Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
OFFSHORE SAFETY DIRECTIVE 2015
SAFETY CASES FOR PRODUCTION AND NON-PRODUCTION INSTALLATIONS
FIRE, EXPLOSION & RISK ASSESSMENT (FERA) FULL TOPIC ASSESSMENT TEMPLATE –
ASPECTS OF SAFETY CASE SUBMISSIONS AS INDICATED IN THE SUMMARY TABLE:
This document provides the Full Topic Assessment Template (FTAT) to be completed as a record of the assessment of the FERA
elements of a Safety Case submitted to the HSE under the “Offshore Installations (Offshore Safety Directive) (Safety Case etc.)
Regulations 2015”. Where reference is made to the “assessor” this refers to the assessor responsible for the Fire, Explosion & QRA
topics. This FTAT is to be completed by the topic assessors and embedded in the Topic Assessment Record that is attached to
COIN.
The FERA assessment has been carried out to the procedures laid out in the safety case assessment manual (SCHAM), to
assessment principles of offshore safety cases (APOSC), guidance for the topic assessment of the major accident hazard aspects
of safety cases (GASCET) and the fire, explosion and risk assessment topic guidance (PMTECH12) all current at the time the
assessor completed the FTAT.
FERA assessment relevant OSDR 2015 Regulations and Schedules:
Regulations 15, 16, 17, 18, 19, 20, 22, 23, 24, 29 & 30 and Schedules 3, 5, 6, 7, 8 & 10
The Offshore installations (Offshore Safety Directive)( Safety Case etc.) Regulations 2015 (SCR2015) require that duty holders
wanting to operate in relevant waters must prepare, and have accepted, a safety case containing the particulars identified in those
regulations. In order to accept a safety case the competent authority must first satisfy itself that the safety case contains the
required information.
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
This template is the assessor’s record of their assessment of the case against the legal requirements of the fire, explosion & risk
assessment aspects contained in the safety case submitted under OSDR 2015. It identifies the specific regulations contained within
relevant statutory provisions such as OSD SCR2015, PFEER, MAR and HSMWR that relate to this topic and identifies what the CA
expects to find within a safety case to meet those requirements. This document complements the guidance produced to support the
regulations as well as existing topic sector guidance.
This template will form the complete record of the assessment process undertaken by the competent authority. It is proposed to
make these templates freely available to promote transparency and assist industry in drafting its submissions.
Key to abbreviations on sheets which follow:
CR: clarification required;
NAI: non-acceptance issue.
A non-acceptance issue (NAI) is a deficiency in the demonstration made for health, safety and environment within the safety case,
which, if not resolved, will prevent the case from being accepted under the relevant statutory provisions.
Non acceptance issues require formal communication with the operator to ensure they are dealt with in the appropriate manner
giving them every chance to address the deficiency. The operator will be given 14 calendar days to respond.
A clarification (CR) is an explanation provided to an inspector, by an operator, to allow them to be confident of their interpretation
of the demonstration provided within the safety case. Clarifications are carried out as part of the routine of assessment work and
should be raised with the operator swiftly and informally and by direct means of communication (by telephone / email) and would
normally expect a prompt response.
In complex cases the requirement for clarification can be pre-empted by setting up a meeting between the operator and relevant
topic specialists to facilitate discussion and understanding between the 2 parties before the case is submitted or in the very early
stages of the assessment.
Where any uncertainty relates to an area that has the potential to lead to a non-acceptance issue, a request for ‘clarification’ would
not be appropriate and the issue should be identified as a non-acceptance issue and raised immediately in the appropriate fashion.
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
FIRE, EXPLOSION AND QRA REQUIREMENTS – ASSESSMENT SUMMARY
SCR2015 Regulatory Requirement
1. Design notification for production installation.
Regulation 15(1) and Schedules 3, 5
2. Relocation notification for production installation.
Regulation 15(3) and Schedule 3, 5
3. Safety case for production installation
Regulations 16, 17, 29, 30 and Schedules 3, 6
4. Safety case for non-production installation
Regulations 16, 29, 30, and Schedules 3, 7
5. Design notification for non-production installation to
be converted
Regulations 16, 19(1),29, 30 and Schedules 3, 5
6. Safety case for non-production installation to be
converted
Regulations 16, 18, 19(7), 29, 30 and Schedule 3, 6
7. Notification of combined operations
Regulation 22 and Schedule 10
8. Safety case for dismantling fixed installation
Regulations 16, 20, 30, and Schedule 8
9. Safety case Thorough Review
Regulation 23. (see types 3 or 4 for specific regulations and
schedules)
10. Revision of Safety Case
Regulation 24(2) (see types 3 or 4 for specific regulations
and schedules)
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Type of
Case
Assessor:
Date:
Page 3 of 19
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
Assessment Record
Relevant SC2015 Regulations
Relevant
CR
NAI
Conclusion
1. SCR2015 Regulations
15 – Design and Relocation for
production installations
16 – MAH
17 – Production installation
18 – Non-production installation
19 – Design and safety case for
non- production installations
20 – Dismantling fixed installations
22 - COMOPS
23 – Review of safety case
24 – Revision of safety case
29 – Control risk
30 – Internal emergency response
2. SCR2015 Schedules
3 – SEMS
5 – Design or relocation of a fixed
installation
6 – Production installation
7 – Non-production installation
8 – Dismantling of a fixed installation
10 - COMOPS
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
SCR 2015 Regulatory FERA Requirement: Regulation 16
Management and control of major accident hazards
16.—(1) A duty holder who prepares a safety case pursuant to these Regulations must, subject to paragraph (2), 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 the duty holder’s control, be complied with; and
(ii) that the management of arrangements with contractors and sub-contractors is satisfactory;
(b) the duty holder has established adequate arrangements for audit and for the making of reports of the audit;
(c) all hazards with the potential to cause a major accident have been identified;
(d) all major accident risks have been evaluated, their likelihood and consequences assessed, including any environmental, meteorological and seabed
limitations on safe operations, and that suitable measures, including the selection and deployment of associated safety and environmental-critical
elements have been, or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with; and
(e) in the case of a non-production installation, all the major hazards have been identified for all operations the installation is capable of performing.
(2) Paragraph Error! Reference source not found. only requires the safety case to include the particulars referred to in that paragraph to the extent that
it is reasonable to expect the duty holder to address them at the time of sending the safety case to the competent authority.
(3) In this regulation, “audit” means systematic assessment of the adequacy of the management system to achieve the purpose referred to in paragraph
Error! Reference source not found.(a) carried out by a person who is sufficiently independent of the system (but who may be employed by the duty
holder) to ensure that such assessment is objective.
(4) The demonstration of the matters referred to in paragraph Error! Reference source not found.(d) must include the estimate of oil spill response
effectiveness contained in the oil pollution emergency plan in respect of the installation, prepared pursuant to regulation 4(3)(a) and (c) of and Schedule 2
to the Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998(a).
Assessment Guidance / Minimum Information
GASCET
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2.1.2
2.3.3
Risk Assessment including human vulnerability
Loss of Containment – Fire and Explosion
Page 5 of 19
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
2.4.1
2.4.5
2.4.6
3.2
Wells – Risk Evaluation and Management
Helicopter Risks
Non-Process Fire and Explosion
Design Case
Principles 2-23, 26 - 32
APOSC
PMTECH12
CR
SCR 2015 Regulatory FERA Requirement: Regulation 16
Assessment Criteria / Minimum Information
1. Hazard identification;
SC Ref
Criteria met / Not Met - Assessment Comments
all hazards with the potential to cause a major
accident have been identified;
in the case of a non-production installation, all the
major hazards have been identified for all operations
the installation is capable of performing.
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NAI
5 HAZARD IDENTIFICATION
8 QUANTIFIED RISK ASSESSMENT
9 RISK EVALUATION AND REDUCTION
10 RISK MANAGEMENT
12 EMERGENCY ARRANGEMEN TS
HSE ALARP GUIDANCE – See http://www.hse.gov.uk/risk/expert.htm
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
CR
SCR 2015 Regulatory FERA Requirement: Regulations 16
Assessment Criteria / Minimum Information
2. Quantified risk assessment (QRA);
SC Ref
Criteria met / Not Met - Assessment Comments
all major accident risks have been evaluated, their
likelihood and consequences assessed, including any
environmental, meteorological and seabed limitations
on safe operations,
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NAI
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
CR
SCR 2015 Regulatory FERA Requirement: Regulation 16
Assessment Criteria / Minimum Information
Risk management (concerning the measures
in place to eliminate, prevent, detect, control
and mitigate major fire and explosion hazards
SC Ref
Criteria met / Not Met - Assessment Comments
and that suitable measures, including the selection
and deployment of associated safety and
environmental-critical elements have been, or will be,
taken to control those risks to ensure that the relevant
statutory provisions will be complied with
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NAI
Case Title - [Safety Case Title]
Operator – [Company Name]
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
SCR 2015 Regulatory FERA Requirement: Regulation 29
Duty to control risk
29.—(1) Where an activity carried out by a duty holder significantly increases the risk of a major accident the duty holder must take suitable measures to
ensure that the risk is reduced as low as is reasonably practicable.
(2) The measures referred to in paragraph Error! Reference source not found. include, where necessary, suspending the relevant activity until the risk
is adequately controlled.
(3) The duty holder must notify the competent authority where it has taken measures under paragraph Error! Reference source not found..
(4) The duty holder must comply with paragraph (3) immediately after, and in any event no later than 24 hours after, adopting the measures.
(5) In this regulation (but not this paragraph) a reference to a duty holder includes a reference to a well operator.
Assessment Guidance / Minimum Information
GASCET
2.1.2
2.3.3
2.4.1
2.4.5
2.4.6
3.2
Risk Assessment including human vulnerability
Loss of Containment – Fire and Explosion
Wells – Risk Evaluation and Management
Helicopter Risks
Non-Process Fire and Explosion
Design Case
APOSC
Principles 2-23, 26 – 32
PMTECH12
5 HAZARD IDENTIFICATION
8 QUANTIFIED RISK ASSESSMENT
9 RISK EVALUATION AND REDUCTION
10 RISK MANAGEMENT
12 EMERGENCY ARRANGEMEN TS
HSE ALARP GUIDANCE – http://www.hse.gov.uk/risk/expert.htm
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Case Title - [Safety Case Title]
Operator – [Company Name]
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COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
Page 10 of 19
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
CR
SCR 2015 Regulatory FERA Requirement: Regulation 29
Assessment Criteria / Minimum Information
Risk management (concerning the measures
in place to eliminate, prevent, detect, control
and mitigate major fire and explosion
hazards, and their associated performance
standards);
SC Ref
Criteria met / Not Met - Assessment Comments
Where an activity carried out by a duty holder
significantly increases the risk of a major accident the
duty holder must take suitable measures to ensure that
the risk is reduced as low as is reasonably practicable.
The measures referred to in paragraph (1) include,
where necessary, suspending the relevant activity
until the risk is adequately controlled
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NAI
Case Title - [Safety Case Title]
Operator – [Company Name]
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
SCR 2015 Regulatory FERA Requirement: Regulation 30
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
Internal emergency response
30.—(1) The duty holder must perform the internal emergency response duties—
(a) consistently with the external emergency response plan; and
(b) taking into account the risk assessment undertaken during preparation of the current safety case for the installation.
(2) Where the duty holder has adopted other measures, the duty holder must perform the internal emergency response duties so as to secure a good
prospect of personal safety and survival, taking into account the adoption of those other measures.
(3) In paragraph (2) “other measures” means measures relating to protection and rescue of personnel from a stricken installation, apart from any
measures adopted in performance of the internal emergency response duties.
(4) Where an installation is to engage in a combined operation the duty holder for the installation must make arrangements, in advance of the
installation’s engagement in the combined operation, for coordinating escape, evacuation and rescue between the installations concerned, to secure a good
prospect of survival for persons on the installations during a major accident.
(5) Where a non-production installation is to engage in a combined operation and the description of the internal emergency response arrangements is
revised, the owner must send a revised description of the internal emergency response arrangements to the competent authority.
(6) Where a mobile non-production installation is to be used for carrying out a well operation the owner must perform the internal emergency response
duties taking into account the risk assessment undertaken during the preparation of the notification of well operations.
(7) Where a mobile non-production installation is to be used for carrying out a well operation and the description of the internal emergency response
arrangements is revised as a result of the particular nature or location of a well, the owner must send a revised description of the internal emergency
response arrangements to the competent authority.
(8) Paragraphs (5) and (7) do not apply where a revised description of the internal emergency response arrangements has been sent to the competent
authority as a revision which makes a material change to the current safety case that is required to be sent to the competent authority under regulation
Error! Reference source not found. in connection with the same operation.
(9) Subject to paragraph (10), the duty holder must send the revised description of the internal emergency response arrangements to the Maritime and
Coastguard Agency (a) as soon as is practicable.
(10) Where—
(a) the description of the internal emergency response arrangements is revised because there is a material change to any of the particulars contained in
a design notification, relocation notification, notification of well operations or notification of combined operations; but
(b) that revision makes any change to the current safety case which must be accepted by the competent authority under regulation Error! Reference
source not found., Error! Reference source not found., Error! Reference source not found. or Error! Reference source not found.,
the duty holder must not send the revised description of those arrangements to the Maritime and Coastguard Agency before the competent authority has
accepted the relevant revisions.
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Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
(11) In any case falling within paragraph (10), the duty holder must send the revised description of the internal emergency response
arrangements as soon as practicable after the competent authority has accepted the revisions.
(12) The duty holder must maintain expertise relevant to the internal emergency response duties in order for that expertise to be
available at all times and to be made available as necessary to the Maritime and Coastguard Agency.
(13) In this regulation “external emergency response plan” means the national plan setting out arrangements for responding to
incidents which cause or may cause marine pollution prepared by the Secretary of State pursuant to section 293(2)(za) of the 1995 Act,
as revised or re-issued from time to time(a), and the Search and Rescue Framework for the United Kingdom of Great Britain and
Northern Ireland as published by the Secretary of State, as revised or re-issued from time to time(b).
(14) In this regulation and regulation Error! Reference source not found. “the internal emergency response duties” means the duties in the following
regulations of the PFEER Regulations(c)—
(a) 5 (assessment);
(b) 6 (preparation for emergencies);
(c) 7 (equipment for helicopter emergencies);
(d) 8(1), (2), and (3) (emergency response plan);
(e) 9(1) (prevention of fire and explosion);
(f) 10 (detection of incidents);
(g) 11 (communication);
(h) 12 (control of emergencies);
(i) 13 (mitigation of fire and explosion);
(j) 14 (muster areas etc.);
(k) 15 (arrangements for evacuation);
(l) 16 (means of escape);
(m) 17 (arrangements for recovery and rescue);
(n) 22B (initiation and direction of emergency response, and liaison with external response authorities); and
(o) 22C (arrangements for early warning of major accidents).
Assessment Guidance / Minimum Information
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Case Title - [Safety Case Title]
Operator – [Company Name]
GASCET
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
2.1.2
2.3.3
2.4.1
2.4.5
2.4.6
3.2
Risk Assessment including human vulnerability
Loss of Containment – Fire and Explosion
Wells – Risk Evaluation and Management
Helicopter Risks
Non-Process Fire and Explosion
Design Case
APOSC
PMTECH12
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5 HAZARD IDENTIFICATION
8 QUANTIFIED RISK ASSESSMENT
9 RISK EVALUATION AND REDUCTION
10 RISK MANAGEMENT
12 EMERGENCY ARRANGEMEN TS
Page 15 of 19
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
CR
SCR 2015 Regulatory FERA Requirement: Regulation 30
Assessment Criteria / Minimum Information
EMERGENCY ARRANGEMENTS
SC Ref
Criteria met / Not Met - Assessment Comments
The duty holder must perform the internal emergency
response duties, taking into account the risk assessment
undertaken during preparation of the most current safety
case for the installation;
installations during a major accident
“the internal emergency response duties” means the duties
in the following regulations of the PFEER Regulations—
5 (assessment);
6 (preparation for emergencies);
7 (equipment for helicopter emergencies);
8(1), (2), and (3) (emergency response plan);
9(1) (prevention of fire and explosion);
10 (detection of incidents);
11 (communication);
12 (control of emergencies);
13 (mitigation of fire and explosion);
14 (muster areas etc.);
15 (arrangements for evacuation);
Where the duty holder has adopted other measures, the
duty holder must perform the internal emergency response
duties so as to secure a good prospect of personal safety
and survival, taking into account the adoption of those other
measures. ns of escape);
17 (arrangements for recovery and rescue);
22B (initiation and direction of emergency response, and
liaison with external response authorities); and
22C (arrangements for early warning of major accidents).
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NAI
Case Title - [Safety Case Title]
Operator – [Company Name]
Case Title - [Safety Case Title]
Operator – [Company Name]
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COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
Page 17 of 19
Case Title - [Safety Case Title]
Operator – [Company Name]
COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
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Criteria Not Met - Assessment Comments
Page 18 of 19
NAI
Relevant Schedule Number:
Schedule Item
SC Ref
number
CR
SCR 2015 Regulatory FERA Schedules 5, 6, 7, 8 & 10 Assessors Comments (add lines as appropriate)
Relevant Regulation:
Case Title - [Safety Case Title]
Operator – [Company Name]
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COIN Numbers - [Case] / [SVC Number]
FERA Topic Assessor – [Name]
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