Document Title: Well Notification Management System & CMAPP Inspection Template
WN Title - [WN Title]
Well Operator – [Company Name]
DECC / HSE / OSDR Logos
TRIM Numbers Topic Specialist – [Name]
WELL NOTIFICATIONS MANAGEMENT SYSTEM & CMAPP INSPECTION TEMPLATE
Work Instructions
The Offshore Installations (Offshore Safety Directive)( Safety Case) Regulations 2015 (SCR2015) requires that well operators who submit a Well Notification,
must also send to the Competent Authority (if they haven’t already done so previously) a copy of their corporate major accident prevention policy (CMAPP),
and an adequate description of their Safety and Environmental Management System (SEMS). The adequate description of the SEMS is a description of the
management system as it relates to the well operation covered by the Well Notification. It is not expected that the same level of detail as expected to be
provided in a Safety Case for an Offshore Installation is required. A Well Operator, however, may choose to send the full copy of their SEMS, as documented
in a safety case. In this scenario, the template used for Safety Case Assessment shall be used instead of this template.
This document will be available to inspectors to record their inspection of the CMAPP and SEMS relating to well operations. Any deficiencies noted will be
communicated back to the Well Operator via the IMT Focal Point inspector for consideration by the Well Operator for future regulatory submissions (in
particular for submissions of safety cases for offshore installations).
Record of inspection of the description of the Well Examination Scheme, which forms part of the SEMS, shall be recorded separately on the Well Examination
Scheme Assessment Template used for safety case assessment.
This template identifies the specific regulations contained within SCR2015 that relate to these topics and identifies what the competent authority expects to
find within the description of the CMAPP and SEMS to meet those requirements. The document is drafted to complement the guidance being produced to
support the regulations as well as existing topic sector guidance. Requirements identified by green text are new to SCR2015, those in black text were present
in SCR05.
Relevant Pre-Existing Guidance

APOSC Principles:
Management of health and safety

Principle 2
The safety case should demonstrate that the management system is adequate to ensure compliance with the relevant statutory provisions
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Owner: ED7
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Document Title: Well Notification Management System & CMAPP Inspection Template
WN Title - [WN Title]
Well Operator – [Company Name]

DECC / HSE / OSDR Logos
TRIM Numbers Topic Specialist – [Name]
GASCET Chapters:
2.1 Safety management

Safety management
The key features of a safety management system (SMS) are establishing a policy, linking objectives with this policy, making arrangements for
delivering the policy/objectives and measuring performance.
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Document Title: Well Notification Management System & CMAPP Inspection Template
DECC / HSE / OSDR Logos
WN Title - [WN Title]
Well Operator – [Company Name]
TRIM Numbers Topic Specialist – [Name]
1. Corporate Major Accident Prevention Policy (CMAPP) Requirements
a) SCR2015 Regulation 7 – Corporate major accident prevention policy
Inspection Criteria / Minimum Information
1.
2.
Ref
Objection
Clarification
SCR2015 Regulatory Requirement
7.—(1) This regulation applies only to a duty holder which is a body corporate or unincorporate.
(2) The duty holder must prepare in writing a policy (referred to in these Regulations as the “corporate major accident prevention policy”) which—
(a) establishes the overall aims and arrangements for controlling the risk of a major accident and how those aims are to be achieved and those
arrangements put into effect by the officers of the duty holder;
(b) covers the duty holder’s installations—
(i)
in external waters; and
(ii)
outside the European Union.
(3) The corporate major accident prevention policy must address at least the particulars set out in Schedule 1 and must be prepared in accordance with the
matters set out Schedule 2.
(4) The corporate major accident prevention policy may in addition outline the commitment of the duty holder to mechanisms for effective tripartite
consultation.
(5) An operator, in preparing a corporate major accident prevention policy, must take account of the operator’s primary responsibility for, among other
things, the control of risks of a major accident that are a result of the operator’s operations and for continuously improving control of those risks so as to
ensure a high level of protection at all times.
(6) A duty holder must—
(a)
implement the corporate major accident prevention policy throughout its offshore oil and gas operations; and
(b)
set up appropriate monitoring arrangements to assure effectiveness of the policy.
(7) In this regulation and Schedule 1, “officer of the duty holder” in relation to—
(a)
a body corporate, other than a limited liability partnership, means a director or secretary;
(b)
a limited liability partnership, means a member;
(c)
a partnership or a limited partnership, means a partner of that partnership or limited partnership; and
(d)
a body unincorporate (other than a partnership or limited partnership), means a member of the body.
(8) In paragraph (7)(a) “director” has the meaning given in section 250 of the Companies Act 2006( ).
(9) In this regulation (but not this paragraph) a reference to a duty holder or operator includes a reference to a well operator.
(10) Paragraph (2)(b) does not apply to a well operator.
Criteria Met / Not Met - Inspection Comments
Cross reference Schedule 1 inspection (see below) to confirm all
requirements met.
Is there a commitment for tripartite consultation between the
competent authority, duty holders and workers’ representatives? e.g.
OIAC or equally as effective route
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Document Title: Well Notification Management System & CMAPP Inspection Template
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WN Title - [WN Title]
Well Operator – [Company Name]
3.
4.
5.
TRIM Numbers Topic Specialist – [Name]
(APOSC Principle 2)
Does CMAPP includes reference to:
a) the operators’ responsibility for the control of risks of a major
accident
(APOSC Principle 2)
b) continuously improving control of those risks
Is there evidence of implementation of CMAPP throughout offshore
oil and gas operations? e.g. Is communication of the policy outlined,
consider recent intervention history – have there been significant
findings that would indicate the CMAPP has not been implemented
effectively?
Does the CMAPP demonstrate the duty holder has set up monitoring
arrangements to assure effectiveness of the policy?
b) SCR2015 Schedule 1 - Particulars to be addressed in a Corporate Major Accident Prevention Policy
SCR2015 Regulatory Requirement
Inspection Criteria / Minimum Information
1.
2.
3.
Ref
Objection
1. The responsibility of officers of the duty holder for ensuring, on a continuous basis, that the corporate major accident prevention policy is suitable,
implemented, and operating as intended.
2. Formal command and control systems that include officers and senior management of the duty holder.
3. Measures for building and maintaining a strong safety culture with a high likelihood of continuous safe operation.
4. The approach to competency at all levels of the duty holder’s organisation.
5. Measures for rewarding and recognising desired behaviours.
6. The evaluation of the duty holder’s capabilities and goals.
7. The extent and intensity of process auditing.
8. Measures for maintenance of safety and environmental protection standards as an organisational core value.
9. The extent to which the particulars in paragraphs 1 to 8 are applied in the duty holder’s offshore oil and gas operations conducted outside the European
Union.
Clarification
Schedule 1 - Particulars to be addresses in a Corporate Major Accident Prevention Policy
Criteria Met / Not Met - Inspection Comments
Is responsibility allocated at senior level for suitability, implementation
and operation of CMAPP
(APOSC Principle 2)
Is there a commitment for formal command and control systems that
includes board members and senior management of the organisation
Is there a commitment to address measures for building and
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Document Title: Well Notification Management System & CMAPP Inspection Template
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4.
5.
6.
7.
8.
DECC / HSE / OSDR Logos
TRIM Numbers Topic Specialist – [Name]
maintaining a strong safety culture?
Is there a commitment to ensure competency at all levels of the
organisation and identify an approach to ensure it is achieved?
Is there a commitment to implement measures for rewarding and
recognising desired behaviours?
Is there a commitment to have a system to evaluate the
organisation’s capabilities and goals?
Is there a commitment for process auditing of an appropriate extent
and intensity?
Are standards in safety and environmental protection identified as
organisational core values and is there a commitment to implement
measures to maintain this?
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Document Title: Well Notification Management System & CMAPP Inspection Template
DECC / HSE / OSDR Logos
WN Title - [WN Title]
Well Operator – [Company Name]
TRIM Numbers Topic Specialist – [Name]
2. Management System Requirements
a) SCR2015 Regulation 8 – Safety and environmental management system
Inspection Criteria / Minimum Information
1.
2.
3.
5.
Ref
Objection
Clarification
SCR2015 Regulatory Requirement
8.—(1) The duty holder must prepare a document setting out its safety and environmental management system.
(2) In the case of a body corporate or unincorporate, the safety and environmental management system must include the organisational structure,
responsibilities, practices, procedures, processes and resources for determining and implementing the corporate major accident prevention policy.
(3) The safety and environmental management system is to be integrated with the overall management system of the duty holder.
(4) The safety and environmental management system must address the particulars in Schedule 3 and must be prepared in accordance with the matters set out
in Schedule 2.
(5) The document setting out the safety and environmental management system must include a description of—
(a)
the organisational arrangements for the control of major hazards;
(b)
the arrangements for preparing and submitting documents under the relevant statutory provisions; and
(c)
the verification scheme (which description must comply with regulation 13(1)).
(6) This regulation applies to a well operator—
(a)
as if the reference to the duty holder in paragraph (1) were a reference to a well operator; and
(b)
as if the reference to the description of the verification scheme in paragraph (5)(c) were a reference to the description of the well
examination scheme (which description must comply with regulation 13(2)).
Criteria Met / Not Met - Inspection Comments
Is there a document setting out the safety and environmental
management system (SEMS)?
Does the SEMS document demonstrate that the management system
includes the following to allow the CMAPP to be determined and
implemented:
a) organisational structure
(APOSC Principle 2)
b) responsibilities,
(APOSC Principle 2)
c) practices, procedures, processes,
(APOSC Principle 2)
d) resources
Is the SEMS integrated with the overall management system of the
duty holder?
Cross reference Schedule 3 inspection to confirm all requirements
met.
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Document Title: Well Notification Management System & CMAPP Inspection Template
DECC / HSE / OSDR Logos
WN Title - [WN Title]
Well Operator – [Company Name]
6.
TRIM Numbers Topic Specialist – [Name]
Does the document setting out the SEMS include:
a) a description of the organisational arrangements for the control
of major hazards?
(APOSC Principles 2-7)
b) SCR2015 Schedule 3 - Particulars to be addressed in a Safety and Environmental Management System
SCR2015 Regulatory Requirement
Inspection Criteria / Minimum Information
1.
Does the description of the SEMS show that the organisational
structure and the personnel roles and responsibilities have been
addressed?
(APOSC Principle 2)
2.
Does the description of the SEMS show that the identification and
evaluation of major hazards as well as their likelihood and potential
consequences have been addressed.
(APOSC Principle 2)
3.
Does the description of the SEMS show that controls of the major
hazards during normal operations have been addressed?
(APOSC Principle 2)
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Ref
Objection
1. Organisational structure and personnel roles and responsibilities.
2. Identification and evaluation of major hazards as well as their likelihood and potential consequences.
3. Integration of environmental impact into major accident risk assessments in the safety case.
4. Controls of the major hazards during normal operations.
5. Emergency planning and response.
6. Limitation of damage to the environment.
7. Management of change.
8. Monitoring of performance.
9. Audit and review arrangements.
10. The measures in place for participating in tripartite consultations and how actions resulting from those consultations are put into effect.
Clarification
Schedule 3 – Particulars to be addressed in a Safety and Environmental Management System
Criteria Met / Not Met - Inspection Comments
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Document Title: Well Notification Management System & CMAPP Inspection Template
WN Title - [WN Title]
Well Operator – [Company Name]
4.
5.
6.
7.
DECC / HSE / OSDR Logos
TRIM Numbers Topic Specialist – [Name]
Does the description of the SEMS show that a management of
change process have been addressed?
(APOSC Principle 2)
Does the description of the SEMS show that emergency planning and
response have been addressed?
(APOSC Principle 2)
Does the description of the SEMS show that monitoring of
performance has been addressed?
(APOSC Principle 2)
Does the description of the SEMS show that audit and review
arrangements have been addressed?
(APOSC Principle 2)
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Document Title: Well Notification Management System & CMAPP Inspection Template
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Well Operator – [Company Name]
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TRIM Numbers Topic Specialist – [Name]
MANAGEMENT SYSTEM AND CMAPP REQUIREMENTS - INSPECTION SUMMARY
SCR2015 Regulatory Requirement
Clarification
Required
Objection
Required
Conclusion
1. CMAPP Requirements
a) Regulation 7 – Corporate major accident prevention
policy
b) Schedule 1 - Particulars to be addressed in a
Corporate Major Accident Prevention Policy
2. Management System Requirements
a) Regulation 8 – Safety & Environmental Management
System
b) Schedule 3 - Particulars to be addressed in a Safety and
Environmental Management System
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