The Offshore Marine Operations Inspection Guide Open Government Status: Fully Open

Publication Date: 28/10/2019

Review Date: 28/10/2022

Review History Date Changes Approved 28/10/2019 First approved issue Howard Harte

Target Audience: ED Specialist Inspectors Contents ➢ Summary ➢ Introduction ➢ Relevant Legislation ➢ Action ➢ Background ➢ Other relevant Inspection Guides ➢ Organisation Targeting Timing Resources Recording & Reporting ➢ Appendices Appendix 1 – Marine Assurance Appendix 2 – Collision Risk Management Appendix 3 – Transfer of Cargo Between Offshore Supply Vessels and Installations Appendix 4 – Rig Moving Appendix 5 – Walk-to-Work Operations Appendix 6 – Multi-Role Emergency Response and Rescue Vessels (ERRV) Operations Appendix 7 – Application of EMM and Dutyholder Performance Assessment

Summary This guidance outlines an approach to inspection of duty holder’s arrangements for marine operations, and the current key topic areas that inspectors should consider when inspecting this topic both on and offshore. 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.

Regulation of marine operations is undertaken by the Maritime and Coastguard Agency (MCA), the Marine Accident Investigation Branch (MAIB), and HSE.

MCA is responsible for enforcing all merchant shipping regulations in respect of occupational health and safety, the safety of vessels, safe navigation and operation (including staffing levels and crew competency). Merchant shipping health and safety regulations extend to all those working on the ship, and any work activities undertaken on board.

MAIB is responsible for investigating accidents related to ships and crew in the territorial sea and involving UK registered vessels worldwide, to determine their circumstances and causes with the sole objective of preventing similar accidents in the future.

HSE leads on the regulation of activities taking place on, or under the control of the operator of:

• offshore installations involved in the exploration or production of oil or gas; • offshore installations involved in gas importation and storage or in relation to underground coal gasification; and • energy structures (wind or wave).

The content of this inspection guide has been determined to be within the jurisdiction of HSE.

Sometimes the jurisdiction of the HSE, MCA and MAIB can overlap. The HSE/MCA/MAIB Operational Working Agreement details the process followed to determine the correct regulatory authority.

NOTE - This guide does not address Evacuation, Escape and Rescue, or Aviation Operations, which also form part of the remit of ED3.3. These topics are subject of a separate Inspection Guide.

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 marine operations inspections. 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).

This operational guidance outlines HSE’s current marine operations inspection practices undertaken offshore. The topic breaks down into six core areas as follows:

1. Marine Assurance 2. Collision Risk Management 3. Transfer of Cargo between Offshore Supply Vessels and Installations 4. Rig Moving 5. Walk-To-Work Operations 6. Emergency Response and Rescue (ERRV)

An overview of each of the above is provided in the appendices. This guidance is to promote a consistent approach to the inspection of the core sub topic of Marine Operations.

Relevant Legislation Health and Safety At Work etc. Act 1974 (Application outside Great Britain) Order 2013 (AOGBO) applies the Health and Safety at Work etc. Act (HSWA) to offshore installations and any activity in connection with an offshore installation, or any activity which is immediately preparatory thereto from a vessel or in any other manner, other than towing the installation (see MAR Reg 4), or an ERRV.

Offshore installations and Pipeline Works (Management, and Administration) Regulations 1995 (MAR) adds some more detailed requirements for the management of offshore operations to HSWA. The AOGBO Order 2001 extended the definition of ‘offshore installation’ to include supplementary units which provide support services to offshore installations on the UK Continental Shelf (UKCS). As a result, the definition of ‘Offshore Installation’ contained in MAR was also amended.

• Regulation 2 interprets a vessel, aircraft or hovercraft attendant on the installation as an “associated structure”. • Regulation 3 defines “installation” and provides guidance on when a marine vessel becomes, and ceases to be, an installation. • Regulation 4 requires application of MAR at all times other than when the installation is in transit. The installation is not considered in transit if it is at, or in the immediate vicinity of its first, a previous or its new working location. • Regulation 11 The duty holder must ensure that comprehensible written instructions are provided and marine operations procedures are observed. This must be brought to the attention of every person who is to do anything to which that part relates. • 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, among other things, safe marine operations on and near the installation.

The Prevention of Fire, Explosion and Emergency Response Regulations 1995 (PFEER) specifies the goals for the preventative and protective measures to manage fire and explosion, and to secure emergency response, and recognises that the responsibility to put into place measures necessary to achieve these goals is best placed with one person – the dutyholder.

• 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 the dutyholder to identify events which could give rise to a major accident and establish appropriate standards of performance to be attained. • Regulation 10 requires the duty holder to take appropriate measures with a view to detecting fire and other events which may require emergency response.

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

Action Inspection of this topic should include not only the six core areas themselves but also an overview of the operator’s Marine Operations procedures to ensure a consistent and complete assessment of control measures.

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 Marine Operations 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 6; • 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.

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 The management of marine operations is a specialist subject that is often overlooked as a major accident hazard. A collision between a vessel and an installation has the potential to result in a major accident with a large number of casualties.

There is little oil and gas legislation that deals specifically with marine operations and the industry draws heavily on guidance documents and the expertise of marine personnel.

Other relevant Inspection Guides Inspection of Emergency Response Inspection of Offshore Aviation Operations

Organisation

Targeting Inspections should be planned within the timescales set out by 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 regarding marine operations. 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 Marine Operations 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 ED3.3 (Emergency Response, Marine Operations and Aviation Specialism) has overall ownership of the Guide and takes the topic lead on inspecting Marine Operations. Resource for the undertaking of Marine Operations interventions will come from ED3.3 discipline specialist inspectors supported by Inspection Management Team inspectors as appropriate.

Recording and 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.

Appendix 1 - Marine Assurance

Fundamental Requirement The dutyholder should have in place suitable arrangements to ensure suitable vessels are selected for the intended operation. They should have in place arrangements to ensure all vessels meet minimum standards for safe operations and station keeping before engaging in offshore operations.

Success Criteria The dutyholder should demonstrate that their vessel assurance policy is sufficiently robust to ensure that all vessels undergo a suitable assessment prior to commencing offshore operations, and the assessment is based on the specific activities to be undertaken. The assessment should cover all aspects of the operation including crew competence, condition of equipment, vessel operator safety management, and compliance with other marine rules, codes and practices. The marine assurance policy should include a process of regular audits and inspections of vessels throughout the period they are on charter to the dutyholder.

During combined operations it is not necessary for all dutyholders to inspect and audit vessels, this is usually undertaken by the charterer of the vessels. Our expectation is for the operator of any installation to have defined the minimum standard of vessel permissible at that installation, and have a process in place to ensure and verify the vessel meets that standard and will be operated in accordance with industry good practice and the standards set by the operator. However, in the case of a drilling unit or flotel operating at a fixed installation, for example, the operator of the mobile unit is not expected to duplicate the audits and inspections undertaken by the operator of the fixed installation, and vice versa. The results of the audits and inspection should be shared between both operators so that both are able to make an informed decision as to the suitability of the vessel.

For some operations, such as seismic survey flybys, it may not be practicable to perform the full suite of vessel audits and inspections. The vessel operator or survey company should provide sufficient information to assure the duty holder the vessel is in good condition and being operated in a safe manner.

Onshore

• Confirm the duty holder has a marine assurance process that, as a minimum, identifies the following: o The vessel is adequately maintained, and critical systems are verified as fit for purpose.

o The number and competence of crew is appropriate for the operations to be undertaken.

o Suitable and sufficient procedures are in place for the safe operation of the vessel and that these procedures are compatible with the operating policies of the duty holder.

o The vessel has in place all Class, Flag and Port State certificates and surveys and the duty holder has a process for reviewing any issues raised by certifying authorities (Flag, Class, Port State).

o The operating envelope of the vessel is suitable for the specific location of the installation in relation to station keeping and the likely meteorological and oceanic conditions.

o The vessel meets any relevant performance standards.

• Does the process require the vessel to undergo a more detailed industry accepted inspection (commonly an OVID or CMID inspection) within the previous 12 months and were any findings properly addressed by the vessel operator? • Does the process require the vessel to undergo an operation specific audit (commonly referred to as an ‘on-hire inspection’ or ‘suitability inspection’) by a competent person on behalf of the duty holder to confirm it meets minimum safety and station keeping standards, (mandatory and dutyholder specific standards) and is staffed by an experienced and competent crew? • Does the dutyholder have a policy of reviewing the results of marine assurance audits and inspections for third party vessels operating with their 500m zones, such as those vessels operating under a proximity agreement, to ensure the vessel meets, and is being operated in accordance, with their own standards? • For DP vessels, does the marine assurance process include a review of the ASOG/CAM to ensure it reflects the dutyholder expectations with regard to the manner in which the vessel will be operated? • Does the assurance process include a review of vessel specific and vessel operator safety statistics?

• During the marine assurance process, was the operating displacements of the vessel considered against the installation maximum impact energy? • For DP vessels, does the marine assurance process include a review of recent proving trials? Is there a system in place for managing category A findings? • For DP vessels, does the marine assurance process include a review of the DP FMEA?

Key Regulations HSWA Sections 2 and 3 – Require (as a minimum) that risks be eliminated SFAIRP (equivalent of ALARP)

SCR 2015 Reg 16(1)(d) and (e) - L154 Para 211

Supporting Standards/ACoP or Guidance Guidelines for Offshore Marine Operations (GOMO)

Guidelines for Offshore Marine Operations UK Supplement

IMCA M103 - Guidelines for the design and operation of dynamically positioned vessels

IMCA M109 - A guide to DP-related documentation for DP vessels

IMCA M117 - The training and experience of key DP personnel

IMCA M116 - Guidance on failure modes and effects analysis (FMEA)

IMCA M182 International guidelines for the safe operation of dynamically positioned offshore supply vessels

IMCA M204 - Vessel assurance

OCIMF – Dynamic Positioning Assurance Framework

Appendix 2 - Collision Risk Management

Fundamental Requirement The dutyholder should have in place suitable arrangements to detect a vessel on collision course with the installation at an adequate distance to intervene. The arrangements should include a means to identify and communicate with the vessel, which may include specific actions to be performed by the standby vessel. Equipment used to detect vessels should be considered safety critical.

The duty holder should also have in place suitable arrangements to monitor and control vessel activity inside the installation 500m zone.

Success Criteria The dutyholder should have in place a dutyholder and installation specific Collision Risk Management (CRM) System to ensure the risk of collision has been adequately assessed and the equipment and systems in place to detect or prevent the collision are sufficient and are considered safety critical. The CRM system should include a means of verifying the performance of associated equipment and ensuring the equipment is maintained to the required standard.

Adequate monitoring and control of vessel activities within the installation 500m zone should include a means of ensuring the vessel is operated in accordance with dutyholder policy and procedures, and operations are only undertaken in suitable weather conditions.

Collision Risk Management System

Onshore • Does the dutyholder have a Collision Risk Management System in place which: o Has assessed, and continues to assess, the probability of a vessel colliding with the installation and the consequences likely to result from such a collision?

o Includes the means of identifying passing vessels which may collide with the installation in sufficient time to take appropriate action?

• Was the specification of the detection system based on location-specific factors such as traffic characteristics (e.g. speed, density, routes, etc.), warning time required by

installation, standby vessel availability, and foreseeable weather conditions, and has the limitations of the equipment selected been taken into account? • Does the CRM cover the following key elements (as described in OGUK guidance Collision Risk Management Systems, Issue 2): o Include clear corporate policies

o Demonstrates senior management commitment to effective collision risk management

o Contains clearly understood responsibilities for implementing and maintaining the system

o Include means of ensuring the competency of personnel involved in CRM

• Are the detection and assessment systems treated as safety critical and is there a means of monitoring performance of vessel detection systems? • Has the dutyholder undertaken a location specific hazard identification and risk assessment for each of their installations? • Can the dutyholder demonstrate that the alerting measures adopted to warn off an approaching vessel are likely to be effective, and that they are undertaken early enough to provide a realistic chance that the vessel can act to avoid a collision? • Does the emergency response plan for the installation address the management of collision risk from passing vessels? • Do the installation emergency procedures (for vessel collision) address the time needed for the installation to prepare for collision? Are there time-based performance standards? • On installations where collision detection is performed by the ERRV is there a process for ensuring radar blind sectors are regularly covered, particularly during periods of close standby or ERRV value added services within the 500m zone? • When collision detection is provided by the ERRV at shared installations can the ERRV cover the required range when located at the extremity of the shared location?

Offshore • Do relevant offshore personnel understand the dutyholder collision risk and collision avoidance policies and procedures? •