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OPITO Policy: Maintenance and

Inspection
OPITO Policy: Maintenance and Inspection

Amendment and Date Pages Changes made by Checked by Approved by

Director
Rev 0 Product Quality
27 (Product
4 May 2020 Development Assurance
Development)

Any amendments made to this Standard by OPITO will be recorded above.

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OPITO Policy: Maintenance and Inspection

Table of contents

Table of contents .......................................................................................... 3


1.0 Introduction ............................................................................................. 5
2.0 Document Control, Language and Revision ............................................ 7
3.0 Abbreviations and Glossary .................................................................... 8
4.0 Maintenance and Inspection Objectives ................................................ 10
4.1 Objective 1: Assure safe operations, care for health and respect for the environment ....................... 10

4.2 Objective 2: Economically maintain the availability of the Equipment .................................................. 10

4.3 Objective 3: Records Management ...................................................................................................... 11

5.0 General Maintenance and Inspection Requirements ............................. 12


5.1 ALARP .................................................................................................................................................. 13

5.2 Local legal and regulatory .................................................................................................................... 13

5.3 Industry standards/good practice ......................................................................................................... 14

5.4 OEM requirements or equivalent .......................................................................................................... 14

5.5 OPITO basic requirements ................................................................................................................... 14

6.0 Maintenance Management System ....................................................... 15


6.1 Identification of High-Risk Equipment .................................................................................................. 15

6.2 Initial Suitability ..................................................................................................................................... 16

6.3 Operating and Environmental Limits .................................................................................................... 16

6.4 Planned Maintenance and Inspection (PM) ......................................................................................... 17

6.5 Corrective Maintenance (CM) ............................................................................................................... 17

6.6 Management of Non-Compliance ......................................................................................................... 18

6.6.1 Non-compliances ............................................................................................................................... 18

6.6.2 Deviations .......................................................................................................................................... 18

6.6.3 Deferrals ............................................................................................................................................ 18

7.0 Roles and Responsibilities .................................................................... 19


7.1 Training provider ................................................................................................................................... 19

7.2 All Staff ................................................................................................................................................. 19

7.3 Maintenance and Inspection lead or equivalent ................................................................................... 20

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7.4 Maintenance and Inspection team ........................................................................................................ 20

7.5 Trainees and Staff responsibilities ........................................................................................................ 20

8.0 Risk Assessment and Controls ............................................................. 20


9.0 Legal, Regulatory, Industry Practice Requirements ............................... 20
10.0 Execution of Maintenance, Inspection and Assurance ........................ 21
11.0 Evaluation and Continuous Improvement ............................................ 21
12.0 Training and Competency Management.............................................. 21

Appendices

Appendix A – FMEA/RBM Maintenance Strategy Selection Framework ..... 22


Appendix B - Example of High-Risk Equipment .......................................... 24
1 Lifting Apparatus General ...................................................................... 24
2 HUET Specific ....................................................................................... 24
3 Utilities................................................................................................... 25
4 Critical Auxiliaries .................................................................................. 25
Appendix C - Risk Matrix............................................................................. 26

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OPITO Policy: Maintenance and Inspection

1.0 Introduction

This Policy document defines the development of the maintenance and inspection activities to be assigned
to various types of equipment operated at training provider facilities providing training and/or assessment
approved by OPITO, across the globe.

This Policy describes how these training providers shall systematically manage maintenance and inspection
in order to assure safe operations, care for health and respect for the environment whilst economically
maintaining the availability of the equipment, specifically to assure:

 Safety of people
 Integrity of equipment
 Compliance to rules and regulations
 Availability to meet business objectives

This Policy details:

 The approach to identifying high-risk equipment to be covered by this Policy


 The hierarchy of requirements on maintenance and inspection dependent upon
 The equipment type
 Geographical location and the prevailing requirements therein
 Original equipment manufacturers’ (OEM) requirements
 The risk to trainees and operators

The risk assessment process requirements to determine failure modes and effects with which to assess
equivalency between Standards and rules, to derive or dictate the maintenance and inspection regime.

The prevalent failure modes of generic equipment types and the process by which maintenance and
inspection activities can be assigned to these at intervals determined by the particular risk, criticality and
characteristics of such equipment.

This Policy has been prepared by OPITO with the intent to harmonise and assure the safety outcomes
gained from maintenance and inspection activities on high-risk equipment as defined in Section 6.1
Identification of High-Risk Equipment.

Included within the scope of this document are the requirements for the determination of risk and criticality
of equipment, the competencies of those using and maintaining the equipment, and the interaction of this
policy with OEM guidance on the maintenance and inspection of equipment.

This Policy applies to high-risk equipment as defined in Section 6.1, but does not target any particular
equipment type. The Policy stipulates a risk-based approach to identifying high-risk equipment and then to

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assessing the specific risk posed by equipment on personnel and trainees, and then guiding the training
provider towards implementing appropriate maintenance and inspection regimes.

This Policy recognises that training providers themselves may not hold the necessary competencies or
capacity to directly fulfil the requirements of this Policy, risk assessments, or the enactment of maintenance
and inspection activities, and therefore caters for the inclusion of subcontractors and OEMs.

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2.0 Document Control, Language and Revision

This Maintenance and Inspection Policy is a controlled document.

This policy is subject to periodic review. The specification and conditions of this policy are subject to change
to ensure the stipulations therein are in line with the current use of equipment and facilities by training
providers, and also as part of OPITO’s standard review process. Training providers must comply with the
latest revision of the Policy, please refer to the OPITO website for the latest version.

Documents and information relating to this Policy, the regime and associated records and risk assessments,
shall be available in English.

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3.0 Abbreviations and Glossary

A concept from UK HSE: managing risk "As Low As Reasonably


ALARP
Practicable"

OPITO audit activities as part of the OPITO assurance process with


Audit
training providers

CM Corrective Maintenance

A professional person or organisation capable of independently assessing


Competent Body the suitability and fitness for service of engineering modifications to
equipment

Critical Work These are activities intended to maintain a function on equipment that is
Scopes critical to safety performance

FMEA Failure Modes and Effects Analysis

HAZID Hazard Identification

High-Risk Equipment that is determined as posing a material risk to: people who
Equipment interact with it and/or to the environment. See 0 for further details

HUET Helicopter Underwater Escape Training

MMS records A records management system relating to the management of the


framework lifecycle of high-risk equipment

MoC Management of Change

NDE Non-Destructive Examination

OEM Original Equipment Manufacturer

Other Equipment is equipment not deemed high-risk equipment.


Other Equipment Maintenance and inspection of other equipment is determined by local
regulations and industry norms

Policy This maintenance and inspection policy document

PM Planned Maintenance and inspection

RBM Risk Based Maintenance

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Regime Maintenance and inspection regime

Includes: trainers, managers, equipment operators, subcontractors,


Staff
technicians, engineers

Any person being trained using the equipment or in proximity to the


Trainee
equipment. Includes observers, auditors and visitors

Training provider The ultimate senior person/body of the training facility company

A work order is a record of an activity that is to be carried out. This may


Work order be recorded within an electronic MMS such as SAP, MAXIMO etc. or on a
maintained spreadsheet or functional alternative

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4.0 Maintenance and Inspection Objectives

The objectives stated below can only be achieved as part of a whole system of well-founded decisions,
systematically controlled and executed activities, and within an effective management structure. Below are
the three overarching objectives guiding the creation and execution of the maintenance and inspection
regime.

4.1 Objective 1: Assure safe operations, care for health and respect for the
environment

The maintenance and inspection regime shall provide that:

 Safe work practices are adhered to at all times


 All maintenance and inspection staff are demonstrably competent1 to perform the maintenance and
inspection tasks assigned to them
 Adverse environmental impacts arising from maintenance and inspection activities are minimised
 All maintenance and inspection activities are auditable
 All maintenance and inspection activities have equivalence, exceed or comply with local regulatory
requirements, international standards, good industry practice, or the maintenance and inspection
objectives of this Policy
 Maintenance and inspection requirements are communicated to all relevant Staff and sub-contractors
 All Equipment in service is in a suitable condition for its intended use
 Equipment not in a serviceable condition, is removed from service and clearly marked as such

4.2 Objective 2: Economically maintain the availability of the Equipment

The maintenance and inspection regime shall:

 Ensure maximum maintenance and inspection effectiveness by minimising equipment downtime


 Optimise maintenance cost relative to risk
 Ensure planned and unplanned interventions are minimised and are as short as possible
 Ensure that critical OEM recommendations2 are considered and learned from, and where appropriate
incorporated within the regime
 Review maintenance and inspection performance and identify opportunities for improvement (more, less
or different activities)
 Have a continuous review process in place to review and optimise the maintenance and inspection
strategy through the equipment’s lifecycle

1 See Section 12 Training and Competency Management


2 The assessment of what is considered ‘not’ a critical OEM recommendation should demonstrate how it is adequately covered by the Regime.

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4.3 Objective 3: Records Management

The regime shall:

 Ensure all maintenance and inspection activities follow documented procedures


 Ensure all maintenance and inspection activities follow a documented plan or schedule
 Ensure all maintenance and inspection activities are recorded as evidence of activities, to support
analysis and auditing
 Ensure such records are suitable to support decisions on life extension, late life operations and
modifications

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5.0 General Maintenance and Inspection Requirements

The maintenance and inspection requirements of OPITO approved training providers’ high-risk equipment
shall be developed using Risk Based Maintenance (RBM) logic with tasks and task frequencies based upon
appropriate parameters. An example Failure Modes and Effects Analysis (FMEA) concept list and table are
included in Appendix A. While it is not mandatory to perform an FMEA and RBM on each high-risk
equipment item, the training provider shall be able to demonstrate a systematic approach to identifying how
each equipment item or system could fail, the consequences of failure, what maintenance and inspection
activities are appropriate to manage the risk, and at what frequency the activity should be performed. The
training provider can delegate the development and execution of the aforementioned systematic approach
where it does not have the inhouse competence and where it has delegated the management of the
maintenance and inspection regime. In such a case, the training provider shall demonstrate that its
subcontractor has performed the activity.

It is the responsibility of the training provider and not OPITO to determine and implement an effective and
safe maintenance and inspection regime. The training provider cannot delegate or offset this responsibility
to have and to operate an effective regime.

The training provider shall be able to demonstrate their compliance to this Policy, see Section 7 Roles and
Responsibilities.

The training provider’s safety policy shall be harmonious with the requirements within the OPITO
Maintenance and Inspection Policy and the safety policy shall be signed by the highest-level officer within
the business.

The equipment used at training provider facilities are, by nature, intended to operate alongside trainees and
staff. As such, the way in which trainees and staff interact with equipment is an important factor to the safety
of the whole system. Trainees and staff take on duties and responsibilities when using or being in proximity
to the equipment, see Section 7 Roles and Responsibilities.

As a guiding principle, risks to people and equipment integrity shall be managed according to the ALARP
principle i.e. risk shall be managed to “As Low As Reasonably Practicable”. Maintaining and inspecting
equipment so the risk is maintained ALARP means, in this context, adhering to a hierarchy of compliance.
The following list describes the concepts to which the regime shall comply, in reducing order of relevance:

1. Risks to be managed to the ALARP principle


2. Compliance shall follow:

A. Local legal and regulatory requirements


B. Industry standards/good practice
C. OEM practice or equivalent

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D. Requirements stipulated in this Policy

5.1 ALARP

“As Low as Reasonably Practicable” means the goal for the management of risk has been set by OPITO
while allowing training providers to make their own cost effective decisions about how to comply, however, it
requires the training provider and OPITO to exercise judgement when considering if the maintenance and
inspection regime is fit-for-purpose. The first test of whether the regime is fit for purpose is by referring to
existing applicable regulations, codes, and ‘good practice’ for similar applications and in wider industry. For
high-risk equipment and novel situations, the training provider shall comply with such ‘good practice’ or
demonstrate their case for deviating from ‘good practice’ while maintaining the risk ALARP.

By stating that they are managing risk to ALARP, (as low as reasonably practicable), the training provider is
confirming that the risk controls they have put in place will reduce the risks to employees and trainees
appropriately. The training provider shall be able to demonstrate that they have undertaken sufficient risk
assessment activities to understand the risk and that they have put appropriate mitigation measures in
place.

5.2 Local legal and regulatory

Training providers considered under this Policy are typically located within jurisdictions which have their own
local legal and regulatory obligations for maintenance and inspection regimes of high-risk equipment. An
example of such would include LOLER (Lifting Operations and Lifting Equipment Regulations) in the UK.

This Policy does not authorise or endorse the training provider to deviate from local legal and regulatory
requirements, even if those requirements exceed those necessary to reduce risks to ALARP.

Where legal or regulatory requirements exist, these shall be the primary driver of the regime, i.e. the regime
shall satisfy these requirements as the priority. Regulatory and legal requirements tend to consider
equipment in a relatively standardised or common configuration and assume that the use of the equipment
will be similarly standardised. In the scenario of the regulations’ application to specialist training equipment,
it is likely that satisfying legal and regulatory requirements will not necessarily result in a fit-for-purpose
regime for systems such as those used in an applicable training course. Where gaps exist, concepts from
the following sources, namely, industry standards and good practice, from the original equipment
manufacturer (OEM), and from basic OPITO requirements, shall be identified and included.

The training provider shall demonstrate that they have identified any gaps between local legal and
regulatory requirements and the maintenance and inspection requirements of the high-risk equipment.

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5.3 Industry standards/good practice

In alignment with the ALARP principle and, in addition to local regulatory requirements, the training provider
shall demonstrate that they have identified any gaps between industry standards/recognised good practice,
and the specific requirements for the maintenance and inspection of the high-risk equipment.

5.4 OEM requirements or equivalent

Specialist equipment, particularly bespoke or modified equipment, often has maintenance and inspection
requirements instructed from the manufacturer. The manufacturer (OEM) is theoretically best placed to
determine the optimum regime for the equipment and following the OEM’s requirements may be a condition
of the provision and validity of warranties. These requirements may make reference to codes and standards
and may include additional activities intended to treat risks or failure modes and effects specific to the
equipment, use and the environment.

Within OEM recommendations there may be requirements for specific activities, their frequencies or trigger
points (running hours, number of cycles, calendar time, damage events) and requirements on the
competency of engineers and technicians performing the work.

Maintenance and inspection activities, their frequency and triggers, and any competency requirements
called for by the OEM, shall be incorporated within the regime unless the training provider can demonstrate:

 The OEM specified activity and frequency have equivalence to other activities
 That the OEM activity is unnecessary in their configuration or operation
 The equipment has been modified so the OEM activity is no longer appropriate
 The technical competency, certified or otherwise, of the relevant maintenance and inspection personnel
is equivalent to that stated as required by the OEM

5.5 OPITO basic requirements

Where local legal or regulatory requirements, industry standards or recognised good practice and
requirements defined by the OEM, are insufficient to guide the creation and assurance of a robust regime
for high-risk equipment, then it is the training provider’s duty to demonstrate that the regime fulfils the
requirements set within this Policy and to have applied a risk-based approach as set out in Section 8 Risk
Assessment and Controls and described in Appendix A.

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6.0 Maintenance Management System

A maintenance management system (MMS) will be used to plan, control and record maintenance,
assurance and inspection activities, for planned and unplanned activities, and for the recording of uncovered
condition, on high-risk equipment. The MMS must be readily available to staff, management, sub-
contractors and auditors, when required. It shall be used proportionally for:

 Work-order generation (writing, planning, approving)


 Task scheduling
 Scheduling of resources required in carrying out tasks
 Ensuring that all critical work scopes are completed in a timely fashion, within the target period
 Recording the history of interventions and findings and reference to product certificates
 Supporting the procurement of materials and services
 Reporting work-order status

The requirements for planned and unplanned maintenance and inspection activities are set out below.

6.1 Identification of High-Risk Equipment

High-risk equipment is credibly capable of causing loss of life in the event of a failure; therefore, this Policy
is applicable to those high-risk equipment items and systems. The definition of high-risk equipment is
derived from the OPITO risk matrix for medical emergency response assessment, specifically the elements
of high-risk activities.

Any equipment, system, or sub-system used in activities described below, are identified as high-risk
equipment:

1. Any activities using breathing apparatus


2. Any activities in confined spaces
3. Any on-water training
4. Any swimming pool activities
5. Any live fire extinguisher activities
6. Working at height activities
7. Lifting operations including operations involving lifting/suspending people
8. Any activities involving the use of hazardous materials and associated equipment

The training provider shall ensure that all equipment used directly or in support of the above-mentioned
activities, is listed and managed within its MMS, as an item of high-risk equipment.

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6.2 Initial Suitability

High-risk equipment used by training centres shall have been engineered for the specific purpose, following
applicable rules, codes and standards. They will have been commissioned, inspected and tested prior to
operation with trainees.

Equipment that has been modified from its intended purpose to the purpose of training, shall have been
assessed by a competent body. That competent body shall have identified the critical areas of the design of
the equipment and assessed how they would change in the new use, identifying new risks. A suitable risk
assessment process, such as an FMEA, shall have been undertaken and the process and results
documented and retained. The outcome of the FMEA or similar shall have produced specific maintenance
and inspection activities as well as documented assurance that the equipment was fit for purpose when it
entered/ re-entered service with the training provider.

The training provider shall be able to demonstrate that initial certification and any change of
use/recertification documentation are recorded within the MMS records framework.

6.3 Operating and Environmental Limits

High-risk equipment shall be used within its operating limits at all times and shall be used within the
environment for which it was specified. The training provider shall be able to demonstrate a process for
detecting and recording if and how equipment is used outside its operating limits, and if the operational
environment changes. This information will be available for inspection and shall be an element of the MMS
records keeping framework.

Operating and environmental limits are parameters including, maximum loads, rates of change, speed,
pressure, max and min temperatures, humidity, UV exposure, dust levels, air flow, water salinity/chemistry,
vibration frequency and magnitude.

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6.4 Planned Maintenance and Inspection (PM)

Planned maintenance and inspection activities shall be scheduled and prioritised on a risk basis, on the
priority as identified and defined within the RBM process set out in Appendix A. Activities shall be
categorised so as to facilitate prioritisation of high-criticality tasks over low-criticality tasks.

An example categorisation framework is set out below:

Priorities Example

Category 1 – Critical activities to the safe performance of equipment.


Equipment functional performance testing or inspection to demonstrate Static load test
that high-risk equipment can meet requirements

Category 2 - Technical maintenance and inspection activities.


Technical maintenance on equipment which, if not undertaken in Non-destructive examination
accordance with the scope and timescales as specified may affect the (NDE) of Hook Block
ability of the high-risk equipment to fulfil requirements

Category 3 - Business critical equipment technical maintenance and


inspection activities.
Braking system/Rotation
Technical maintenance on high-risk equipment which if not undertaken
system wear assessment
in accordance with the scope and timescales may increase the risk of
equipment failure
Category 4 - Other maintenance and inspection activities
General maintenance and inspection activities on high-risk equipment
Coating/painting inspection
that is not critical to safety or environmental performance

6.5 Corrective Maintenance (CM)

All defects reported or found will be risk assessed and a priority will be assigned based on the:

 Criticality of the equipment


 Nature of the observed defect
 Consequences of not undertaking the remedial work
 Likelihood of those consequences occurring

The objective of risk assessing and assigning a priority for the rectification work is to ensure that work is
done in the optimum sequence. For example, tasks deemed important within the risk assessment process
shall be scheduled for execution before tasks with a lower priority. Tasks deemed as low importance may be
scheduled for execution within a planned maintenance cycle.

The risk assessment methodology used by the training provider shall be appropriate and scaled to the
specific situation and shall be capable of identifying the relative risk reduction gained from different activities
in the MMS.
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The training provider shall be able to demonstrate that appropriate risk assessments are performed on CM
activities and not performed at the time of discovery.

6.6 Management of Non-Compliance

The training provider shall be able to demonstrate their process for the management of non-compliances,
deviations, and deferrals which affect the execution of the regime activities.

6.6.1 Non-compliances

Where an activity is found to have been performed with errors, not performed while being recorded as
having been performed, or related data is incorrect, then these are considered non-compliances. The
training provider shall have an assurance process to detect when non-compliances occur and a process to
record the instance of non-compliance and what mitigations and learnings were the result.

6.6.2 Deviations

Where it was necessary to deviate from the activities in the regime, either in frequency or the technical
performance of the activity, then the training provider shall use a deviation process to assess the risk and to
record the instance and resulting actions. The process shall record the decision process and this record
shall be retained and available for audit.

6.6.3 Deferrals

Decisions to defer inspection or maintenance activities shall be made through a deferral process which
assesses the risk of deferring and which can put in place any required mitigation.

The risk assessment should also document the additional controls necessary to permit the equipment to
continue to operate safely. The training provider shall suspend operation if such controls are not identified
and implemented.

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7.0 Roles and Responsibilities

This Policy contains information, instruction and responsibilities applicable to the following people and roles:

 Training provider
 All staff
 Maintenance and inspection lead or equivalent
 All trainees

7.1 Training provider

The training provider is the ultimate responsible body for ensuring that the maintenance and inspection
regime is fit for purpose and is compliant to this Policy. They cannot delegate this responsibility. They are
responsible for the enactment of this Policy and accountable for the outcomes on the equipment reliability,
its safety and on its environmental performance.

The training provider is responsible for embedding this Policy within its own governance framework. The
training provider retains legal liability for the safety and integrity of the equipment:

 Ensures staff are competent for the activities and inspection tasks assigned to them
 Ensure suitable resources, time, access to equipment to implement the Policy
 Maintain the MMS including plans, procedures and records of maintenance and inspection activities

7.2 All Staff

Staff are those individuals who interact with or are close to the equipment, or who have influence over its
management, operation, records keeping, maintenance, inspection, purchasing, training, cleaning,
commissioning, modifying, decommissioning.

Staff have a responsibility to diligently follow instructions and guidelines, work safely to procedures, attend
training, update records, report unsafe conditions, contribute to risk assessments:

 Carry out maintenance and inspection according to the assigned workorder and schedule, and to a
suitable standard
 Report equipment found to be in a dangerous condition
 Take equipment found to be dangerous out of service
 Maintain records

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7.3 Maintenance and Inspection lead or equivalent

The Maintenance and inspection lead or equivalent holds a critical role within this Policy:

 Maintain the maintenance and inspection procedures, plans and associated records
 Assign tasks to competent people
 Allocate resources
 Ensure accurate reporting

7.4 Maintenance and Inspection team

All personnel engaged in carrying out maintenance activities must be familiar with, and have a detailed
understanding of, the safety issues involved in maintenance activities:

 Carry out maintenance and inspection tasks according to the assigned work order
 Report equipment found to be in a dangerous condition
 Maintain records

7.5 Trainees and Staff responsibilities

Trainees are responsible for following instructions intended to keep themselves and others safe alongside
equipment, given by instructors.

Staff are responsible for following instructions and guidance within policies, manuals, instruction panels, etc.
to keep themselves and others safe alongside equipment.

8.0 Risk Assessment and Controls

The training provider shall perform risk assessment to support the generation and execution of the MMS.
The training provider shall be able to demonstrate their use of suitable HAZID and FMEA processes to
assess risk and to put mitigation measures in place and to monitor their effectiveness.

9.0 Legal, Regulatory, Industry Practice Requirements

Recognising that different regions have different requirements relating to the use, maintenance and
inspection of potentially dangerous equipment, it is the training provider’s duty to identify and justify its
compliance to appropriate legal, regulatory, industry practice requirements.

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10.0 Execution of Maintenance, Inspection and


Assurance

The training provider shall demonstrate that the regime is executed by competent people with adequate
resources, and that appropriate records are being kept.

11.0 Evaluation and Continuous Improvement

The training provider shall be able to demonstrate that they detect and act on near misses, use root cause
analysis, and learn from incipient issues. The training provider shall be able to demonstrate how such
learning is incorporated into an improvement cycle.

12.0 Training and Competency Management

The training provider is responsible to determine the competencies and certification required by the
members of the operational team and of the maintenance and inspection team. The training provider is
responsible for ensuring that the training provided to staff is appropriate for the specific equipment and
operations found at the training facility. Where the training provider has outsourced maintenance, they
remain accountable for demonstrating that training and competency is managed as required but may
delegate the execution of that assessment to the subcontracting party.

Changes to equipment or operating conditions shall be assessed so to identify any required changes to
training plans and content.

The training provider shall maintain records of the training status of staff and contractors working with high-
risk equipment and shall ensure that training is maintained as valid and current.

Changes to training content or training provider shall be assessed and the training provider will be able to
demonstrate that the new training is valid for the facility’s situation.

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Appendix A – FMEA/RBM Maintenance Strategy


Selection Framework

The process of identifying equipment covered by this Policy through to defining appropriate maintenance
and inspection activities and their frequencies, is set out below. It is not required to follow the detail within
each step but the training provider shall follow and be able to demonstrate that such a similar process is
followed when generating the regime and populating their MMS.

1) Identify High-Risk Equipment


Any equipment, system, or sub-system used in activities described below, are identified as high-risk
equipment:

1. Any activities using breathing apparatus


2. Any activities in confined spaces
3. Any on-water training
4. Any swimming pool activities
5. Any live fire extinguisher activities
6. Working at height activities
7. Lifting operations including operations involving lifting/suspending people
8. Any activities involving the use of hazardous materials and associated equipment

2) Perform risk assessment (FMEA and RBM)


For those high-risk equipment, a risk assessment shall be performed to support the RBM process. This may
typically be performed as a FMEA. Where FMEA is followed, it would be expected that a worksheet
containing the following information would be used to elicit the required information to then develop optimum
maintenance and inspection activities and frequencies:

1. Item/subsystem name
2. Item function
3. Failure modes and mechanisms
4. Failure effects on the item and system
5. Consequences: safety and environmental
6. Likelihood
7. Detection opportunity
8. Resulting risk
9. Criticality classification
10. Mitigation activity: inspection/maintenance
11. Frequency

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It is not required to follow the included example, only that the outcomes support the general maintenance
and inspection requirements for that specific equipment in its specific environment and operational situation.

3) Correlate the Activity Category for Priority


For each of the activities identified, assign a category to facilitate prioritisation.

Priorities

Category 1 – Critical activities to the safe performance of equipment

Equipment functional performance testing or inspection to demonstrate that high-risk equipment can
meet requirements.

Category 2 - Technical maintenance and inspection activities

Technical maintenance on equipment which, if not undertaken in accordance with the scope and
timescales as specified may affect the ability of the high-risk equipment to fulfil requirements.

Category 3 - Business critical equipment technical maintenance and inspection activities

Technical maintenance on high-risk equipment which, if not undertaken in accordance with the scope
and timescales, may increase the risk of equipment failure.

Category 4 - Other maintenance and inspection activities

General maintenance and inspection activities on high-risk equipment that is not critical to safety or
environmental performance.

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Appendix B - Example of High-Risk Equipment

The following is a catalogue of typical equipment items that may be found at OPITO-approved training
centres and which are likely to be high-risk equipment. The list is not exhaustive nor complete and is set out
here as an aid to the training provider when determining their own high-risk equipment which shall be
subject to this Policy.

1 Lifting Apparatus General

Lifting apparatus general are those pieces of equipment and systems that are designed for the purpose of
lifting items and/or people:

 Electric and manual hoists and winches


 Gantries, jib cranes, davits, crane gantry girder, trolley, hoist, hook block, pendant controller
 Scissor jacks
 Webbing, strops, chains, wire ropes, clamps, hooks, tag lines
 Lifting beams, shackles, pulleys
 Load arrestors

2 HUET Specific

HUET-specific equipment are those pieces of equipment or systems specifically related to Helicopter
Underwater Escape Training (HUET) systems. HUET systems are typically a combination of lifting
apparatus and passenger compartment, joined by a clutch/brake ring to facilitate axial rotation of the
passenger compartment. Equipment may comprise of:

 Gantry system to hook block


 Hook block to braking system/rotation system
 Chassis
 Seat attachment to chassis, seat belt attachments, seatbelts, seatbelt buckles
 Buoyancy/ballast packs and attachment
 Remote control

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3 Utilities

Utilities are those services critical to the operation or recovery of the equipment covered within this Policy.
These may include:

 Mains power for lighting, safety, security and control systems


 3-phase power for lifting appliances, pumps, compressors
 Uninterruptable power supplies (UPS) and battery units used to power high-risk equipment in the event
of a power failure
 Drainage and water test and treatment facilities for pool water, the management of chemical and
biological balance of water, temperature control and water disposal

4 Critical Auxiliaries

Critical Auxiliaries include items, typically attached to the larger equipment items, that perform a function
and where the loss of that function may cause injury. Examples of such auxiliaries may include (and some
are mentioned in other sections):

 HUET seatbelt straps and attachment points, seatbelt buckles, seats and attachment points
 Immersion suites, life jackets and compressed air bottles
 Lifting apparatus control panels, remote control units, emergency stop buttons
 Emergency/warning lighting and beacons, torches, sirens and audible alarms

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Appendix C - Risk Matrix

The “OPITO Medical Emergency Response and Planning Requirements” risk matrix is used as the common
basis to guide the determination of low, medium and high-risk activities, see Figure 1 OPITO Medical
Emergency Response and Planning Requirements Risk Matrix.

Equipment facilitating, supporting or otherwise related to high-risk activities, are classified within this Policy
as high-risk equipment. With this logic, the risk-based approach to defining maintenance and inspection
activities within the regime, means that maintenance on high-risk equipment can be prioritised over lower-
risk equipment.

Lifting operations incorporating lifting of people and working at height activities are not explicitly detailed
within the risk matrix. For the purposes of this Policy, all lifting operations including those involving
lifting/suspending people, and working at height activities are considered high-risk activities.

The risk matrix was originally developed for medical emergency response and planning assessment. The
original matrix can be found in context in the ‘Medical Emergency Response and Planning Requirements’
document, available from the Industry Standards Approvals area of the OPITO website.

Policy High-Risk Activities

This Policy defines the following as high-risk activities:

1. Any activities using breathing apparatus


2. Any activities in confined spaces
3. Any on-water training
4. Any swimming pool activities
5. Any live fire and extinguisher activities
6. Working at height activities
7. Lifting operations including operations involving lifting/suspending people
8. Any activities involving the use of hazardous materials and associated equipment

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Figure 1. OPITO Medical Emergency Response and Planning Requirements Risk Matrix

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