Professional Documents
Culture Documents
Safety Case
Topic Assessment Guide:
Industrial Hygiene
Case Title [Case title]
Duty Holder [Company name]
Topic Assessor [Inspector]
COIN Reference [Coin number]
CAP Reference [Cap number]
Offshore Major Accident Regulator
Table of Contents
Work Instruction....................................................................................................................................3
Guidance...............................................................................................................................................4
Topic specific expectations....................................................................................................................4
1. Assessment Scope.........................................................................................................................6
2. Assessment Record........................................................................................................................7
2.1 Specialist Advice & Services.....................................................................................................7
2.2 Occupational Health and Hygiene............................................................................................9
2.3 Occupational Health – Health care and First-Aid...................................................................12
2.4 Occupational Health – Welfare & Accommodation...............................................................14
2.5 Decommissioning and Dismantlement..................................................................................16
Appendices: Guidance Material..........................................................................................................19
Appendix 1: Industrial Hygiene Advice................................................................................................20
Appendix 2: Industrial Hygiene Guidance...........................................................................................21
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Offshore Major Accident Regulator
Work Instruction
This Topic Assessment Guide (TAG) contains the reference material and guidance required to
complete the assessment of this topic.
The TAG template is one of a series covering all assessment disciplines, which together, once
completed, will 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, and other relevant statutory provisions, for the topic and indicate what
the competent authority expects to find within a safety case to demonstrate that those requirements
are met. The TAG template complements the published guidance that supports the regulations and
other available topic sector guidance. The TAG templates are created to ensure a consistent and
transparency approach by inspectors assessing the cases and are made available to duty holders
who may find them a useful aid when drafting submissions.
Assessment Issue
An Assessment Issue (AI) is a deficiency in the demonstration made within a safety case. Where
an AI has the potential to risk acceptance of the Case, the Case Manager must be informed. The
issue must be clearly outlined on an Assessment Issue Note that is communicated to the duty
holder.
Assessment Issues must be sent via the portal to the DH and the AI must give the DH 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 and recorded on the portal using the communications tab. A meeting between the duty
holder and relevant topic specialists may also be appropriate in some circumstances. Clarification
is not a first stage before raising an assessment issue. Any aspect that could credibly lead to an
assessment issue should be raised as such in the first instance.
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Guidance
Guidance that relates to the information a DH needs to present in a safety case is available from
several sources, the guidance identified below signposts key information that is relevant to this topic
or area of assessment:
Other published guidance that is pertinent to safety case content in relation to Industrial Hygiene is
detailed below within the assessment scopes.
Topic specific expectations
The Industrial Hygiene discipline has provided the following guidance that sets out the Competent
Authority’s expectations in relation to aspects of health management in offshore operations. There is
further guidance in Appendix 2.
Scope
The Offshore Installations (Safety Case) Regulations [SCR15] requires a safety case to demonstrate
the duty holder’s management systems are adequate to ensure compliance with the relevant statutory
provisions, and there are satisfactory arrangements for the management of contractors and sub-
contractors. The required demonstration of the adequacy of the management system is not restricted to
the management of major accident hazards and it is also necessary for the safety case to demonstrate
that the occupational health arrangements ensure compliance with the relevant statutory provisions. A
safety case which does not include industrial health, hygiene & welfare elements in the descriptions of
the management system is therefore unlikely to demonstrate that the management system is adequate.
Depth of Assessment
Assessment of a duty holder’s industrial health & hygiene arrangements is targeted primarily at
determining whether the performance of the arrangements made to ensure effective control of health
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Offshore Major Accident Regulator
risks is credible and effective. Verifying whether the health arrangements are physically capable of
delivering the claimed performance is a matter for post acceptance inspection.
While it is a matter of balance as to how much material is required in a safety case rather than verified
through inspection, any discussion included in a safety case in support of a demonstration of
regulatory compliance should contain sufficient detail to lend conviction to the arguments. It is
important that the case demonstrates an understanding of the principles and practice required to
ensure adequate management of hygiene & health risks.
The assessment of safety cases is basically a sampling process. Therefore, dependent upon several
factors including assessment history, not all the elements identified in this Section may necessarily be
assessed in every safety case assessment. It should also be noted that this material is only relevant to
safety case assessment and is not sufficient to determine full compliance with all relevant industrial
health & hygiene legislation.
Assessment Sheets
Occupational & industrial health can be said to be the creation of a state of physical, mental and social
wellbeing of the workers in the working environment. The aims should be to promote, protect and
maintain the physical and mental health, and welfare of the workforce. The subdivision of
occupational health into assessment record sheets for the purposes of safety case assessment.
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
1. Assessment Scope
The scope of the assessment was in accordance with the Assessment Instructions and any agreed changes. The assessment was carried out in accordance
with the procedure outlined in the Framework Diagram and covered the following areas:
The table below identifies the type of Case and sub-topics that were considered as part of this assessment. Where Assessment Issues were identified
these are noted in the record and the specific details can be found on the PORTAL.
Type of Assessment
New Safety Case Assessment Yes
Production – ALL records completed ☐
Non-production – All records completed ☐
Material Change Assessments Yes
Production – Material Change (all relevant changes assessed as per assessment instructions) ☐
Non-Production – Material Change (all relevant changes assessed as per assessment instructions) ☐
The following ‘Sub-topic’ records have been completed as part of this ‘Material Change’ Assessment:
2.1 Specialist Advice and Services ☐
Any additional comments relevant to the Assessment Scope [outline as appropriate or insert ‘NONE]
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
2. Assessment Record
The health management system should therefore set out the arrangements for getting access to sufficient occupational health & hygiene knowledge, skills
or experience to identify and manage occupational health risks effectively. The commitment of senior management is essential to this process and the
safety case should demonstrate support of senior management, provision of adequate resource and input from technical specialists as appropriate.
‘Occupational/Industrial Hygienists use science and engineering to control risks to health, by designing out hazards and applying engineering controls to
reduce exposures to a minimum. This approach is designed to protect workers from serious, and even fatal, illnesses caused by work-related activities.
The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015 (L154).
The Management of Health and Safety at Work Regulations 1999 (specifically Regulation 7)
Guidance associated with MHSW Regulations 1999 - Health and safety regulation...... a short guide
The Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996
Information associated with DCM 1996 - SPC/Enforcement/170
The offshore installations and pipeline works (management and administration) regulations 1995
Information associated with MAR 1995 - SPC/ENF/153
Assessment Criteria - Information Expected SC Ref Criteria met / not met? Add assessment comments to justify Assessment
position take. Please note nature of any clarifications made in Issue
portal.
Confirm via roles and responsibilities and an organogram
that appropriate health specialists are involved in
developing the health management system.
Confirm there is a competence process in place for roles
and responsibilities including a matrix, supporting the DH
to manage their activities safely and keep up to date with
developments in occupational health and industrial hygiene.
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
The adequacy of the management system to prevent or control exposure to health risks by recognising health hazards, evaluating the risk and establishing
appropriate control measures is considered. The occupational health hazards may include
The essential requirements for managing occupational health are just the same as those for any management system. Any sub-system for managing
occupational health functions should therefore have the key features of any good management system i.e. policy, organisation, planning and setting
standards, performance measures and auditing and review. Confirmation should be obtained that a recognised code, standard or body of guidance has been
considered in determining the required performance of the occupational health management system.
The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015
Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995 (specifically Regulations 17 and 18),
including associated guidance (L70)
Control of Noise at Work Regulations 2005, including associated guidance (L108)
Control of Vibration at work Regulations 2005, including associated guidance (L140)
Control of Ionising Radiations 2017, including associated guidance (L121)
Control of Asbestos Regulations 2006, including associated guidance (L143)
Control of Substances Hazardous to Health Regulations 2002 (as amended), including associated guidance (L5)
Control of Lead at Work Regulations, including associated guidance (L132)
Manual Handling Operations Regulations 1992 (as amended), including associated guidance (L23)
Environmental Health Guidelines, Oil and Gas UK
Occupational Health web site, Offshore Division, HSE
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
Assessment Criteria - Information Expected SC Ref Criteria met / not met? Add assessment comments to justify Assessment
position take. Please note nature of any clarifications made in Issue
portal.
Does the Safety case demonstrate that the management of
health issues is integrated into the installation’s Safety
Management System?
Are Health Risk Assessments in place identifying,
evaluating and controlling of risks arising from the
following:
Chemical hazards – COSHH assessment process in
place, identified use & maintenance of controls
(promoting hierarchy: elimination, substitution,
local exhaust ventilation etc) personal monitoring,
health surveillance, competence, links into PTW
system.
Physical hazards – Noise, control policy -
Survey/RA, Action plan, programmes for
monitoring, considerations for design of new
equipment/modifications, H/S programmes
Physical hazards – Vibration, control policy -
Survey/RA, Action plan, programmes for
monitoring, considerations for design of new
equipment/modifications, H/S programmes
Physical hazards – Radiation Management process
in place?
Biological hazards – Legionella, Current risk
assessment, written scheme of control in operation,
roles and responsibilities.
Biological hazards - Food safety management,
competent contractor, HACCP in place.
Biological hazards – Infectious disease protocols in
place?
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
The Offshore Installations and Pipeline Works (First-Aid) Regulations require provision of health care and first-aid for employees who are injured or
become ill at work.
Confirmation should be obtained that a recognised code, standard or body of guidance has been considered in determining the required performance of the
emergency response management.
Where a standard/code of practice other than those listed above has been employed, judgement as to the adequacy of provision of health care and first
aid can only be assessed on an individual basis and the duty holder should be required to justify why its approach will deliver an equivalent level of health
care and first-aid.
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
Assessment of needs including provision of equipment, facilities, and medications and the numbers of ‘suitable persons’ required for rendering
first-aid to people who are injured or become ill while at work.
The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015
Offshore Installations and Pipeline Works (First-Aid) Regulations 1989, and associated guidance (L123)
OGUK industry guidelines for first aid and medical equipment on offshore installations
MS39 Offshore first aid and medic qualifications
Assessment Criteria - Information Expected SC Ref Criteria met / not met? Add assessment comments to justify Assessment
position take. Please note nature of any clarifications made in Issue
portal.
The duty holder has carried out a review of their “first aid
needs” assessment?
Are the medic’s core roles on the installation focussed on
health? Are they expected to carry out dual roles? If so,
what are these and have they been evaluated?
Are there adequate arrangements for the provision of
emergency first-aid and basic health care in terms of
facilities, equipment, medications and suitable persons?
For new installations into the UKCS, Topside Doctor
requires to be a fully registered person who holds a current
General Medical Council (GMC) registration to practice in
the UK…is this confirmed?
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
The Offshore Installations and Pipeline Works (Design and Construction) Regulations 1996 require provision of adequate and appropriate welfare facilities
for the workforce while they are on the installation. This includes sleeping accommodation.
Confirmation should be obtained that a recognised code, standard or body of guidance has been considered in determining the adequacy of
welfare/accommodation.
Where a standard/code of practice other than those listed below has been employed, judgement as to the adequacy of the Welfare/accommodation
provision can only be assessed on an individual basis and the duty holder should be required to justify why its approach will deliver an equivalent level of
welfare/accommodation.
HVAC systems
Rest room facilities
Sanitary facilities
Sleeping accommodation
The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015
The Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996
https://www.hse.gov.uk/foi/internalops/hid_circs/enforcement/spcenf170.htm
OGUK Guidelines for Environmental Health for Offshore Installations.
Assessment Criteria - Information Expected SC Ref Criteria met / not met? Add assessment comments to justify Assessment
position take. Please note nature of any clarifications made in Issue
portal.
Has the duty holder carried out a welfare impact assessment
for any significant POB changes?
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
Industrial hygiene hazards can be present in many of the common stages of decommissioning and dismantling activities, these would include:
Cessation of Production
Well P&A
Pipeline Isolation and removal / leave in situ
Topsides shut down
Isolation
Clean Down
Early stage dismantling i.e., derrick removal, helideck removal, modular splitting etc
Dismantling (as defined in SCR, Reg 20)
The Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996, Regulation 10
The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015, Regulation 24, Revision of safety case
The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015, Regulation 20, Safety case for dismantling fixed
installations
The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015, Schedule 8: Particulars to be included in a current
safety case in respect of the dismantling of a fixed installation
Decommissioning within the offshore UK oil and gas industry: a practical guide to worker health protection
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
Assessment Criteria - Information Expected SC Ref Criteria met / not met? Add assessment comments to justify Assessment
position taken Issue
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Safety Case Title: [Case title] COIN/CAP: [Coin number] / [Cap
number] Offshore Major Accident Regulator
Duty holder name: [Company Topic assessor: [Inspector]
name]
End of assessment
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Industrial Hygiene – Recognition, Evaluation and Control of hazards and risks to health
Chemicals
Each installation should maintain a complete inventory of hazardous substances used or generated,
together with ‘in-house’ or ‘suppliers’ Safety Data Sheets. Documented risk assessments should be
conducted to assess risk and appropriate controls put in place. For controlling the risk, priority should
be given to elimination of the hazard(s), engineering methods (containment, local exhaust ventilation)
and administrative measures. Reliance upon the use of personal protective equipment should only be
considered as a last resort. Control measures should be subject to testing and maintenance as
appropriate. Health surveillance should also be considered, and appropriate arrangements put in place,
where required.
Asbestos
Unless there is robust evidence that there is no asbestos on the installation, the location, condition,
quantity and type of all asbestos and asbestos containing materials (e.g. insulation materials, gaskets,
brake linings etc) should be determined (or assumed) and an ‘Asbestos Management Plan’ (AMP)
developed. As part of the AMP a risk assessment should be undertaken on the materials and
appropriate action taken. Information on the presence of Asbestos Containing Materials (ACM),
actions etc should be recorded in the AMP and passed to those who need to be made aware. The AMP
should detail how the ACMs will be managed in the long-term e.g. re-inspections, maintaining the
AMP and for dealing with the removal and disposal of asbestos. Particular attention needs to be paid
to maintenance or demolition work which might result in asbestos disturbance.
Noise
Each installation should implement a noise control policy. This should include risk assessment, a
‘Noise Action Plan’, demarcation of high noise areas and health surveillance (audiometry) based on
risk. Over reliance on ‘blanket’ hearing protection policies is often an indication of poor
understanding of the regulations as priority should be given to control of noisy plant and machinery
by engineering means. Noise criteria should be incorporated into design specifications of new plant
and equipment. Consideration also needs to be given to the effect of modifications on existing plant
and structures. Formal arrangements should be put in place for co-operation between operator and
contractor to ensure that, where appropriate, contractor employees are placed under suitable health
surveillance.
Ionising Radiation
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Where sources of ionising radiation are used (e.g. site radiography, nucleonic gauges) or where
workers are exposed to naturally occurring radiation (i.e. NORM/LSA scale); exposure to ionising
radiations must be kept as low as reasonably practicable. Exposures should not exceed specified dose
limits and restriction of exposure should be achieved first by means of engineering control and design
features. A safe system of work should be introduced, and personal protective equipment only
introduced as a last resort.
Thermal Environment
Thermal conditions which may pose a risk to health or wellbeing should be evaluated and procedures
developed to ensure that the risk to personnel is minimised.
Manual handling
Where there is a possibility of risks to employees from the manual handling of loads; a suitable and
sufficient assessment should be made, and the risk of injury reduced to the lowest level reasonably
practicable. The assessment should consider avoiding manual handling (e.g. automation), redesigning
the load, redesigning the task, redesigning the work environment and introducing mechanical
handling aids.
Microbiological hazards
Microbiological contamination of food and water must be controlled to minimise the risk of disease
i.e. food poisoning and water-borne diseases. The Hazard Analysis Critical Control Point (HACCP)
system is the benchmark means of assessing food and water safety
Duty holders are further required to ensure that an adequate supply of clean wholesome drinking
water is available at suitable locations on an offshore installation, and the purity of the water supply is
maintained and that such locations are clearly marked to show that drinking water is there.
Legionella
Typical offshore potable water systems include: all water transfer equipment (e.g. bunkering hoses),
water makers, storage facilities, distribution pipework, utilities, ancillary plant and equipment such as
pumps and water softeners etc.
To comply with their legal duties, duty holders should:
(a) identify and assess sources of risk. This includes checking whether conditions will encourage
bacteria to multiply
(b) if appropriate, prepare a written scheme for preventing or controlling the risk
(c) implement, manage and monitor precautions – if control measures are to remain effective, regular
monitoring of the systems and control measures is essential
(d) keep records of the precautions
(e) appoint a competent person with sufficient authority and knowledge of the water system to help
take the measures needed to comply with the law
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