) as such parts of an installation and such of its plant the failure of which could cause or contribute substantially to or the purpose of which is to prevent, or limit the effect of a major accident.  Regulation 12 Management of health and safety and control of major accident hazards requires the dutyholder to demonstrate that all major accident risks have been evaluated and measures have been, or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with. The requirement of an adequate management system to achieve this is specified. Maintenance management is a clear component of this.

 Provision and Use of Work Equipment Regulations (PUWER) 1998  Regulation 4 Suitability requires employers to ensure that work equipment is so constructed or adapted as to be suitable for the purpose for which it is used or provided.

 Regulation 5 Maintenance requires employers to ensure that work equipment is maintained in an efficient state, in efficient working order and in good repair. All employers should also ensure that where machinery has a maintenance log, the log is kept up to date.  Regulation 6 Inspection requires employers to ensure that work equipment exposed to conditions causing deterioration is inspected at suitable intervals, or after exceptional circumstances,

 Offshore Installations Prevention of Fire and Explosion, and Emergency Response Regulations 1995 (PFEER) specify the goals for the preventative and protective measures to manage fire and explosion and to secure emergency response and recognise that the responsibility to put into place measures necessary to achieve these goals is best placed with one person – the duty holder.

 Regulation 5 requires the duty holder to establish appropriate standards of performance to be attained by anything provided for ensuring effective evacuation, escape, recovery and rescue to avoid or minimise a major accident or other measures to protect people from a major accident involving fire and explosion.  Regulation 9 requires the duty holder to take such measures necessary to prevent fire and explosion by, amongst others, ensuring the safe storage, handling and movement of flammable or explosive substances and preventing their uncontrolled release.  Regulation 19 requires that plant fitted be so constructed as to be suitable and is maintained in an efficient state, in efficient working order and in good repair.

 Management of Health and Safety at Work Regulations (MHSWR) 1999  Regulation 5(1) Every Employer shall make and give such effect to such arrangements as are appropriate for the effective planning, organisation, control, monitoring and review of the preventive and protective measures.

Organisation

Targeting

The HID Business Plan 2012 – 15, section D.1 commits HID to deliver intervention plans at major hazard sites/operators. HID reports progress on the number of sites/operators inspected and topics completed against the plan. The guidance set out in SPC/Admin/85 details the arrangements for HID to monitor and report progress against plan.

Although the inspection may be carried out at any installation it is particularly important to carry this out where there are known issues that may affect maintenance management issues such as ageing equipment, major projects etc. It is essential to ensure that duty holders 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 Inspectors should undertake maintenance management 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 Resource for the undertaking of maintenance management interventions will come from Discipline inspectors and 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.

Contacts

ED Offshore: ED Mechanical, Materials and Corrosion and EC&I Specialist Inspectors

Appendix 1: Asset Register

Fundamental Requirement Every employer shall ensure that work equipment is used only for operations for which, and under conditions for which, it is suitable. [PUWER Regulation 4] Every employer shall ensure that work equipment is maintained in an efficient state, in efficient working order and in good repair. [PUWER Regulation 5] The duty holder to establish appropriates standards of performance to be attained by anything provided for ensuring effective evacuation, escape, recovery and recue to avoid or minimise a major accident or other measures to protect people from a major accident involving fire and explosion [PFEER Regulation 5]

Success Criteria The employer must know:  What equipment is installed.  Where appropriate what modification state the equipment is in.  What the equipment’s operating parameters are.  Where appropriate what the performance standards are (PFEER SCEs).  How the employer will maintain this installed equipment to be used in their operation.

Widespread practice is to have an asset register that forms the foundation of the maintenance management system (MMS). This register should be a live document and updated to address changes due to modification, enhancement, redundancy, upgrade and removal of equipment or components.

Category Issues Good Practice Found

Dedicated resources were provided to clean data in the MMS and ensure classification of SCEs/non-SCE as MMS have large amounts appropriate. Where MMS data has of spurious data as a been cleansed backlog figures have result of ‘daughter’ work been seen to reduce as a result of the orders, work completed removal of spurious workorders. MMS Data but not signed off, Prioritisation of work, forward planning Quality inadequate or of resources maintenance tasks and inappropriate managing backlog downwards classification of safety- becomes possible. and non-safety-critical equipment.

Key Regulations  PUWER Reg 4 Suitability of Work Equipment  PUWER Reg 5 Maintenance  PFEER Reg 5 Assessment

Supporting Standards/ACoP or Guidance  L22 Safe Use of Work Equipment  L65 PFEER ACoP

Appendix 2: Plant Inspection

Fundamental Requirement Every employer shall ensure that, where the safety of work equipment depends on the installation conditions, it is inspected after installation and before putting into service for the first time. [PUWER Regulation 6]

Every employer shall ensure that work equipment exposed to conditions causing deterioration which is liable to result in dangerous situations is inspected at suitable intervals and each time exceptional circumstances occur to ensure that health and safety conditions are maintained and that any deterioration can be remedied and detected in good time.[PUWER Regulation 6]

The duty holder to take such measures necessary to prevent fire and explosion by, amongst others, ensuring the safe storage, handling and movement of flammable or explosive substances and preventing their uncontrolled release. [PFEER Regulation 9]

Success Criteria  Does the employer have an inspection programme?  Is that inspection programme based on, and proportionate to, risk?  Has that risk been assessed appropriately?  Is that employer adequately resourcing that programme with suitably qualified and experienced personnel (SQEP)?  Does the inspection programme find deterioration in good time – or are there corrective maintenance lists full of repairs?  Is the inspection programme up to date? The benchmark is that inspection should be completely up to date.  If inspection items cannot be completed, there should be an assessment of the risk this presents. Where the risk is acceptable, a deferral may be possible. It should be noted that if a risk-based assessment has been used to determine inspection intervals (particularly for SCEs) then this may be difficult to justify and will be challenged by HSE. o Non-SCE related inspections should have a level of risk assessment appropriate and proportionate to the likelihood and consequences of any failure. o Risk assessment must also be in place for the cumulative effect of inability to achieve the inspection programme.

Category Issues Good Practice Found Inspection As installations