OFFSHORE MAJOR ACCIDENT REGULATOR

Offshore Petroleum Regulator for Environment & Decommissioning The Offshore Noise and Vibration Inspection Guide Open Government Status Fully Open Publication Date April 2023 Review Date April 2026

Review History Date Changes

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

Contents • Summary (p.2) • Introduction (p.2) • Relevant Legislation (p.3 to 5) • Action (p.5 to 6) • Background (p.7) • Other relevant Inspection Guides (p.7) • Specialist Advice (p.7) • Organisation (p.7 to 8) Targeting Timing Resources

Recording & Reporting Health and Safety • Appendices (p.9 to 26) Appendix 1 – Plan, Do, Check, Act for Noise and Vibration Management Appendix 2 – Application of EMM and Dutyholder Performance Assessment Appendix 3 – Management and Control of Risks from Noise Flowchart Appendix 4 – General Management of HAV risks when the use of vibrating equipment is unavoidable Appendix 5 – Example vibration magnitudes of some common machines

Summary This guidance outlines an approach to inspection of dutyholders arrangements for managing health risks offshore associated with Noise and Hand-arm Vibration (HAV). It also sets out criteria for satisfactory and unsatisfactory performance factors against which the dutyholder 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. The effectiveness of such systems is a key component of occupational health risk management and securing effective control of health risks to prevent or minimise the incidence of occupational diseases such as noise induced hearing loss, HAV syndrome.

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 health risk management. It does this by highlighting current 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 operational guidance outlines HSE’s priorities for inspection of Noise and Hand-arm vibration health risks offshore. It is important to note that this guidance does not include detailed information on other offshore health risks such as Hazardous Substances, Asbestos, Ergonomics/Manual Handling, Ionising and Non-Ionising Radiations, Thermal Environment, Personal Protective Equipment, Food/Water hygiene, First-Aid and Welfare, which continue to form part of the remit of the ED Industrial Hygiene Team.

Relevant Legislation Health and Safety at Work etc Act 1974, Section 2(1) – It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees.

Health and Safety at Work etc Act 1974, Section 3(1) – It shall be the duty of every employer to conduct his undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in his employment who may be affected thereby are not thereby exposed to risks to their health or safety.

Health and Safety at Work etc Act 1974, Section 6 – Places duties on any person who designs, manufactures, imports or supplies articles and substances for use at work to ensure these articles and substances are designed, constructed and tested and that it will be safe and without risks to health at all times when it is being set, used, cleaned or maintained by a person at work.

The Management of Health and Safety at Work Regulations 1999, Regulation 3 – Requires every employer shall make a suitable and sufficient assessment of the risks to the health and safety of his employees to which they are exposed whilst they are at work; and the risks to the health and safety of persons not in his employment arising out of or in connection with the conduct by him of his undertaking.

The Management of Health and Safety at Work Regulations 1999, Regulation 5 – Requires employers make and give effect to such arrangements as are appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures.

The Control of Noise at Work Regulations 2005, Regulation 5 – Requires an employer who carries out work which is liable to expose any employees to noise at or above a lower exposure action value shall make a suitable and sufficient assessment of the risk from that noise to the health and safety of those employees, and the risk assessment shall identify the measures which need to be taken to meet the requirements of these Regulations.

The Control of Noise at Work Regulations 2005, Regulation 6 – Requires an employer to ensure that risk from the exposure of his employees to noise is either eliminated at source or, where this is not reasonably practicable, reduced to as Iow a level as is reasonably practicable. If any employee is likely to be exposed to noise at or above an upper exposure action value, the employer shall reduce exposure to as Iow a level as is reasonably practicable by establishing and implementing a programme of organisational and technical measures, excluding the provision of personal hearing protectors, which is appropriate to the activity.

The Control of Noise at Work Regulations 2005, Regulation 8 – Requires an employer to ensure so far as is practicable that anything provided by him in compliance with his duties under these Regulations or for the benefit of an employee, other than personal hearing protectors, is fully and properly used; and maintained in an efficient state, in efficient working order and in good repair.

The Control of Vibration at Work Regulations 2005, Regulation 5 – Requires an employer who carries out work which is liable to expose any of his employees to risk from vibration shall make a suitable and sufficient assessment of the risk created by that work to the health and safety of those employees and the risk assessment shall identify the measures that need to be taken to meet the requirements of these Regulations.

The Control of Vibration at Work Regulations 2005, Regulation 6 – Requires employers shall ensure that risk from the exposure of his employees to vibration is either eliminated at source or, where this is not reasonably practicable, reduced to as Iow a level as is reasonably practicable. Where it is not reasonably practicable to eliminate risk at source pursuant and an exposure action value is likely to be reached or exceeded, the employer shall reduce exposure to as Iow a level as is reasonably practicable by establishing and implementing a programme of organisational and technical measures which is appropriate to the activity.

The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015, Regulation 16 – Requires a dutyholder who prepares a safety case pursuant to these Regulations demonstrate that the dutyholders management system is adequate to ensure that the relevant statutory provisions will, in respect of matters within the dutyholders control, be complied with.

Offshore Installations and Pipeline Works (Design and Construction etc) Regulations 1996, Regulation 12 and specifically Schedule 1 – Requires dutyholders ensure that the additional requirements set out in Schedule 1 are complied with in relation to an installation, while it is in use, unless in the case of any such requirement it would not prejudice the health, safety or welfare of any person if it were not complied with.

Controlling Noise at Work, The Control of Noise at Work Regulations 2005 and guidance L108 (Third edition) Published 2021 – This guidance is aimed at employers and other dutyholders and includes the Control of Noise at Work Regulations alongside guidance on what they mean, setting out an employer’s legal obligations to control risks to workers’ health and safety from noise. It also gives detailed advice on assessing risks, practical noise control, how to select and use hearing protection, what to consider when buying and hiring equipment and how to develop health surveillance procedures.

Hand-arm Vibration, The Control of Vibration at work Regulations 2005, guidance L140 (Second edition) Published 2019 – This guidance outlines what an employer’s duties are under the Control of Vibration at Work Regulations 2005 and relates specifically to HAV. The guidance looks at the employer’s legal obligations to control risks to employees’ health and safety from exposure to HAV and to prevent HAV-related diseases such as hand-arm vibration syndrome and carpal tunnel syndrome. It covers the management and control of the risks from HAV and how to protect employees, with practical guidance on risk assessments, controlling vibration exposure and arranging health surveillance. The guidance is aimed at employers as well as those who advise employers, such as health and safety professionals, vibration specialists and occupational health professionals.

Action Inspectors should review relevant documentation outlined within the IG prior to the installation visit and test compliance during the installation visit against the “Success Criteria” given in Appendix 1.

Inspection of this topic should include both inspection of the priority areas as well as an inspection of the overall policy, procedures and organisation for managing occupational health risks to establish a consistent and complete coverage of the topic. In inspecting individual topic areas, it may be necessary to have input from the relevant specialist inspectors where there are technical issues beyond the competence of the IMT inspector.

Noise - Each installation should implement a noise control policy. This should include risk assessment, a ‘Noise Action Plan’, demarcation of high noise areas and health surveillance (audiometry) based on risk. Over reliance on ‘blanket’ hearing protection policies is often an indication of poor understanding of the regulations, as priority should be given to control of noisy plant and machinery by engineering means. Noise criteria should be incorporated into design specifications of new plant and equipment. Consideration also needs to be given to the effect of modifications on existing plant and structures. Formal arrangements should be put in place for co- operation between operator and contractor to ensure that, where appropriate, contractor employees are placed under suitable health surveillance when required.

Hand-arm Vibration (HAV) - A control strategy should be in place to eliminate or reduce the risk of HAV syndrome as a result of working with handheld power tools and other vibrating equipment. This should include a Tool register, with representative in-use vibration levels for each tool and an assessment of who may be at risk. Control options to consider are alternative work methods, equipment selection, workstation design, trigger time and management of work schedules. The tools should be maintained and health surveillance provided for workers who are likely to be exposed at or above the exposure action value or who are at particular risk. Further examples can be found within the Energy Institute guidance on health surveillance.

By the conclusion of the inspection, it should be possible to:

• Have undertaken a targeted proactive inspection of the noise and vibration management system • investigate concerns associated with noise and vibration • decide whether the measures in place were adequate to control the risk of exposure; and take any necessary enforcement action where these are deemed inadequate

When carrying out inspections covered by this IG inspectors should:

• Assess dutyholder responses against the success criteria in Appendix 2 • Use the performance descriptors in Appendix 1 and 2 to: o Determine the appropriate performance rating o The Initial Enforcement Expectation (IEE) o Consider how and when the issues raised during an inspection are to be closed out

Background The aim of Industrial Hygiene is to prevent or control exposure to health risks by recognising health hazards, evaluating the risk and establishing appropriate control measures. The occupational health hazards may include; • Physical agents (e.g., noise, vibration, radiation) • Hazardous substances (e.g., chemicals, asbestos) • Biological agents (e.g., Legionella, food hygiene) • Ergonomics/Manual Handling

The essential requirements for managing occupational health are the same as those for any management system. Any sub-system for managing occupational health risks should therefore have the key features of an adequate management system i.e., policy, organisation, planning and setting standards, performance measures and auditing and review. Confirmation should be obtained that a recognised code, standard or body of guidance has been considered in determining the required performance of the occupational health management system.

Other Relevant Inspection Guides The Offshore Health Risk Management Inspection Guide The Offshore Control of Substances Hazardous to Health (COSHH) Inspection Guide

Specialist Advice Specialist advice should be sought from ED Industrial Hygiene Team in circumstances when considering enforcement / debate over relevant standards on any aspects of noise and vibration.

Organisation

Targeting

Inspections should be planned to ensure that the necessary site personnel are available, and arrangements can be made to facilitate physical inspection of the system(s).

Timing

Inspectors should undertake Inspections as part of the agreed Intervention Plan or as determined by the Energy Division Senior Leadership Team (EDSLT).

Resources

Further guidance can be sought from: Occupational health risks offshore - HSE Offshore Technology Report 2001/068 – Noise & Vibration HSE: Noise at work – health and safety in the workplace Hand-arm vibration at work Hand-arm vibration: Inspection and Enforcement Guidance Energy Institute Guidance on health surveillance Energy Institute Good practice guidance for controlling noise at offshore installations

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.

Health and Safety When conducting an inspection, the principles for mitigating the risk to staff are as follows: - Sound training for the recognition and identification of risks. Understanding of roles and responsibilities. Planning and conducting site visits in accordance with HSE procedures.

Inspectors undertaking inspections must be suitably trained and competent. The aim is to avoid the risk of exposure by carrying out your duties without entering areas where exposure to physical hazards may occur. If you are in any doubt about the hazards you face or whether control measures are adequate to safeguard your own health and safety, you should withdraw from the area and seek advice from your line manager or an experienced colleague.

Further guidance can be sought from - Your health and safety - Site visits - Visiting offshore installations and inshore/inland diving sites

Appendix 1 – Plan, Do, Check, Act for Noise and Vibration Success Criteria - the dutyholder is required to have in place risk assessments that include a record of the measures they intend to take in order to comply with the other regulations (control, training, health surveillance etc). It is insufficient to have a noise ‘survey’ or to have tool tagging without identifying those persons exposed at or above the action values, and any required actions. Action plans should be appropriately resourced, managed and monitored. Those tasked with delivering and managing noise and HAV action plans should have support and commitment from senior management. This will also require communication and cooperation with the relevant technical authorities (TAs) and contractor management. PLAN 1. Is there a noise and vibration control and management system in place? 2. Has the dutyholder appointed competent persons to manage and deliver all relevant aspects of their noise and vibration control and management system? 3. Have appointed competent persons and those who are appointed to carry out the role of noise and vibration focal points (noise/HAV competent person, or similar) been suitably informed, instructed and trained? 4. Does the noise and vibration management process link to the installations permit to work system (PTW)? 5. Is there a system in place for preventive and reactive maintenance of noise and vibrating machinery and work equipment? 6. Is there a system in place for preventive and reactive maintenance of noise control equipment (silencers, noise enclosures, refuges, etc.)? 7. Is there a process in place to assess risks to health associated with new equipment being purchased/mobilised offshore i.e., pre- approvals/review/authorisation process? 8. Is there a buy quiet/low vibration purchasing policy in place? 9. Are HAV/noise risks considered at the design and specification stage for new processes and projects? 10. Is there a Management of Change (MOC) process in place which formally incorporates noise and vibration risks? 11. Is there a process in place for Industrial Hygiene Focal Points/Specialists involvement in high-risk work involving physical risks and/or including management of change? 12. Have the employees been engaged, via the Safety Committee/Safety Representatives, in the development and implementation of action plans to manage and control noise and vibration risks? 13. Are contractor companies similarly equipped, and is there sufficient oversight of their systems by the installation operator? 14. Is there a process in place for routine engagement between employers and contracting companies/third parties to highlight risks/share relevant employee data (monitoring data notification letters/anonymised audiograms etc)?

Risk Assessment DO, CHECK and ACT 1. Are there risk assessments representative of all relevant operating conditions and covering all those likely to be exposed? Are they suitable and sufficient? Has the hierarchy of controls been considered and applied? 2. Has the risk assessment been completed by a competent person? 3. Has the risk assessment considered information from health surveillance? 4. Are there arrangements for maintaining the relevance of the current noise/vibration assessments? 5. Is there a coherent noise action plan, describing measures (other than those referring to hearing protection)? Is this being acted upon? 6. If there are identified noise problems in accommodation (see OTO 2001/068), does the action plan include measures to control transmitted noise? 7. Is there coherent feedback systems to improve the task and associated risk assessments, based on sample comparisons between predicted and actual exposure? 8. Is consideration given to keeping the operators warm and dry, e.g., by clothing or gloves, and have the effects of the environment or changing weather conditions been considered within the risk assessment? 9. Do risk assessments take account of persons with underlying health issues e.g., existing HAVS (see Health surveillance Reg 7) which may require restricting exposure? 10. Is there a system in place for periodic