Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
EMERGENCY RESPONSE (ER) TOPIC ASSESSMENT TEMPLATE
FOR SAFETY CASE FOR A PRODUCTION OR A NON-PRODUCTION INSTALLATION OR REVISIONS – SCR05 TO SCR15
TRANSITIONS FOR APPROVED SAFETY CASES SHOULD USE THE ER TRANSITION TEMPLATE
Work Instructions
Topic specialists should use this template to record their assessment of the Emergency Response aspects of a transitional safety case. Assessment should
be against the requirements of SCR2015.
Exemplar Approach - This template should be used in accordance with the scope of the Assessment Instructions when the topic is included for assessment.
An exemplar approach may be sufficient if some material has been previously accepted and has not materially changed.
The template is one of a series covering all assessment topics, which together form a complete record of the safety case assessment and create evidence of
how the decision to accept the case, or not, was reached. The templates identify the specific regulatory requirements of SCR2015 for the topic and indicate
what the competent authority expects to find within a safety case to demonstrate that those requirements are met. The template complements the published
guidance that supports the regulations and topic sector guidance. The templates are available to promote transparency and assist duty holders in drafting
submissions.
Green text indicates regulatory requirements that are new in SCR2015.
Black text represents regulatory requirements that are contained in both SCR2005 and SCR2015.
Non Acceptance Issue - A Non Acceptance Issue (NAI) is a deficiency in the demonstration made within a safety case, which, if not resolved, will prevent the
case from being accepted under the relevant statutory provisions. Non Acceptance Issues must be sent by a formal letters to the duty holder requiring them
to be dealt with in the appropriate manner, giving the duty holder a clear understanding of how to address the deficiency.
Clarification - A Clarification is an explanation provided by a duty holder on request during assessment to enable the assessing Inspectors to be confident of
their interpretation of the information in a safety case. Clarifications are a routine part of assessment work and should be raised with a duty holder promptly.
Clarifications do not require formal letters. Communicating by telephone and email is sufficient. A meeting between the duty holder and relevant topic
specialists may also be appropriate in some circumstances for clarifications. Clarification is not a first stage before raising non-acceptance issues. Any
aspect that could credibly lead to a Non-Acceptance Issue should be raised as such in the first instance.
Relevant Pre-Existing Guidance
Relevant APOSC Principles and GASCET Sections are identified on the template sheets which follow.
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Page 1 of 26
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Some aspects of the duty holder’s management system will
relate to compliance with those parts of certain statutory
provisions which deal with emergency response. While not
a comprehensive list, the main statutory provisions within
this category are: PPEWR 1992, PFEER 1995, MAR 1995,
DCR 1996, and MHSWR 1999. The relevant parts of
PFEER 1995 are covered explicitly by SCR2015. A review
of the other statutory provisions shows that some
Regulations relating to offshore emergency response are
covered by PFEER 1995, or are outside the scope of
assessment covered by this template – see the review in
the attached Table 1. However, as per Table 1,
Assessor should check safety case for (a) suitable
arrangements for collecting and keeping meteorological
and oceanographic information, and for ensuring that it is
available on the installation, and (b) for confirmation that
the helideck is suitably certified.
APOSC Principle 2 is relevant.
GASCET Section 2.4.5 is relevant.
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Page 2 of 26
NAI
Regulation 16 (1) “ The duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraphs (2) and (3), include in the
safety case sufficient particulars to demonstrate that—
(a) The duty holder’s management system is adequate to ensure—
(i) that the relevant statutory provisions will, in respect of matters within his the duty holder’s control, be complied with; and
(ii) the satisfactory management of arrangements with contractors and sub-contractors;”
Clarification
SCR 2015 Regulatory Requirement: Regulation 16
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Table 1. Emergency related aspects of certain legislation, excluding PFEER.
Statutory
provision.
MAR 1995
DCR 1996
MHSWR
1999
PPEWR
1992
Regulation
Aspect relevant to EER
Notes
Reg 6
Managers to be competent
Reg 13
Control of helicopter operations
Reg 14
Operational information
Reg 5
Appropriate design
Reg 8
Maintaining installation integrity.
Reg 11(b)
Helicopter landing area
Reg 3
Risk assessment.
Reg 7
Reg 8
Procedures for evacuation etc
Information for employees
Reg 11
Reg 4
Training/refresher training
Provision of PPE*
Reg 5
Reg 6
Reg 7
Compatibility of PPE*
Assessment of PPE*
Maintenance and replacement of
PPE*
Accommodation for PPE*
Emergency response aspects are covered by PFEER Regulation 6 and Template
Sheet 17
Emergency response aspects are covered by PFEER 1995 Regulation 6 and
Template Sheet 17.
This Regulation includes a requirement for the duty holder to collect and keep
meteorological and oceanographic information. Such information is relevant to the
installation emergency response arrangements. Check that the safety case
describes suitable arrangements for collecting and keeping this information, and
for ensuring that it is available on the installation.
Installation integrity has some relevance to emergency response, such as
requiring adequate integrity to resist ship collision. However, this is outwith ER
Section topic area.
Maintenance of installation integrity has some relevance to emergency response,
such as maintaining lifeboat davits. However, this is out ER Section topic area.
Helideck size and clear approach aspects – check for confirmation in the safety
case that the helideck is suitably certified.
The PFEER Assessment provides emergency response related risks assessment.
This Assessment is covered by PFEER Regulation 5 and Template Sheet 16.
Covered by PFEER Regulations 6 and 8, and Template Sheets 17 and 19.
Emergency response aspects are covered by PFEER Regulation 6 and Template
Sheet 17.
As above.
Emergency response aspects are covered by PFEER Regulation 17 and Template
Sheet 27.
As above.
This is covered by PFEER Regulation 5 and Template Sheet 16.
This level of detail is not usually explored in a safety case assessment.
Reg 8
Reg 9
Information, instruction, training in
use of PPE*
Location of PPE* is critical to the emergency response arrangements – this falls
within PFEER Regulations 5 and 17 and Template Sheets 16 and 27. However,
details of the boxes in which PPE is stored etc. is a level of detail which is not
usually explored in a safety case assessment.
Emergency response aspects are covered by PFEER Regulation 6 and Template
Sheet 17.
Key: * PPE for use in an emergency, including PPE for survival in the sea.
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Page 3 of 26
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
NAI
SC Ref
NAI
Assessment Criteria / Minimum Information
Clarification
Regulation 16 (1) “ The duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraphs (2) and (3), include in the
safety case sufficient particulars to demonstrate that—
….
(b) he has established adequate arrangements for audit and for the making of reports thereof; …”
Clarification
SCR 2015 Regulatory Requirement: Regulations 16(1)(b)
Criteria Met / Not met - Assessment Comments
The Assessor should determine whether the safety case
confirms sufficient auditing of the emergency response
arrangements.
APOSC Principle 2 is relevant.
SCR 2015 Regulatory Requirement: Regulation16(1)(c)
Safety Case to contain:
Regulation 12 (1) “ The duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraphs (2) and (3), include in
the safety case sufficient particulars to demonstrate that—
….
(c) all hazards with the potential to cause a major accident have been identified; … “
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
The Assessor should check that all such hazards have
been identified. There may be some relevant hazards which
are not obvious to other disciplines, such as the hazard of
dropping a lifeboat during lifeboat familiarisation training.
APOSC Principle 4 is relevant.
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Page 4 of 26
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
statutory provisions will be complied with, …”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
The Assessor should check that the information in the
safety case is sufficient to demonstrate that the necessary
measures related to emergency response and related
aviation & marine issues have been of will be provided.
The Assessor should refer to the guidance in GASCET
Sections 2.2.4 “Vessel Impact”, 2.3.4 “Emergency
Response” & 2.4.5 “Helicopter Risks” to assist with
identifying those measures. The Assessor should also
check that when major accident risks are evaluated,
adequate account is taken of the risk associated with the
necessary emergency response.
APOSC Principles 5 – 15, 18 – 21, 24, 25 & 31 are
relevant.
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NAI
Regulation 16 (1) “ The duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraphs (2) and (3), include in
the safety case sufficient particulars to demonstrate that—
….
(d) all major accident risks have been evaluated and measures have been, or will be, taken to control those risks to ensure that the relevant
Clarification
SCR 2015 Regulatory Requirement: Regulation 16(1)(d)
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
SCR 2015 Regulatory Requirement: Schedule 6(2). Schedule 7(2)
NAI
SC Ref
NAI
Assessment Criteria / Minimum Information
Clarification
“The maximum number of persons—
(a) expected to be on the installation at any time;
(b) that may be on the installation at any time; and
(c) for whom accommodation is to be provided.”
Clarification
Safety case to contain:
Criteria Met / Not met - Assessment Comments
Assessor to check if information, of the kind listed above,
has been included in the safety case sufficient to enable
the emergency response, aviation & marine aspects of the
safety case to be adequately assessed.
APOSC Principle 1 is relevant.
SCR 2015 Regulatory Requirement: Schedule 6(3). Schedule 7(3) Regulation 7(2)(a).
Schedule 7(3) “A copy of the owner’s corporate major accident prevention policy.”
Regulation 7(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 these aims are to be achieved and those
arrangements put into effect by the officers of the duty holder.
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to review the policy to determine that it contains a
suitable policy in relation to emergency response. The
policy may outline the Emergency Response Management
arrangements - GASCET Section 2.3.4 F1 provides
guidance.
APOSC Principle 2 is relevant.
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SCR 2015 Regulatory Requirement: Schedule 6(6). Schedule 7(6). Regulation 13(1).
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Safety case to contain:
Schedule 7(6) “A description of the verification scheme which complies with regulation 13(1).”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
The Assessor will not be concerned with most of the detail
of the verification scheme, but should check that the
appropriate parts of the emergency response
arrangements have been designated as safety critical
elements.
SCR 2015 Regulatory Requirement: Schedule 6(8). Schedule 7(7)
Safety case to contain:
(c) a description of how the duty holder has ensured, or will ensure, the suitability of the safety and environmental-critical elements; and …………..
Schedule 6(8)(e) or Schedule 7(7)(d) relevant codes, standards and guidance used in the construction and commissioning of the installation.”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to review:
(a) The limits for safe operation, particularly in relation to
weather, to confirm the limits are consistent with securing
continued effectiveness of the emergency response.
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NAI
(a) any limits for safe operation or use specified therein; …………..
Clarification
“A description of the main requirements in the specification for the design of the installation and its plant, which must include—
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
(b) The safety critical elements identified in the safety case
to ensure they suitably encompass the emergency
response facilities.
(c) The relevant codes, standards, and guidance used in
the construction and commissioning of the emergency
response, aviation & marine facilities to ensure they are
sufficient and suitable.
See GASCET Sections 2.2.4 “Vessel Impact”, 2.3.4
“Emergency Response” & 2.4.5 “Helicopter Risks” for
guidance on these aspects.
APOSC Principles 1, 21 - 25 are relevant.
SCR 2015 Regulatory Requirement: Schedule 6(10) and Schedule 7(8)
(a) the limits of the environmental and meteorological conditions beyond which the installation cannot safely be stationed or operated;
(b) the properties of the sea-bed and subsoil which are necessary for the safe stationing and operation of the installation; and
(c) the locations in which the installation may be stationed and operated safely. (Non-production only)
Assessment Criteria / Minimum Information
SC Ref
NAI
Clarification
“ Particulars of—
Criteria Met / Not met - Assessment Comments
Assessor to check if information, of the kind listed above,
has been included in the safety case sufficient to enable
the emergency response, aviation & marine aspects of the
safety case to be adequately assessed.
The limiting conditions are important in that emergency
procedures may be necessary to cover those situations in
which the limiting conditions are expected to be exceeded.
APOSC Principle 1 is relevant.
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SCR 2015 Regulatory Requirement: Schedule 7(9) – Non-Production Installation Only
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Schedule 7(9) “ A description of the arrangements for—
(a) identifying the risks from seabed and marine hazards, including the routes and locations of pipelines, moorings of adjacent installations, wells
and other subsea equipment; and
(b) assessing the risks that they pose to the installation.
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to check that adequate arrangements are
described. For example, should the installation be stationed
in a shipping lane it will be necessary for the increased ship
collision risk to be taken into account.
APOSC Principle 1 is relevant.
Clarification
“A description, with suitable diagrams, of the installation, including a description of—
(a) the main and secondary structure of the installation and its materials;
(b) its plant;
(c) the layout and configuration of its plant; and
(d) in the case of a mobile installation, its means of transfer between locations and its stationing system.
NAI
SCR 2015 Regulatory Requirement: Schedule 6(11) and Schedule 7(10)
Schedule 7(11) “Particulars of the types of operation, and activities in connection with an operation which the installation is capable of performing”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to check if information, of the kind listed above,
has been included in the safety case sufficient to enable
the emergency response, aviation & marine aspects of the
safety case to be adequately assessed.
APOSC Principle 1 is relevant.
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SCR 2015 Regulatory Requirement: Schedule 6(15) and Schedule 7(13)
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
“A description of how the duty holder has ensured, or will ensure, compliance with regulation 4(1) of the PFEER Regulations.”
“PFEER Regulation 4 General duty
(1) The duty holder shall take appropriate measures with a view to (a) protecting persons on the installation from fire and explosion; and
(b) securing effective emergency response.”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
PFEER Regulation 4(1)(b) is relevant to the emergency
response topic. PFEER Regulation 4(1)(b) is also relevant,
but is assessed separately within Energy Division.
Assessor to review the measures, as described in the
safety case for securing effective emergency response, to
determine if they are adequate.
Other Schedule items specific some specific emergency
response measures. This Schedule item provides a catchall requiring consideration of relevant measures which are
not already called for by other Schedule items.
The Assessor should take account of the guidance in
GASCET Sections 2.2.4 “Vessel Impact”, 2.3.4
“Emergency Response” & 2.4.5 “Helicopter Risks”.
APOSC Principles 2, 15 – 25 & 31 are relevant.
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SCR 2015 Regulatory Requirement: Schedule 6(18) and Schedule 7(15)
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Safety case to contain:
“A description of the plant used and arrangements made for protecting persons on the installation from hazardous substances, including toxic gas, at all
times.”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to review the available information about extent
and toxicity of hazardous substances on the installation,
and to check that there are adequate emergency
arrangements, as described in the safety case, to mitigate
the effect of an accidental release.
APOSC Principle 1 is relevant
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to review the above arrangements, as described
in the safety case, to determine if they are adequate. This is
a change from SCR 2005 in that the definition of hazards is
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NAI
“A description of the measures taken or to be taken or the arrangements made or to be made for the protection of persons on the installation from
hazards, including explosion, fire, heat, smoke, toxic gas or fumes in particular while there may be a need to remain on the installation following an
incident which is beyond immediate control and for enabling such persons to be evacuated or rescued from the installation where necessary, including
provision for—
(a) temporary refuge;
(b) routes from locations where persons may be present to temporary refuge and for egress therefrom to points from where the installation may be
evacuated;
(c) means of evacuation at those points; and
(d) facilities within temporary refuge for the monitoring and control of the incident and for organising evacuation.”
Clarification
SCR 2015 Regulatory Requirement: Schedule 6(19) and Schedule 7(16)
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
no longer restricted to just the named hazards.
See GASCET Section 2.3.4 “Emergency Response”
Sections F2, F3, F4, F5 for guidance on the expected
arrangements.
Assessor to liaise with the Fire & Explosion Assessor, and
Control & Instrumentation Assessor, since there will be
potential overlaps with their assessments.
Clarification
SCR 2015 Regulatory Requirement: Schedule 6(21) and Schedule 7(17)
“The description of the internal emergency response arrangements.”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to review the description of the installation
emergency response arrangements. This description
should describe the manner of performance of the internal
emergency response duties. The duties are those specified
by certain of the PFEER regulations. Guidance on how to
assess the performance of each of these various duties is
given in template sheets which follow (excepting those
duties associated with PFEER Regulations 9 and 13, these
being outwith the emergency response topic). This template
sheet should simply summarise the results recorded on
these later template sheets.
Those arrangements exclusively associated with the oil
pollution emergency plan are outwith the scope of this
template. However, the Assessor will need to liaise with the
DECC Assessor since emergency arrangements to protect
the workforce and installation may have an influence on the
oil pollution emergency plan.
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APOSC Principles 1, 21 – 24 are relevant.
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Guidance is provided in GASCET Section 2.3.4
“Emergency Response” and in the Approved Code of
Practice and Guidance to the PFEER Regulations
(Document L65). The assessor should also review
relevant aspects of the aviation & marine topics which
relate to emergency response.
APOSC Principles 1, 15, 17 – 25 are relevant.
SCR 2015 Regulatory Requirement: Schedule 6(23) and Schedule 7(19)
Assessment Criteria / Minimum Information
SC Ref
NAI
“Particulars of any combined operations which may involve the installation, including—
(a) a summary of the arrangements in place for co-ordinating the management systems of all duty holders involved in any such combined operation;
(b) a summary of the arrangements in place for a joint review of the safety aspects of any such combined operation by all duty holders involved, which
must include the identification of hazards with the potential to cause a major accident and the assessment of risks which may arise during any such
combined operation;
(c) the plant likely to be used during any such combined operation; and
(d) the likely impact any such combined operation may have on the installations involved.”
Clarification
Safety case to contain:
Criteria Met / Not met - Assessment Comments
While recognising that this safety case may reasonably
contain only a generic approach to combined operations,
Assessor to review the above information to confirm that it
includes adequate consideration of the impact of a
combined operation on the emergency response, aviation &
marine arrangements.
APOSC Principles 27 – 32 are relevant.
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SCR 2015 Regulatory Requirement: Regulation 30(14) (a) PFEER Regulation 5
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
PFEER Regulation 5 Assessment
“(1) The duty holder shall perform, and thereafter repeat as often as may be appropriate a process (in this regulation called “Can assessment”)
described in paragraph (2) in relation to the installation.
(2) An assessment shall consist of(a) the identification of the various events which could give rise to (i) a major accident involving fire or explosion; or
(ii) the need (whether or not by reason of fire or explosion) for evacuation, escape or rescue to avoid or minimise a major accident;
(b) the evaluation of the likelihood and consequences of such events;
(c) the establishment of appropriate standards of performance to be attained by anything provided by measures for (i) ensuring effective evacuation, escape, recovery and rescue to avoid or minimise a major accident; and
(ii) otherwise protecting persons from a major accident involving fire or explosion; and
(d) the selection of appropriate measures.
(3) The duty holder shall(a) record the assessment (including each repetition of it);
(b) keep the record at an address in Great Britain; and
(c) notify the Executive of such address”.
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to examine safety case for evidence of a suitable
PFEER Assessment, related to emergency response, having
been carried out. Such evidence may include:
(i) Summary of the assessment process applied, including
approach to hazard identification and evaluation.
(ii) List of the safety critical elements and other measures for
ensuring effective evacuation, escape, recovery and rescue to
avoid or minimise a major accident, for which performance
standards have been provided.
(iii) Confirmation that those items listed in Paragraph 56 of the
Approved Code of Practice and Guidance to the PFEER
Regulations (Document L65) are addressed in the PFEER
Assessment.
(iv) Examples of performance standards arising from the PFEER
Assessment.
(v) Details of where the record of the PFEER Assessment is
located.
APOSC Principles 5 – 15, 21 - 25 are relevant.
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SCR 2015 Regulatory Requirement: Regulation 30(14) (b)– PFEER Regulation 6
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Safety case to contain:
A description of the manner of performance of the duties in PFEER Regulation 6.
Regulation 6 Preparation for emergencies
“(1) The duty holder shall establish such appropriate organisation and arrangements as are to have effect in, or in anticipation of, an emergency and
which shall include arrangements (a) for command by competent persons which can be maintained, so far as is practicable, throughout an emergency;
(b) for there to be a sufficient number of persons on the installation competent to undertake emergency duties and operate relevant equipment;
(c) in the case of an installation on which personnel are present, for a sufficient number of such persons to be in attendance at the helicopter landing area
during helicopter movements; and
(d) for lists of persons referred to in sub-paragraphs (a), (b) and (c) above to be posted at suitable locations on the installation when persons are present.
(2) The duty holder shall ensure that every person on the installation (a) is provided with adequate instruction and training in the appropriate action to take in an emergency; and
(b) can consult written information on the use of emergency plant.”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to examine safety case for evidence of suitable
preparation for emergencies, as per above. GASCET
Section 2.3.4 “Emergency Response” F1 “ Emergency
Response Management” and Document L65 provide
guidance. PFEER Reg. 6 is also relevant to the Aviation &
Marine topics.
APOSC Principle 21 is relevant.
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SCR 2015 Regulatory Requirement: Regulation 30(14) (c)– PFEER Regulation 7
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Regulation 7 Equipment for helicopter emergencies
“The duty holder shall ensure that there is kept available near the helicopter landing area equipment necessary for use in the event of an accident involving
a helicopter.”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to examine safety case for evidence that the
above equipment is provided.
It may be sufficient for the safety case to state that
equipment necessary for use in the event of an accident
involving a helicopter is provided as specified by CAP437.
Document L65 provides guidance. See also GASCET
2.4.5 “Helicopter Risks”
APOSC Principle 1 is relevant.
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
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NAI
Regulation 8 Emergency response plan
“(1) The duty holder shall, after consulting persons who are likely to become involved in emergency response, prepare and, as often as is
appropriate, revise a document (in this regulation called “the emergency response plan”) containing sufficient information, for the guidance of such
persons, on (a) the organisation and arrangements which are to have effect in an emergency; and
(b) procedures by way of emergency response to be followed in different circumstances.
(2) The duty holder shall ensure that (a) the emergency response plan is available to all persons on the installation; and
(b) each person on the installation, and each person who may be called upon to assist in implementing the emergency response plan, are given
such notification of its contents as are sufficient for them.
(3) The duty holder shall ensure that the organisation, arrangements and procedures referred to in paragraph (1) are tested, by practice and
otherwise, as often as may be appropriate.
(4) Every person on the installation shall, in an emergency, so far as is practicable, conform to the appropriate procedure in the plan.”
Clarification
SCR 2015 Regulatory Requirement: Regulation 30(14) (d)– PFEER Regulation 8
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Assessor to examine safety case for evidence that a
suitable Emergency Response Plan is provided, as per
above, including arrangements to ensure adequate
availability, notification, and testing of the plan. Evidence
may include a list of those hazards which are covered by
the Plan. The Plan should take appropriate account of
compromised stability and/or likely structural failure,
whether in isolation or related to an initiating hazard such
as fire/explosion or ship collision. To the extent practicable,
emergency response plans should provide continued
effectiveness in the event of severe meteorological
conditions.
GASCET Section 2.3.4 “Emergency Response” F1 “
Emergency Response Management” and Document L65
provide guidance.
APOSC Principles 19 – 21, 25 are relevant.
SCR 2015 Regulatory Requirement: Regulation 30(14) (f)– PFEER Regulation 10
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Several disciplines will be involved with assessing
compliance of the safety case with this requirement,
including C&I, Fire & Explosion, and Process.
Assessor to liaise with other Assessors as above, and to
examine the case for evidence of adequate arrangements
for detection of incidents which may require emergency
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“The duty holder shall take appropriate measures (a) with a view to detecting fire and other events which may require emergency response, including the provision of means for (i) detecting and recording accumulations of flammable or toxic gases; and
(ii) identifying leakages of flammable liquids; and
(b) with a view to enabling information regarding such incidents to be conveyed forthwith to places from which control action can be instigated.”
Clarification
Regulation 10 Detection of incidents
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
response, including arrangements for advanced warning of
potential ship collision.
GASCET Section 2.3.4 “Emergency Response” F2 “ Alarms
and Communication” and F8 “Ship collision”, GASCET
Section 2.2.4 “Vessel Impact” Document L65 provide
guidance.
APOSC Principle 18 is relevant.
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to liaise with C&I Assessor, and to examine
the case for evidence of (i) adequate arrangements for
giving warning of an emergency, and (ii) adequate
emergency communication systems with persons as per
above. Evidence will include a description the
communication systems available during an emergency,
and a description of the alarm sounds and lights. Evidence
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NAI
Regulation 11 Communication
“(1) The duty holder shall make appropriate arrangements (a) for giving warning of an emergency, by audible and, where necessary, visual alarm systems, to all persons on the installation; and
(b) for the purpose of emergency response, for communication between (i) persons on the installation;
(ii) the installation and persons not on it and engaged in activities in connection with it; and
(iii) the installation and persons beyond it;
and shall ensure that, so far as is reasonably practicable, the arrangements are capable of remaining effective in an emergency.
(2) Subject to paragraph (3), the duty holder shall ensure that (a) an illuminated sign provided pursuant to paragraph (1) (a) is(i) in the case of a warning of toxic gas, a red flashing sign; and
(ii) in all other cases, a yellow flashing sign; and
(b) an acoustic signal provided pursuant to paragraph (1) (a) is (i) in the case of a warning to prepare for evacuation, a continuous signal of variable frequency;
(ii) in the case of a warning of toxic gas, a continuous signal of a constant frequency; and
(iii) in all other cases, an intermittent signal of a constant frequency.
Clarification
SCR 2015 Regulatory Requirement: Regulation 30(14) (g)– PFEER Regulation 11
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
should include details of how the alarm and communication
systems are made sufficiently robust under emergency
conditions.
GASCET Sections 2.3.4 F1, F2, and F8, and Document
L65 provide guidance.
APOSC Principles 3, 20 are relevant.
SCR 2015 Regulatory Requirement: Regulation 30(14) (h)– PFEER Regulation 12
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Several disciplines will be involved with assessing
compliance of the safety case with this requirement,
including C&I, Fire & Explosion, and Process.
Assessor to liaise with other Assessors as above, and to
examine the case for evidence of adequate emergency
response procedures, such as a statement confirming that
the detailed emergency response procedures have been
documented and are in a form readily accessible to the
appropriate personnel. Assessor will also need to confirm
that personnel with essential emergency duties (such as
the Central Control Room personnel) are sufficiently
protected from the effect of a major accident.
Document L65 provides guidance.
APOSC Principle 20 is relevant.
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“The duty holder shall (a) take appropriate measures with a view to limiting the extent of an emergency, including such measures to combat fire and
explosion; and
(b) shall ensure that(i) where appropriate, those measures include provision for the remote operation of plant; and
(ii) so far as is reasonably practicable, any arrangements made and plant provided pursuant to this regulation are capable of
remaining effective in an emergency.”
Clarification
Regulation 12 Control of emergencies
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
SCR 2015 Regulatory Requirement: Regulation 30(14) (i)– PFEER Regulation 13
NAI
SC Ref
NAI
Assessment Criteria / Minimum Information
Clarification
“The duty holder shall (a) take appropriate measures with a view to protecting persons on the installation during an emergency from the effects of fire and
explosion; and
(b) ensure that, so far as is reasonably practicable, any arrangements made and plant provided pursuant to this regulation are capable of
remaining effective in an emergency..”
Clarification
Regulation 13 Mitigation of fire and explosion
Criteria Met / Not met - Assessment Comments
Mainly other disciplines will be involved with assessing
compliance of the safety case with this requirement,
primarily Fire & Explosion, and C&I.
Assessor to liaise with other Assessors as above, and to
examine the case for evidence of features such as
adequate protection of key locations (eg temporary refuge
and escape routes), and suitable contingency measures
should these be necessary to ensure measures as above
remain effective in an emergency.
Document L65 provides guidance.
APOSC Principles 19 – 24 are relevant.
SCR 2015 Regulatory Requirement: Regulation 30(14) (j)– PFEER Regulation 14
Regulation 14 Muster areas etc.
“(1) The duty holder shall make appropriate provision for (a) areas for persons to muster safely in an emergency (in these Regulations referred to as “muster areas”);
(b) safe egress from accommodation and work areas, and safe access to muster areas, temporary refuge, and evacuation and
escape points; and
(c) safe evacuation and escape points.
(2) The duty holder shall ensure that the muster areas, egress, access and evacuation and escape points referred to in paragraph (1) (a) are kept unobstructed;
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
(b) are provided with adequate emergency lighting; and
(c) are marked by suitable signs,
and shall take appropriate measures to ensure that, so far as is reasonably practicable, the egress and access remain passable in
an emergency.
(3) The duty holder shall ensure that (a) doors for use in an emergency (i) open in the appropriate direction or, if this is not possible, are sliding doors; and
(ii) are not so fastened that they cannot readily be opened by any person who may require to use them in an emergency; and
(b) accommodation areas are provided at each level with at least two means of egress situated a proper distance apart.
(4) The duty holder shall (a) ensure that(i) each person on the installation is assigned to a muster area; and
(ii) for each muster area a list of names of persons assigned to it is kept up-to-date and displayed; and
(b) establish procedures (i) for mustering at such areas; and
(ii) for accounting for persons.”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to examine the case for evidence of the features
described above. Assessor to liaise with C&I Assessor re.
emergency lighting; and to liaise with Fire & Explosion
Assessor re. protection from these hazards.
GASCET Sections 2.3.4 F3 and F4, and Document L65
provide guidance.
APOSC Principles 19 – 24 are relevant.
SCR 2015 Regulatory Requirement: Regulation 30(14)(k) – PFEER Regulation 15
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
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“The duty holder shall ensure that such arrangements are made which include, to the extent necessary (a) the provision of plant on the installation; and
(b) such arrangements with suitable persons beyond the installation, as will ensure, so far as is reasonably practicable, the safe evacuation of
all persons and their being taken to a place of safety, or to a place from which they can be recovered and taken to a place of safety under
arrangements made pursuant to regulation 17.”
Clarification
Regulation 15 Arrangements for evacuation
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
Assessor to examine the case for evidence of adequate
evacuation arrangements, including hardware, procedures,
personnel, and credible evacuation times.
GASCET Section 2.3.4 F5, and Document L65 provide
guidance.
APOSC Principle 24 is relevant.
SC Ref
NAI
Assessment Criteria / Minimum Information
NAI
“The duty holder shall provide such means as will ensure, so far as is reasonably practicable, the safe escape of all persons from the installation in case
arrangements for evacuation fail.”
Clarification
Regulation 16 Means of escape
Clarification
SCR 2015 Regulatory Requirement: Regulation 30(14)(l) – PFEER Regulation 16
Criteria Met / Not met - Assessment Comments
Assessor to examine the case for evidence of adequate
means of escape.
GASCET Section 2.3.4 F6, and Document L65 provide
guidance.
APOSC Principle 24 is relevant.
SCR 2015 Regulatory Requirement: Regulation 30(14)(m) – PFEER Regulation 17
Regulation 17 Arrangements for recovery and rescue
“The duty holder shall ensure that effective arrangements are made, which include such arrangements with suitable persons beyond the
installation, for (a) recovery of persons following their evacuation or escape from the installation; and
(b) rescue of persons near the installation; and
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
(c) taking such persons to a place of safety,
and for the purposes of this regulation arrangements shall be regarded as being effective if they secure a good prospect of those persons
being recovered, rescued, and taken to a place of safety.”
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
Assessor to examine the case for evidence of adequate
arrangements for recovery and rescue, including whether
the target rescue times are consistent or otherwise with
industry guidance (such as Oil&Gas UK ERRV
Management Guidelines), and whether suitable survival
PPE (type, number, location) is provided on the installation.
GASCET Section 2.3.4 F7, and Document L65 provide
guidance.
APOSC Principle 25 is relevant.
SCR 2015 Regulatory Requirement: Regulation 30(14)(n and o) – PFEER Regulation 22B and 22C
Assessment Criteria / Minimum Information
SC Ref
Criteria Met / Not met - Assessment Comments
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Arrangements for early warning of major accidents
22C.—(1) This regulation applies only in relation to external waters.
(2) The duty holder must make arrangements—
(a)for providing early warning of a major accident to the Maritime and Coastguard Agency; and
(b)for providing more detailed information about such an accident as soon as it becomes available,
but nothing in this paragraph is to be taken as imposing a requirement which is imposed by regulation 4(3)(c) and paragraph 11 of Schedule 2 to the
Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998 (arrangements for early warning of major
environmental incidents).”
Clarification
22B.—(1) This regulation applies only in relation to external waters.
(2) The duty holder must authorise one or more persons—
(a)to initiate an emergency response;
(b)to direct an emergency response; and
(c)to liaise with the Maritime and Coastguard Agency.
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
The duty holder should describe the adequacy of their
arrangements to communicate the detail of emergency
responses to authorities and the communications systems
that underpin them
EMERGENCY RESPONSE TOPIC – ASSESSMENT SUMMARY
NAI – Non Acceptance Issue
Schedule 6 requirements for Production Installation, Schedule 7 requirements for Non-Production Installations
SCR2015 Regulatory Requirement
Clarification
Required
NAI
Required
Conclusion
Emergency response aspects of:
1. Regulation 16(1)(a)
2. Regulation 16(1)(b)
3. Regulation 16(1)(c)
4. Regulation 16(1)(d)
5. Schedule 6(2), Schedule 7(2)
Number of Persons
6. Schedule 6(3), Schedule 7(3)
Corporate Major Accident Prevention Policy
7. Schedule 6(6), Schedule 7(6), Regulation 13(1)
Verification
8. Schedule 6(8), Schedule 7(7)
Description of Plant
9. Schedule 6(10), Schedule 7(8)
Environmental Conditions
10. Schedule 6(15), Schedule 7(13)
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
PFEER Reg 4 General Duty – Compliance Statement
11. Schedule 6(18), Schedule 7(15)
Protecting persons, hazardous substances
12. Schedule 6(19), Schedule 7(16)
Protecting persons, explosion/fire/heat
13. Schedule 6(21), Schedule 7(17)
Internal Emergency Response
14. Schedule 6(23), Schedule 7(19)
Summary and effect of combined operations
15. Regulation 30(14)(a) –
PFEER Regulation 5
16. Regulation 30(14)(b) –
PFEER Regulation 6
17. Regulation 30(14)(c) –
PFEER Regulation 7
18. Regulation 30(14)(d) –
PFEER Regulation 8
19. Regulation 30(14)(f) –
PFEER Regulation 10
20. Regulation 30(14)(g) –
PFEER Regulation 11
21. Regulation 30(14)(h) –
PFEER Regulation 12
22. Regulation 30(14)(i) –
PFEER Regulation 13
23. Regulation 30(14)(j) –
PFEER Regulation 14
24. Regulation 30(14)(k) –
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Page 25 of 26
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
ER Topic Assessor – [Name]
PFEER Regulation 15
25. Regulation 30(14)(l) –
PFEER Regulation 16
26. Regulation 30(14)(m) –
PFEER Regulation 17
27. Regulation 30(14)(n and o) –
PFEER Regulation 22B and 22C
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