offshore major accident regulator

OFFSHORE MAJOR ACCIDENT REGULATOR

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Title The offshore active fire protection inspection guide

Publication Date August 2021 Document Identification

Review Due August 2024 Internal Reference 2021/188192

Target Audience ED inspectors Document Owner ED3.2

Review History Date Changes Approved August 2021 Approved for issue H Harte

Contents

Review History ........................................................................................................... 1 Summary .................................................................................................................... 1 Introduction ................................................................................................................ 2 Relevant legislation .................................................................................................... 2 Supplementary information ........................................................................................ 3 Action ......................................................................................................................... 3 Background ................................................................................................................ 3 Other relevant inspection guides ................................................................................ 4 Specialist advice ........................................................................................................ 4 Appendix 1 ................................................................................................................. 5 Appendix 2 ................................................................................................................. 6 Appendix 3 ................................................................................................................. 8 Appendix 4 ............................................................................................................... 11 Appendix 5 ............................................................................................................... 14

Summary This inspection guide (IG) outlines an approach to the inspection of duty holder arrangements with respect to active fire protection and the key areas that inspectors should consider when inspecting this topic. It also sets out the criteria for satisfactory

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and unsatisfactory performance factors against which duty holder performance will be rated. Reference is made to technical standards and guidance that inspectors will use to form an opinion of legal compliance.

Introduction The purpose of this IG is to provide information and guidance to OMAR inspectors to support the delivery of consistent and effective inspection of duty holder arrangements to comply with the Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995 (PFEER).

This guide highlights key areas for inspection and provides a framework against which inspectors can judge compliance, assign performance ratings, and determine what enforcement action should be taken with respect to legislative breaches that may be found.

Relevant legislation Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995

Regulation 13 Mitigation of fire and explosion

The duty holder shall –

(a) take appropriate measures with a view to protecting persons on the

installation during an emergency from the effects of fire and explosion and;

(b) ensure that, so far as is reasonably practicable, any arrangements made

and plant provided pursuant to this regulation are capable of remaining

effective in an emergency.

PFEER ACOP (L65 Third edition 2016 www.hse.gov.uk/pubns/priced/l65.pdf )

170 Regulation 13 require the duty holder to put in place measures that will

mitigate the effects of fire and explosion (i.e., protect people on the installation from them). The duty holder must take into account not just direct hazards to people, but also hazards to structures or plant on which their safety depends. Measures include active and passive measures to mitigate the effects of fire and explosion.

171 This paragraph explains some of the important terms used in the regulation:

(a) measures – has the same meaning as in the guidance for regulation 4 General duty.

In the context of this regulation measures may provide active or passive protection and include plant, equipment, structures and workplace procedures.

Examples of these include:

(ii) deluge systems;

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(b) remaining effective in an emergency – means mitigation measures should, so far as reasonably practicable, be capable of remaining operational in major accident conditions for as long as they are needed to fulfil their functions, taking into account the conditions to which they may be exposed.

Supplementary information Offshore Information Sheet 3/2006 Guidance on risk assessment for offshore installations www.hse.gov.uk/offshore/sheet 32006.pdf

Offshore Information Sheet 5/2009 Provision of active fire protection on offshore installations www.hse.gov.uk/offshore/infosheets/is5-2009.htm

Offshore Information Sheet 1/2010 Water deluge systems: Testing and performance measurements www.hse.gov.uk/offshore/infosheets/is1-2010.htm

Action Inspectors should review relevant documentation related to the elements listed in Appendix 1 prior to the installation visit and test compliance during the installation visit using the Onshore and Offshore questions sets given in Appendix 3 and Appendix 4 respectively.

By the conclusion of the inspection, it should be possible to

• demonstrate the level of compliance to the statutory provision to mitigate

against potential fire and explosion events on offshore installations

When carrying out inspections covered by this IG inspectors should

• assess duty holder responses to the question sets in Appendices 3 and 4

• use the performance descriptors in Appendix 5 to

o determine the appropriate performance rating

o the initial enforcement expectation

o consider how and when the issues raised during an inspection are to

be closed out

Background There has been a long-standing need to have a structured approach to inspecting offshore active fire protection (AFP) systems which have in the past been emphasised by, for example, the ageing plant issues identified following the KP4 initiative. Compliance in this area is enshrined in the risk assessment and fire and explosion strategy explaining how the fire and explosion potential is mitigated offshore, but no discipline specific framework exists for the inspection of these active systems. This guide aims to address all the elements of such an inspection and

http://www.hse.gov.uk/offshore/sheet%2032006.pdf

http://www.hse.gov.uk/offshore/infosheets/is5-2009.htm

http://www.hse.gov.uk/offshore/infosheets/is1-2010.htm

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identify what a compliance demonstration needs to include when it comes to AFP systems offshore.

Other relevant inspection guides None

Specialist advice Specialist advice should be sought from ED 3.2 for any support required to enforce on any element contained in this guide, or any clarification required in the compliance demonstration made for any relevant provision.

The duty holder performance ratings should be entered on the Inspection Rating (IRF) Tab of the relevant installation Intervention Plan Service Order. Findings should be recorded in the post inspection report and letter.

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Appendix 1

The following is a summary of the AFP elements to be inspected

Design

AFP system(s) design and design compliance, the identification, assessment and

definition of integrity and performance requirements and management

arrangements, pipework specification, nozzle performance and operating

parameters, deluge skid definition and operating parameters, fire water supply

requirements, system survivability, and damage resistance performance

requirements.

AFP SMS

AFP system safety management system (SMS): Safety and environmental critical

element (SECE) identification, performance standard establishment, maintenance,

test, and inspection regimes.

AFP Integrity Management

Implementation of the AFP integrity management process: development and

implementation of planned maintenance routines (PMRs), inspection, evidence of

test and delivery of effective SECE management.

Emergency Response

Emergency planning and preparedness should be demonstrated by provision of an

effective AFP system. The system should enable the provision of effective mitigation

against fire (and blast overpressures - if appropriate). It should be clear that the

system is suitable and will perform its function in the event of a major accident

hazard (MAH).

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Appendix 2

At an AFP inspection some or several of the following concerns may be identified

a) Poor condition of the deluge system pipework, obvious impact damage including misalignment of directed deluge nozzles, leaking nozzles, corroded and damaged spray diffusers and deluge skid valves, and operating handles, very little fire water pump performance data recorded or analysed. Pump performance curves not available.

b) Evidence of bacteria growth, debris, scale or crustacean shell fragments inside the nozzle spray orifices, blockages, passing water out of some nozzles evidence of salt deposition below / on nozzles.

c) Passing elastomeric valves on a deluge skid, water build up above the dry system actuation valve, no procedure in place to check for water build up or prevention for such water entering the dry sections of the deluge system.

d) Lack of inspection for identification of system dead legs or measures to ensure any are regularly checked and drained as necessary.

e) Lack of provision to observe/inspect/maintain and reduce nozzle blockages from dry and wet system testing. No means for checking sensitive sections of the delivery pipework internal condition.

f) Limited or no positive response to reducing test interval for wet testing where nozzle blockage numbers are increasing on progressive wet tests; demonstration for continued suitability of the system is lacking.

g) Inadequate SECE definition for fire mitigation systems in other enclosures or high-risk fire areas such as the galley.

h) Stand-by or other fire water pumps out of service for an extended period of several months or more.

i) Duty fire water pumps not meeting their defined performance point(s).

j) Fire water performance testing failing performance criteria (flow rate, pressure) and not corrected using the pumps performance curve to confirm performance point compliance.

k) Deluge test fails to employ, flow socks, water trays or check for vessel dry spots or report details obtained from the use of such rate/coverage determining methods and equipment.

l) Poorly defined performance standards for AFP systems; failure to achieve performance criteria.

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m) Excessive delivery or activation time (30 seconds is often claimed as a target

in the safety case).

n) Low FWP delivery pressure and or flow rate to the deluge skids.

o) High hazard rating on the installation - from hydrocarbon inventories (oil, gas, and condensate, including pipelines if appropriate).

p) Clear indication of obsolescence issue such as mixed delivery heads on a single system.

q) Modification or decommissioning activities. Has the firewater system been modified, reduced, or removed for suppressant delivery to a fire zone/suppression system?

r) Inhibition of activation systems or control logic without an adequate assessment and implementation of alternative and equivalent means of activation and system operation.

Complete emergency shut down (ESD) functions on loss of power and remain in ESD state upon power restart - this should not allow SD systems to re-latch to the energised state for active components.

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Appendix 3

Onshore Question Set Topic Questions Duty Holder Response/ Inspector Comments

STANDARDS What (national/international/other) standard(s) have been used as the basis of design for the deluge systems (such as BSEN 13702, NFPA 15)?

OWNERSHIP DESIGN PURPOSE

Who has overall responsibility for AFP systems, makes decisions; implements plans; measures performance; reviews and secures improvements and compliance with audit arrangements?

Describe the purpose of your AFP arrangements or justify any alternative approach used (in the absence of AFP where any fire risk exists). On installations where several makes and types of equipment are already present (i.e., suppressant (water, CO2, foam, Inergen, or Dry Chemical etc.), deluge nozzles), it should be demonstrated that equipment has been selected based on the predicted hazards and that personnel competencies are consistent with equipment.

What are your deluge aims, objectives and priorities (are these reflected in any policy or statement)? How are the scope and definitions of the AFP systems linked to major accident risk?

Has the design and operation of each AFP system been subject to an independent audit?

If not, why not?

What changes/improvements have been made to any of the AFP systems in the last 3 years? What prompted these changes?

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OWNERSHIP DESIGN PURPOSE

Have there been any changes to any AFP system brought about as a result of an investigation into an accident or incident?

Is examination/test intelligence used to determine examination/test frequency?

What requirements are established as the minimum acceptable level of performance? (i.e., what level of compliance with the performance standard(s) are identified) for:

Response time Delivery nozzle:

blockage delivery pressure (max/min) suppressant flow rate Nozzle spray/distribution pattern

Coverage (for both directed and general area coverage)

System availability / reliability

Foreign Bodies such as scale/rust/biological growth

Dry areas

Drain/decontamination after use

Damage

How are the performance criteria measured, checked, recorded, and analysed?

Do you carry out regular AFP systems inspections? What resources are dedicated to these inspections?

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TRAINING AND COMPETENCE

How do you ensure that those who hold key responsibilities for AFP systems are made clear on what is expected of them? How are the employees and contractors involved with the AFP systems deemed competent?

What are the arrangements in relation to training records and competency assessment?

Are training programmes in place with records kept and periodically reviewed?

Is there a preferred list of contractors derived systematically versus health and safety standards?

What AFP systems are maintained via contractors?

Are contractors made aware of the relevant AFP system(s) requirements and standards?

COMMUNICATION

How are AFP expectations communicated to those responsible / undertaking any examinations/tests?

How are verifier findings and actions managed?

How are design issues addressed when they are identified?

What measures are in place to ensure that concerns over AFP performance are appropriately addressed?

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Appendix 4

Offshore Question Set Inspection topic Guidance Notes Inspection Findings / Comments

Maintaining the integrity of AFP:

How does the management system address integrity of AFP equipment and systems?

Is there a risk-based maintenance regime for all areas and equipment covered by AFP?

The integrity of AFP systems and equipment over the whole life of the plant should be addressed within the management system.

Factors which affect the integrity of AFP systems and component equipment should include: inspection, maintenance, environment conditions, assessment of actual condition, remedial measures, functional survivability, protection, diversity and redundancy, and dependence on other systems.

Responsibilities:

Are responsibilities/ accountabilities adequately defined for management of AFP equipment?

Responsibility/accountability extends to all levels of management. The safety management system should make clear how these responsibilities ensure the effective management of AFP equipment.

Training and Competence

How is competence established / assured?

Is there a register of competent persons?

How is the competence of vendors addressed?

How is suitability of new equipment assessed?

Is there a demonstration that the personnel have adequate qualifications, knowledge, experience, and training to undertake their responsibilities?

A competence assurance scheme should cover the range of knowledge and task skills appropriate to the AFP equipment and associated fittings on the installation.

A register of competent personnel should be kept by the duty holder – this includes any personnel employed to design, right through to those maintaining the equipment.

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Offshore Question Set Inspection topic Guidance Notes Inspection Findings / Comments

Maintenance and Operational Procedures:

Does the duty holder have specific maintenance program and calibration procedures for AFP equipment?

Do these procedures reflect manufacturer’s specifications?

Operational and maintenance personnel should be aware of the operational requirements of AFP equipment in terms of manual, mechanical and environmental interference.

Are personnel aware of the predicted hazard levels within an area/module, predicted or measured release rates, number of distribution nozzles requiring maintenance, predicted or measured fault levels, environmental conditions (indoor/outdoor), and nozzle type?

The calibration/function testing procedures should reflect the manufacturer’s recommendations.

Removal and Reinstatement Procedures:

Do the maintenance and operational procedures cover removal and reinstatement of equipment?

Procedures for the routine removal and replacement of AFP equipment should be available. These should include

• a risk assessment to ensure that adequate coverage is provided during removal

• procedures for deluge cover assessment during removal/replacement and where operation is required to continue

• assessment of additional risks arising from erection of temporary access structures

• spares policy

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Distribution System Checks

Inspection Findings / Comments

Pump/delivery system Location(s)

Pipework routing

Control Valve location

Nozzle orientation

Equipment Accessibility

Component vulnerability - environmental

Redundancy

Availability

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Appendix 5

Application of EMM and duty holder performance assessment

When inspecting the offshore active fire protection topic, duty holder compliance is to

be assessed against the relevant success criteria. The success criteria have been

determined from specific regulatory requirements, defined standards, established

standards or interpretative standards.

This assessment will determine the: EMM Risk Gap, the associated topic performance

score together with the Initial Enforcement Expectation as shown in the table below.

The actual enforcement may differ from that consistent with the recorded topic score

depending on duty holder and strategic factors. However, should this occur then the

relevant duty holder and strategic factors should be identified in the inspection report.

The Topic Score recorded on COIN must be consistent with the Initial Enforcement Expectation

Further guidance can be found at: http://www.hse.gov.uk/enforce/emm.pdf

EMM RISK GAP Extreme Substantial Moderate Nominal None None

TOPIC PERFORMANCE SCORE 60 50 40 30 20 10

Unacceptable Very Poor Poor Broadly Compliant

Fully Compliant

Exemplary

Optional IG Specific Performance Score Guidance (delete if not used) Specific IG Guidance

Specific IG Guidance





EMM Initial Enforcement Expectation Prosecution / Enforcement Notice

Enforcement notice / Letter

Enforcement notice / Letter

Letter / Verbal warning

None None

It should be noted that

• the recorded score should reflect the most significant compliance gap identified relevant to the inspection guide

• the IG and hence the allocated scores may not cover all the matters that were

considered during the intervention

• the intervention may not necessarily have used every part of the IG -

consequently the score only reflects what was inspected. The inspection

http://www.hse.gov.uk/enforce/emm.pdf

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report should make it clear what aspects of the IG the duty holder has been scored against (or it is clearly identifiable by a letter item)

• where the score only relates to limited aspect of the IG then consideration

should be given to consulting the IG owner before finalising the score

• proposed inspection scores should be reviewed/discussed by the full

inspection team before finalising

• the impact of cumulative risk should be considered when scoring1

• the allocated performance score only reflects regulatory judgements about a

duty holder’s degree of compliance at a particular point in time

Use of performance scores

HSE uses the performance scores as one of the many inputs to prioritise and plan

future regulatory interventions. Prioritising interventions is fundamental to ensuring

HSE delivers its major hazards regulatory strategy whilst supporting businesses and

the GB economy. HSE aims to ensure that regulatory activity is proportionate to the

risk to people taking account a duty holder’s performance in controlling risks. In

general, this means the HSE will inspect major hazard installations and duty holders

with relatively poorer risk management performance more frequently and in greater

depth than lower hazard installations and duty holders where there is evidence of

higher risk management performance.

1 For example, two or three substantive scores of ‘30’ will point strongly to an overall score of ‘40’. There is currently no mathematical or other systematic process for doing this and inspectors must therefore use their judgement to allocate an appropriate score that best represents the overall inspection findings against this IG.

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