INTERVENTION PLANNING TIMETABLE TO GENERATE COMPETENT AUTHORITY INTERVENTION PLANS
FOR 2015/16 AND 2016/17
Date
Intervention planning timetable
Notes and comments
Mid – Year
onwards
Overview of resourcing for the year ahead
Assumptions
i. Heads HSE Operational Units have agreed
unit level resource requirements (excl.
Predictive)
Strategic Priorities have been agreed for 2016/17 (see: http://www.hse.gov.uk/comah/caguides.htm)
HSE Specialist Team Leaders inform Regulatory Teams which Specialist Inspectors will
support their sites.
ii. Specialists Team Leaders have provided the
level of specialist resource available for
COMAH work.
Relevant HSL Team Leaders will provide Specialists with resource days for allocation to the
relevant discipline.
October
onwards
Preparing for the review of Intervention plans.
1. Regulatory Team Leaders / Regulatory Inspectors / COMAH Intervention Managers
(CIM) discuss emerging picture from current year’s interventions, site specific issues for next
year including assessment, follow-up and on-going investigation and enforcement.
2. Heads of Operational Units / Regulatory Team Leaders discuss broad priorities.
3. Heads of Operational Units provide allocations for Specialist Disciplines to
Units/Teams
4. Specialist Team Leaders and Specialist Inspectors will proactively identify any priorities
they feel should be taken forward in 2016-17 and 2017-18 Plans e.g. priority sites for
strategic programmes. Follow up work and post assessment inspection will be included in
plans.
1
Date
Intervention planning timetable
By END
October
5. Regulatory Inspectors/CIMs review Strategic priorities for the following two years.
(Note: The Competent Authority Intelligence Review Group (CAIRG) has confirmed no new
topics for 2016-17. Existing Delivery Guides should continue to be used unless directed
otherwise
6. Regulatory Inspectors/CIMs should review SR due dates for coming 3 years to identify
when pre receipt visits, assessments and post assessment inspections will be needed over
the coming two years.
Notes and comments
i. Competent Authority Strategic Priorities for
2016 -17 can be found at:
http://Intranet/comah/guidance-andtemplates.htm
7. Regulatory Inspectors/CIMs will need to assemble relevant information for the review. This
year the ‘Site overview’ section of the plan should contain relevant risk ranking scores (for
safety and the environment) and any performance ratings (available from the COIN IRF), and
for top tier sites, the SR receipt and pre-receipt dates for future reference.
8. Regulatory, EA / SEPA / NRW, inspectors and relevant Specialist Inspectors confirm
meeting dates to review plans and prepare new plan.
9. During early October 2015, EA / NRW / SEPA COMAH officers liaise with HSE (and EPR
officers) to confirm/identify sites that fall under both COMAH and EPR (Installations and
Waste only)
10. By end October 2015 – EPR/PPC officers draft CAPs in the ‘CAPs for COMAH sites’
format for EPR/PPC sites also covered by COMAH (supported by COMAH officer)
By END
November
Reviewing the Intervention Plan
i.
Regulatory Inspectors/CIMs will inform
Regulatory Team Leaders of any current
year work that has not been started and will
be formally abandoned and not transferred to
the new plan.
ii.
Any relevant site intelligence updates should
be added to the IP in Part A - Site and site
processes Overview
1. Regulatory/CIM and EA / NRW / SEPA Inspectors and relevant Specialist Inspectors
review the current intervention plan to:
-
Review and update The IP and Identify outstanding work which will not be completed by
year-end
Update (or add) information in the PIP of outstanding and new identified Interventions
SR Assessment pre-receipt, Assessment and Post Assessment Inspection work;
Identify Priority Follow–up Issues from 2015-16 inspections requiring close out
2
Date
Intervention planning timetable
-
Notes and comments
Additional relevant strategic topics
Confirm the risk ranking hazard scores and the latest performance score for any earlier
national topic inspection.
Confirm the Qtr in which the interventions will be delivered
2. Agency Inspectors must ensure that any information required to update the plan is
available.
3. EA / SEPA / NRW COMAH officers share draft CAPs with HSE regulatory inspectors and
discuss COMAH intervention plans and any COMAH/EPR overlaps
4. EA / SEPA / NRW COMAH officers provide Regulatory Inspectors/CIMs with details of
Agency Leads for topics included in the plan by the end of November. At the same time the
EA / SEPA / NRW COMAH officers confirm the contact details of the Relevant Manager
who will sign off the plan.
5. Q1 Interventions - Where it is clear high priority work will be resourced for delivery in Q1,
start the planning needed for the intervention now to avoid any delays at the start of the
work year. The actual Q1 inspection date should be agreed with the Site and inspection
team no later than mid-January 2016
6. Regulatory Inspectors/CIMs should discuss any priority / resource conflicts with Team
Leaders.
3
Date
By MID
December
Intervention planning timetable
Agreeing the DRAFT intervention plan
1. Regulatory Inspectors/CIMs should conclude this stage of the review by drafting the
2016/17 – 2017-18 Intervention Plan and where relevant discuss /agree resources days
needed to deliver the work with the relevant Specialist Inspector.
2. Regulatory Inspectors (Lead site inspector) send DRAFT two year intervention plans to
Regulatory Team Leader and EA / SEPA / NRW Managers for moderation / agreement.
BY 7th December 2015.
Between
MID
December MID
January
Moderation - resource vs. priorities
1. Regulatory Team Leader moderate team Intervention Plans to:
-
-
Ensure plans are of an appropriate scale, taking account of Risk ranking, Operators
performance and site complexity.
Moderate resource demand to match the teams resource allocation liaise with Head Of
Unit / Other Team Leaders to address resource shortfalls for priority work (i.e. SR
assessment PAI or legacy/follow-up work)
Alert Heads of Operations to serious shortages or excesses as soon as possible
2. Regulatory Team leaders will ensure the Predictive Resource Bid Pro-forma is submitted
to CEMHD5 by 18th December 2015
3. Agency team Leaders should input where appropriate to confirm Agency work / Personnel
commitments any changes should be highlighted or applied in Edit Mode
– By 18th December 2015
4. Regulatory Team Leader /Admin create Spreadsheet of Year 1 resourced jobs (Regulatory
and Specialist) plus identified Yr 1 contingency as far as possible at this stage. Any Yr 1
jobs that are Not resourced should be transferred to the planned Yr2 work. Submit this to
Notes and comments
i. This stage enables Agency Managers to
ensure that resources for Agency Inspectors
are in place to deliver their commitments.
ii. It would assist COMAH Admin teams handling
the transfer of Information to COIN, if
intervention work linked to Safety Report
Assessment was clearly identified (Prereceipt, assessment etc.)
i. Following resource allocation to YR1
Regulatory Team leaders will in conjunction
with Specialist Colleagues, identify Yr1
Contingency work.
NOTE: A new version of the Resource
Allocation Spreadsheet will be provided for each
Team / Unit and available from November.
NOTE: Predictive Resource bid is generated in
December on Resource spreadsheets
ALL Team / Unit copies of the resource
spreadsheet will be accessed from and should
be saved to the Planning TRIM folder
1.2.3.899...
NOTE: Adjustment of Contingency labelling in
4
Date
Intervention planning timetable
Heads of Operations by 15th January 2016 ABSOLUTE DEADLINE.
By END
January
Finalising Resource Demands
1. Heads of Operations and Regulatory Team Leader to agree allocations by end of Jan
and finalise Unit Spreadsheet. Note: YR 2 work will be amended to take into account YR 1
work not Resourced or classed as Contingency (see moderation above). The outcome will
be YR 1 work will carry ‘Resourced’ ‘Y’, ‘Contingency’ ‘C’ or ‘Not Resourced’ ‘N’ Flag. YR 2
work will remain untagged (see SS instructions)
2. Regulatory Team Leader send moderated Draft Intervention Plans to EA / SEPA / NRW
Team Leaders / Managers by End of January 2016
Notes and comments
the Resource allocation spreadsheet may be
required after Finalisation Review below
NOTE: Moderated Predictive resource should
be incorporated in the Team Resource
spreadsheet
NOTE: For each Site un-resourced YR1 work
will appear in YR2 and should represent the
suggested work in the second year of the site
Intervention Plan
The final version should be saved to TRIM.
CEMHD4 will assemble the National
Spreadsheet (excluding Contingency work) in
preparation for Specialist Team leaders work to
confirm specialist staffing / resourcing.
5
Date
Intervention planning timetable
By End
January
Draft Intervention Plans
1. CIMs to share Draft Intervention Plans with Dutyholders and to allow discussion of the draft
plans
Notes and comments
Refer to CIM Manual for detailed guidance on
this stage of the process
2. At this stage the plan is in Draft and may be subject to adjustment following discussions with
Duty Holders, Specialist Team leaders or Agency Inspectors
By MID
February
Finalising Specialist input to intervention planning
1. Spreadsheet information detailing planned work for 2016-17 and 2017-18 will shared with
HSE Specialist team leaders
2. Specialist Team Leaders sign off the resource picture for their teams confirming that:
a.
b.
c.
d.
Individual Specialist Inspectors have been assigned to individual intervention plans.
Named Specialist Inspectors have agreed dates for any early interventions (Apr - Jun
2015).
Total resource deployment matches that provided at the beginning of this process.
HSL resources are fully deployed and agreed with HSL team leaders.
By 26th February ABSOLUTE DEADLINE
i. Specialist Team Leaders and HSL
equivalents should adjust to accommodate
skills, ensure that HSL resources are fully
committed. This step should not
significantly change the inspection listings
or the overall resource deployed for each
Specialism
ii. Any material changes need agreement from
the relevant Field Team/Inspector
iii. This draft national picture will also be useful to
Agency Managers and HSE Heads of
Operations.
6
Date
Intervention planning timetable
By End
February
Finalising Agency Input to Intervention Planning
1. EA / SEPA / NRW managers and Inspectors should ensure that:
‐
‐
‐
‐
‐
Agency led interventions in Part B of the plan have been updated and correctly show
progress made by the operator
Agency lead elements in the IP for the current year have been updated and correctly
show what work will be delivered by the CA.
Changes arising from Agency moderation have been incorporated into the plan.
IP entries have been made for Agency work for the next two years
If the plan is acceptable complete the Name / date boxes on the Plan.
Notes and comments
i. Agency Managers should ensure that there
are adequate arrangements for handling of
the sign-off process in order to avoid delays
experienced in previous years.
ii. To assist handling changes it would be helpful
if changes to the plans at this stage are made
in Edit mode or otherwise highlighted
2. By 26th Feb EA / SEPA / NRW Inspectors / Managers confirm plans as final and return to
HSE.
3. February 2016 – EPR/PPC officers redraft CAPs if necessary aiming to avoid any further
identified regulatory overlap or duplication (joint discussions with COMAH officers and HSE)
4. By End February - CIMs will update Draft COMAH Intervention Plan following any
discussions with Duty Holder and the relevant Agency/Regulatory inspectors
By MID
March
Signing off the plan
1. EPR team leaders send finalised CAP to HSE Principal Inspectors/Regulatory Team
Leaders
2. CIMs should make any final changes to the plan as necessary in consultation with the review
team and submit to Regulatory Team Leaders and Agency Managers for Sign off
3. Agency Managers and Regulatory Team leader sign off completed plans.
i. Every effort should be made to avoid
unnecessary late adjustments to plans.
ii. It is not necessary for plans to be physically
‘signed-off’ - any confirmation emails should
be sent and retained on both HSE and
EA/SEPA records
iii. CEMHD4 will collate the final National Picture
of COMAH Intervention
4. Regulatory Team Leaders reflect any final adjustments on the Team Spreadsheet
7
Date
Intervention planning timetable
By End
March
1. Admin processes undertaken during March
Notes and comments
i.
‐
‐
‐
‐
‐
‐
‐
‐
‐
‐
‐
Update IP with any new Performance scores from Q3/4 inspections (as directed by B3)
Add Service Orders for 2016/17 to COIN CASE.
Update the Service Order for 2015/16 to reflect February and ongoing reviews and close
ii.
them where possible
Contingency work should NOT be added to COIN at this stage.
Prepare letters and make copies of 2016/17 intervention plans
Send intervention plans by end March 2016
iii.
Create New IPSO for ALL COMAH active sites
All Intervention Plan Service Orders (IPSOs) where work is planned should have line 1
(Plan Agreed) as complete
For COMAH sites where work is NOT planned in the current year should have Line 1
(Plan Agreed) marked as NOT RELEVENT
Check the number of New IPSO’s is the same as the no. of COMAH sites in the team.
Create additional Service Orders for sites with shared IPs
Handling contingency work. Any contingency
included in Intervention plans must be clearly
labelled. Contingency items will be input to
COIN once it is decided that they will go
ahead.
Admin staff should refer to COIN Guidance:
How to record COMAH Intervention Plan
Inspections on COIN
By a consistent placement of IPs on the COIN
CASE, relevant CA staff will be able to locate
the documents through the COIN database
2. Regulatory Inspectors continue to complete writing up of all 2015/16 intervention work for
addition to COIN and confirm to admin when all is done and SO can be closed.
April to May
1. By end of April Regulatory Inspectors to have completed all COIN work and notify
Administrators that previous year’s Service Orders can be closed
2. Regulatory Inspectors should notify Admin by e-mail re: SO closure, so that Admin can
attach the e-mail to Line 12 (SO Closure Review) before closing the SO.
3. By End of May - Admin to close off all 2015/16 Service Orders.
Note: Regulatory Inspectors should take all steps
to ensure that all outstanding documentation /
reports are finalised and attached to the
appropriate Service Order prior to closure.
If documents are delayed or require to be attached
to a closed Service Order - they should inform their
Admin teams - who will liaise with CI4 to have the
Service order reopened for remedial work to be
completed.
8