Health and Safety Documents in connection with offshore oil and gas operations

Arbejdstilsynet, The Danish Working Environment Authority (WEA) guideline 65.1.13-1 on Health and Safety Documents in connection with offshore oil and gas operations

January 2017

The most important rules on Health and Safety Documents for installations with connected infrastructure and pipelines.

This guideline concerns the most important rules concerning requirements for when a Health and Safety Document (also known as a Health and Safety Case (HSC)) must be available for installations, connected infrastructure and pipelines in connection with offshore oil and gas operations, as well as requirements for the content of the Health and Safety Document.

The guideline is aimed at operators and owners with a duty to prepare Health and Safety Documents for installations with connected infrastructure and pipelines, but the safety organisation on individual installations may also benefit from the guideline.

For operators and owners with operating permits issued before 19 July 2015, some of the requirements for the content of the Health and Safety Document will not enter into force until 19 July 2018. This is specified in more detail in the guideline.

The most important rules

The Offshore Safety Act stipulates that the operator and the owner, respectively, must prepare a Health and Safety Document before an installation with connected infrastructure or a pipeline may be commissioned. 
The Health and Safety Document accounts for management of health and safety risks and risks of major environmental incidents.

In the following, the main elements of the Health and Safety Document for installations with connected infrastructure and pipelines will be described:

1. Content of Health and Safety Documents 
1.1. General information and summary 
1.2. Description of the installation etc.
1.3. Risk management 
1.4. Description of the management system 
1.5. Independent verification 
1.6. Internal emergency response plan 
2. Time for preparation of Health and Safety Documents 
3. Updating Health and Safety Documents 
3.1. Continuous updates during operations 
3.2. Updates in connection with applying for a permit to make modifications 
3.3. Updates in connection with applying for a decommissioning permit
3.4. Thorough review of the Health and Safety Document 
4. Involvement of employees 
5. Operation of installations after expiry of their design lifetime 
6. Availability of Health and Safety Documents 
7. Compliance with the Health and Safety Document 
8. Regulations for vessels 
8.1. Pipe-laying vessels 
8.2. Crane vessels 
8.3. Accommodation vessels 
8.4. Well intervention and stimulation vessels 
8.5. FSOs 
9. Transitional provisions for existing installations 
10. Schematic summary

1. Content of Health and Safety Documents

There are no formal requirements for Health and Safety Documents. The Health and Safety Document may be organised as an independent, complete, controlled document or as a system of documents. An example of the latter can be seen in figure 1 which conforms to the Offshore Safety Act requirements for the content of a Health and Safety Document for an installation with connected infrastructure or a pipeline.

Figure 1
The Health and Safety Document should be an auditable document, which means that, based on the Health and Safety Document, an auditor must be able to find the documentation on which the Health and Safety Document is based.

The Health and Safety Document, or elements of this, may cover several fixed installations with connected infrastructure which have the same operator or owner. The Health and Safety Document may apply generally to conditions that are the same across the installations, connected infrastructure and pipelines, e.g. parts of the management system.
Any subsequent updates of the Health and Safety Document during operation may also apply generally. This also requires that installations with connected infrastructure have the same operator or owner. 
The following sections describe how information required by law to be included in a Health and Safety Document can be set into the model above. Furthermore, the legislative provisions will be further explained where relevant.

1.1. General information and summary

The section comprising general information and summary may include the following details:

  • Name and address of the operator and the owner, respectively.
  • Analysis of the installation(s) covered by the Health and Safety Document.
  • A summary of how employees have been involved in preparation of the Health and Safety Document, see section 4.

The summary may also include brief descriptions of the other parts of the Health and Safety Document, with reference to the documents in which these parts are described in detail.

1.2. Description of the installation etc.

In this section, the design and operational conditions of the installation may be described, including:

  • For a production installation, a fixed non-production installation with connected infrastructure or a pipeline: A description of how the response from the supervisory authority to the operator’s or the owner’s design notification has been taken into account.
  • A description of the installation, connected infrastructure, the pipeline and any association with other installations or connected infrastructures or pipelines, including wells. This includes
    • based on the design notification for a new permanently manned production installation, a description of how the installation is divided into main areas and the location of these areas in relation to each other, how the main areas are connected, whether, for example, a fire barrier has been established between the main areas, or whether they are connected by bridges. Overall briefing about the types and number of wells and other operational conditions, connected infrastructure and pipelines between the installation and other installations or between the installation and the shore, and
    • for other installations, a description of how the installation is divided into areas according to the degree of danger with respect to risks of fire and explosion.
  • For mobile non-production installations: A description of how the installation is transferred between different locations, and its stationing system.
  • A description of the types of operations with health and safety risks and risks of major environmental incidents to be carried out on the installation, connected infrastructure or pipelines, and the maximum number of persons that can be on the installation simultaneously.
  • A description of systems and arrangements which, in connection with major accidents or incidents with the potential of such accident, serve to ensure controls regarding
    • well operations,
    • process safety,
    • containment of hazardous substances and materials,
    • prevention of fire and explosion,
    • protection of employees against hazardous substances and materials, and
    • protection of the environment.
  • A description of the measures taken to
    • protect persons on the installation or connected infrastructure against health and safety risks,
    • prevention of risks of major environmental incidents,
    • ensure safe escape, evacuation and rescue, and
    • maintain control systems that serve to prevent damage to the installation, connected infrastructure and the environment in the event that all persons are evacuated.
  • Codes, standards and guidance used in the construction and commissioning of the installation, connected infrastructure or a pipeline.
  • Any other information, for example where two or more installations are operated in combination in a way which affects the risk of major accidents on either or all installations.
  • Any information relevant to other requirements in the Offshore Safety Act or in regulations pursuant to this Act.
  • With respect to operations conducted from the installation, connected infrastructure or pipeline, information relating to the prevention of major accidents resulting in a major environmental incident relevant to other requirements in the Offshore Safety Act or regulations pursuant to this Act, and which has been obtained pursuant to regulations on environmental impact assessments pursuant to the Subsoil Act.
  • An assessment of the identified potential environmental impacts resulting from the loss of containment of pollutants and materials arising from a major accident, and a description of the technical and non-technical measures envisaged to prevent, reduce or offset them, including monitoring.
  • The areas in which monitoring devices to automatically and continuously measure gas concentrations at specified places, automatic alarms, devices to automatically cut off power from electrical installations and devices to automatically stop internal combustion engines have been installed.
  • The necessary measures taken to prevent the occurrence and accumulation of potentially explosive atmospheres, and, where there is a risk of an explosion, the measures required to prevent ignition of the potentially explosive atmosphere.
  • The measures taken to prevent, detect and combat the outbreak and spread of fires.
  • How a remote control system has been implemented to take over in emergency situations for systems for
    • ventilation,
    • emergency shut-down of equipment which may cause ignition,
    • prevention of the escape of flammable liquids and gas,
    • fire protection and
    • well control.
  • The extent to which permanently manned installations are equipped with
    • an acoustic and optical system capable of transmitting an alarm indication to every manned part of the installation as necessary,
    • an acoustic system capable of being heard distinctly in all parts of the installation where people on board are frequently present, and
    • a system capable of maintaining communication with the shore and rescue services.

1.3. Risk management

This section documents risk management.

Risk management comprises the following elements:

  • Identification of risks.
  • Assessment of risks.
  • Evidence that risks have been identified, assessed and reduced in accordance with the ALARP principle.

All the elements are described in more detail in the DWEA guideline on risk management in connection with offshore oil and gas operations as well as the DWEA guideline on the ALARP principle in connection with offshore oil and gas operations. These guidelines also describe the required content of the documentation.

1.4. Description of the management system

This section describes the structure of the management system of the operator and the owner, respectively, with respect to health and safety, including the organisation of the enterprise, and its documentation for how its management systems ensure and document compliance with the regulations of the Offshore Safety Act as well as Executive Orders pursuant to the Act. Requirements for the content of the management system of the operator and the owner, respectively, are described in the DWEA guideline on management systems for health and safety in connection with offshore oil and gas operations. The description of the management system should make it possible to perform an audit of the extent to which the management system complies with the legislative requirements.

1.5. Independent verification

This section describes schemes for independent verification.

Independent verification includes the following areas:

1.5.1. Safety and environmental critical elements.

1.5.2. Well operations.

1.5.3. Evacuation analyses.

1.5.4. Pressure equipment on production installations and fixed non-production installations.

1.5.5. Any optional verification of other health and safety conditions.

More specific requirements for independent verification, as well as the content of the descriptions of individual schemes, are described in the guidelines on independent verification mentioned under “Read more”.

1.6. Internal emergency response plan

The internal emergency response plan includes the operator’s or the owner’s plan for measures to prevent escalation or limit the consequences of accidents and hazardous situations on an installation, connected infrastructure or a pipeline.

This section should contain either an exhaustive description of the emergency response plan based on the evacuation analysis, among other things, or the plan in its entirety. However, the part of the plan comprising the oil spill emergency response plan should not be enclosed, but should be sent directly to the Danish Environmental Protection Agency for approval.

2. Time for preparation of Health and Safety Documents

The Health and Safety Document for installations, connected infrastructure or pipelines must be prepared prior to commissioning installations, connected infrastructure or pipelines, and by no later than in connection with applying for an operating permit. Measures that are described in the Health and Safety Document and that must be taken in connection with operations in order to reduce health and safety risks according to the ALARP principle must be implemented and documented prior to commissioning installations, connected infrastructure or pipelines.

Prior to commissioning installations, connected infrastructure or pipelines, the rules concerning general duties will apply to health and safety conditions during project planning, installation and construction.

3. Updating Health and Safety Documents

3.1. Continuous updates during operations

The Health and Safety Document must be updated if, during operation, material modifications are made to the installation, connected infrastructure or a pipeline, or to their layout, equipment or operational conditions, and if these modifications have an impact on the health and safety risks or risks of major environmental incidents.When the Health and Safety Document is structured according to the model described in section 1 above, it will be an advantage if the update is restricted to elements concerning the modification, i.e. in most cases section 1.3 on risk management, section 1.4 on description of the management system, or section 1.6 on the internal emergency response plan.

An update will be required in the case of material physical or operational modifications that have an impact on the risk of major accidents. Such modifications require a prior permit, see section 3.2.

Furthermore, updates are required in connection with material modifications concerning risks not associated with risks of major accidents, e.g. material modifications to workstations, setting up new workstations or decommissioning workstations, or material modifications to procedures for work performance.

3.2. Updates in connection with applying for a permit to make modifications

In connection with applying for a permit to modify an installation, connected infrastructure or a pipeline, the updated Health and Safety Document must also contain sufficiently detailed information to

  • fully update the previous Health and Safety Document and associated internal emergency response plan for the installation, and
  • demonstrate that health and safety risks and risks of major environmental incidents are reduced to a level as low as reasonably practicable.

For combined operations, the Health and Safety Document for the individual installations must be updated, and, as a minimum, a description must be provided of how management of health and safety risks on the installations involved is coordinated. This description should take the form of a bridging document or an interface document describing the responsibilities of each of the operators and owners, respectively, as well as their shared responsibilities, in connection with combined operations.

3.3. Updates in connection with applying for a decommissioning permit

In the case of decommissioning a fixed installation, connected infrastructure or a pipeline, the updated Health and Safety Document must include, as a minimum, the following information:

  • Means of isolating all hazardous substances and materials.
  • In the case of wells connected to the installation, permanent sealing of the wells from the installation, other connected infrastructure and the environment.
  • A description of health and safety risks associated with decommissioning the installation, connected infrastructure or pipeline to persons and the environment, a description of the total exposed population, and a description of the risk control measures.
  • Emergency response arrangements to secure safe evacuation and rescue of persons and to maintain control systems for preventing a major environmental incident.

3.4. Thorough review of the Health and Safety Document

The Health and Safety Document must be subject to a thorough periodic review by the operator and the owner, respectively, at least every five years. The five years will be calculated either from the time when the DWEA has issued an operating permit or a modification permit, or from the time of the last thorough review. A summary of the thorough review and the result of it must be submitted to the supervisory authority by no later than one month after the review has been performed.

Irrespective of the above, the DWEA may require at any time that a thorough review is performed. This will typically be the case if the DWEA has the impression that the content of the Health and Safety Document no longer reflects the actual conditions on the installation or pipeline. If relevant, the requirement for a thorough review will be based on considerations of proportionality.

4. Involvement of employees

The operator and the owner, respectively, must ensure that the health and safety representatives on the installation are involved in preparation or updating of the Health and Safety Document, and that this is documented in a summary describing how the involvement has taken place, see section 1.1. See also the DWEA guideline on cooperation on health and safety in connection with offshore oil and gas operations.

5. Operation of installations after expiry of their design lifetime

If operation of an installation, connected infrastructure or a pipeline is planned to proceed after the expiry of its design lifetime, the Health and Safety Document must demonstrate that health and safety risks originating from the safety and environmental critical elements of the installation have been identified, assessed and reduced to a level as low as reasonably practicable in the planned operation period. The expected length of the planned operation period must be stated in the Health and Safety Document.

6. Availability of Health and Safety Documents

The Health and Safety Document must be available on the offshore installation, either electronically or on paper, and it must be accessible to the management and the employees on the installation as well as to the DWEA.

Furthermore, the operator and the owner must ensure that physicians, occupational health clinics and health authorities responsible for occupational health assessments have access to the Health and Safety Document when this is relevant for employee health checks.

7. Compliance with the Health and Safety Document

The operator and the owner, respectively, have a duty to implement health and safety measures and measures to prevent major environmental incidents as laid down in the Health and Safety Document.

8. Regulations for vessels

The following section describes how the Health and Safety Document for an installation covers associated vessels which are not, in themselves, considered to be installations.

With certain exceptions, vessels are excluded from the definition of an installation, and consequently, independent Health and Safety Documents are not required for these facilities. If a vessel performs an operation in connection with an installation, the Health and Safety Document of the installation will cover the operations of the vessel.

An exception is vessels performing operations involving a risk of major accidents, and vessels where no installation is connected. Furthermore, floating production, storage and offloading vessels (FPSOs) and drillships are considered installations. Read more in the DWEA guideline on concepts related to offshore oil and gas operations.

8.1. Pipe-laying vessels

Pipe-laying vessels are not regulated in the Offshore Safety Act. The reason for this is that operations on these vessels are not generally assumed to involve a risk of major accidents. If a pipe-laying vessel performs operations within the safety zone of an installation, the risks to the installation caused by these operations will be covered by the Health and Safety Document of the installation.

8.2. Crane vessels

Crane vessels are not considered installations. However, in cases where lifting operations are performed in connection with an installation, lifting operations performed from such vessel will be covered by the Health and Safety Document. When the crane vessel is used to install a new fixed installation, lifting operations will be covered by the installation operator’s risk management system with respect to risks of damage to the installation or to the part of the installation lifted by the crane vessel. Management of health and safety risks on the vessel itself is covered by the specific rules of the Flag State.

8.3. Accommodation vessels

The accommodation section of accommodation vessels that is used for accommodation for persons working on an associated installation will be covered by the Health and Safety Document of the associated installation.

8.4. Well intervention and stimulation vessels

For well intervention vessels, including well stimulation vessels, a distinction is made between well intervention vessels operating in connection with an installation, and well intervention vessels operating without any connection to an installation, e.g. in a submarine well.

When the well intervention vessel operates in connection with an installation, the operations are associated with a well on the associated installation, and risk management in connection with well operation must be dealt with in the Health and Safety Document of the associated installation.

If the well intervention vessel operates without any connection to an installation, e.g. in a submarine well not forming part of an installation, the well intervention vessel will be considered an installation, and a separate Health and Safety Document is therefore required for the vessel.

8.5. FSOs

Floating storage and offloading units (FSOs) located within the safety zone of an associated installation are considered connected infrastructure and will thus be covered by the Health and Safety Document of the associated installation. If the FSO is located outside the safety zone, it will be considered a separate installation operating in combination with the installation to which the FSO is associated (combined operation).

9. Transitional provisions for existing installations

For operators and owners with operating permits issued before 19 July 2015, some of the requirements for the content of the Health and Safety Document will not enter into force until 19 July 2018.

This concerns sections 5-9, section 12, section 22(5) and (6), section 23, with respect to risks of major environmental incidents, as well as sections 30-33 and sections 35-53 of Executive Order no. 1198 of 23 October 2015 on Management of Safety and Health etc. in connection with Offshore Oil and Gas Operations etc., which will not apply until 19 July 2018 for installations and connected infrastructure for which an operating permit was granted according to section 28 of the Safety etc. for Offshore Installations for Exploration, Production and Transportation of Hydrocarbons Act, cf. Consolidated Act no. 520 of 13 May 2013, before 19 July 2015. Until this date, the existing rules shall apply, including the associated penalty provisions, cf. Part 12.

10. Schematic summary

Schematic summary of sections applying to different types of installations etc.

*) Intervention vessels operating without any association to an installation.