Risk Matters 02:2018

At Forge Risk, we understand the full range of benefits that are experienced by strong, enduring and successful organisations. These organisations have the flexibility and resilience to anticipate and respond effectively to the risks – opportunities and threats – impacting on their business. We hope that our update and insights will inform and inspire you and your organisation in how to meet the risk challenges in an ever more complex and interconnected world.

We welcome feedback, especially on our opinion piece on the role of Standardisation in the wind sector. Leaving the politics aside, with the increased complexity and connectivity of business and technology, there has never been a more crucial time to champion the positive safety and economic benefits that standards can provide. However, this will require a high level of industry collaboration if we are to achieve consensus when developing risk-based standards seen as essential for the sector.

RISK

Wind Turbine life extension

IEC has agreed to the development of a new technical specification (Through life management and life extension, IEC 61400-28.) TC-88 has approved the formation of a project team (PT-28) to write the specification and the first meetings are expected to take place during Q3/4 of 2018. The UK is taking the lead on the project and there is currently an active process of engagement with the wind sector including seeking the participation of key stakeholders and individuals

with relevant experience to support this project. This will be initiated by means of a breakfast briefing for wind farm operators, hosted in London by Lloyd’s Register during the week beginning 11th September 2018.

Examples of issues that the working group has already been made aware of include:

• Existence of several suitable documents, valid in particular countries or regions, either for guidance purposes or for formal verification (e.g. Netherlands, Germany and Denmark)

• The relative importance of inspection, numerical analysis and risk analysis as parts of the process of assessment of the suitability of a particular wind project for extended operation

• Variability of information about the historical and current condition of wind farm assets (including selection of appropriate tools, factors of confidence/ safety for dealing consistently with these variable levels of information)

• Lack of knowledge about the spectrum of failure modes and their relative importance, for instance via a failure modes, effects and criticality analysis (FMECA) resulting in risk matrices for each mode of failure (“risk” includes both probability and consequence)

• Variable proposals from consultants about methods for assessing the risks associated with extended operation

• Importance of independent methods and techniques for the following, which have been validated and which give reliable indications of current and future risks, including probability of failure:

– estimation of the historical deterioration of a component or system with respect to a particular function or mode of failure, either by use of operational data, repair statistics or the results of remote diagnosis, on-site inspection or non-destructive testing

– estimation of remaining useful life – estimation of the probability of failure: currently and at a

defined future point in time – relative merits of various statistical approaches, based on

machine learning (either supervised or unsupervised)• The importance of sharing key design information about

turbines (design, manufacture, transport, installation and commissioning), operating software, major components, site conditions and operational history (failure, refurbishment, repair and retrofit):

– in particular, margins of safety, reliability, structural integrity and the assumptions used to estimate these

Welcome to Risk Matters, our regular update on risk, regulation and standards. The editorial focus is health and safety in renewables, construction and asset management. However, skills, sustainability and corporate governance will also be topics we will cover.

45001: Executive Briefing www.forge-risk.co.uk/services/training

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“...there has never been a more crucial time to champion the positive safety and economic benefits that standards can provide.”

FORGE RISK2

As a responsible industry, the drive for efficiency gains and cost reductions should never be at the expense of compromising health and safety performance. The legal, contractual, economic and reputational implications are just too great to even imply corners are being cut. However, what is becoming clearer as the offshore wind sector moves to the next stage of growth and onshore looks at turbine life extension – standards and harmonisation can and must play an increasingly key role going forward.

OPINION: Health & Safety Standardisation

At their worst, poor standards can stifle innovation, create narrow and defensive compliance cultures and add cost and complexity throughout the supply chain.

At their best, good standards stimulate innovation, drive down costs, reduce risks, enhance resilience and instil a learning culture that delivers continual improvement across the supply chain and lifecycle of project delivery. Forge Risk are presenting a paper at Wind Europe 2018 to support the session (How standardisation is creating a safer and more productive workforce) where we will be setting out A Risk based approach to wind standardisation to deliver enhanced efficiency and safety improvements. To support the presentation a full paper will be published. However, in this edition of Risk Matters we summarise some of the key issues and opportunities we will highlight.

Context The presentation and article will look at the opportunities standards and harmonisation can play for the wind sector. The focus will be on occupational and product health & safety standards but many of the principles equally apply to the standardisation of design, project, contractual, process and operational issues. The focus will be from the perspective of workers engaged in the construction, operation and maintenance of wind farms and balance of plant. A key theme will be to ensure we don’t let any key H&S risks fall through the cracks by assuming safety is someone else’s problem but also, we take care not to re-invent the wheel by merely adding a “wind badge” to tried & tested standards.

The presentation and full article will set out:

• Basic understanding on the role, application and use of standards• Contextualisation of the risks and opportunities of standardisation

in the wind sector• The principles and benefits of applying a risk-based approach to

standardisation • A summary of priority areas for standardisation in wind sector• A postscript acknowledging current geo-political challenges and

opportunities

Role, application and use of standards

We all use the terms standardisation and harmonisation without necessarily understanding their meaning or their application. Wikipedia summarise standardisation as “the process of implementing and developing technical standards based on the consensus of different parties that include firms, users, interest groups, standards organizations and governments”. In relation to standards - ISO state how it was founded on the idea of answering a fundamental question: “what’s the best way of doing this?” which is a simple description of the purpose of standards setting. The full article will consider the distinct types of “standards” [e.g. Product safety; Occupational safety] and reflect on their different application depending whether they relate to ‘Supply Side’ legislation (e.g. Rules for manufacturers, importers distributors and other vendors) or ‘In service’ legislation (e.g. Rules for employers and others). One of the key messages is understanding that in effect all standards are voluntary with only constitutional requirements & legislation being mandatory (See Figure 1.)

Figure 1 : Relationship & Status of Laws & Standards

Examples: • Laws: EU Directives/Acts/Regulations e.g. Machinery Directive

(2006/42/EC)• Harmonised Standards: Type B & C Standards e.g. EN ISO

19353:2016 Safety of machinery - Fire prevention and fire protection

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OPINION: Health & Safety Standardisation

• Other Standards: EN 50308:2004 Wind Turbines – Protective Measures

• Rules & Codes of Practice: Wind Turbine Safety Rules v3: 2015• Industry Guidance: Good practice guideline the safe management

of small service vessels used in the offshore wind industry (G+); Basic Safety Training (GWO)

A key message will be not that any one type of standard is better than another – but that it’s about choosing the right type standard to achieve the right outcome and that this needs to be risk and context specific.

Risks and opportunities of standardisation The article will reflect on the transformation of the wind sector and acknowledge that the status and recognition of health & safety is being given an ever higher profile. This has resulted in the development of industry focused rules, standard, statistics, and good practice guidelines produced by organisations such as G+; IMCA; RenewableUK; AWEA and GWO. The initiatives are to be commended and work plans of the organisations indicate that further standards and good practice guidance will be produced going forward. However, there remains several challenges and gaps that potentially expose the wind sector to a range of significant risks (e.g. Regulatory intervention; Major Incidents; Serial Safety Defects; Licence Restrictions). Examples that exacerbate this situation include:

• There are currently no Harmonised Safety Standards for wind turbines. Potentially relevant standards are either dated & poorly drafted (e.g. EN 50308:2004) or were not created with the primary purpose of addressing product or occupational safety risks (e.g. IEC 61400-1; IEC 61400-3)

• All published industry standards are in effect “voluntary”. There are strong contractual and reputational drivers that encourage/enforce compliance and regulators will use them as a benchmark to judge compliance with the law. However, their implementation at a national and global level is at best inconsistent to the degree it would often be difficult to infer a sector wide consensus of the standard.

• Many of the H&S initiatives are solely focused on the offshore sector. It would be harsh to criticise many of the positive initiatives taken by the sector, but we are already creating technical, cultural and organisational silos between the onshore and offshore sector. The differences should not be ignored – not least as we risk losing vital knowledge and organisational learning because of this.

• Many of the initiatives, understandably, have been driven by lagging H&S metrics and narrowly focused with limited consideration of health risks. This has resulted in the development of safety and compliance driven standards & guidelines while potentially underplaying more complex risks (e.g. low frequency: high consequence events) that a more risk-based approach to standardisation would consider.

• Available H&S statistics (LTIR/TRIR) show safety performance is above benchmark sectors. The reasons appear complex and care is needed about simplistic comparisons in the absence of normalised data sets – but it does indicate significant improvement opportunities remain.

When looked at collectively – the key issue is that there is no clear consensus as to what the key risks and priorities are, and in turn, where are the biggest opportunities for seeking standardisation across the onshore and offshore wind supply chains? Priority areas for standardisation The article will encourage stakeholders in the wind sector to seek a greater alignment in adopting a risk-based approach to standardisation, with an emphasis on balancing the value and opportunities to be gained against the absolute and relative risk of the issues concerned. It will also recognise that standards need to reflect the degree of maturity and consensus of what good practice is. This is to try and avoid creating red or blue tape that could stifle innovation but also to prevent the risk of market failure where safety standards could be seriously compromised by not implementing standards and good practices that are well recognised. Postscript By way of a post script – the article will acknowledge the risks posed by Brexit, protectionism and multi-polarisation to the degree that “standards” & “rules” have never been under such an existential theat. While leaving the politics aside – with the increased complexity and connectivity of business and technology, there has never been a more important time to champion the positive safety and economic benefits standards can provide. The wind sector has a terrific opportunity to become a beacon of excellence in the development and dissemination of standards. All stakeholders working across the wind supply chain and related sectors are strongly encouraged to take every opportunity to support the development and maintenance of relevant standards that add value and reduce the risk burden on the sector.

The Article is a work in progress so we welcome comments on your experience of standards in the wind sector, including suggestions of the priority areas where standards could add value to the sector.

Source: Wind Europe

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– detail design of site-specific or turbine specific elements such as foundations, cable routes, civil works, scour, jack-up spud-can locations during installation or major retrofit tasks

• Potential for imminent obsolescence of key replacement components or substitution by suitable alternatives or new suppliers, compatibility, equivalence, reliability.

This is a vital project, essential to ensure the safety and ongoing sustainability of the wind sector. The UK has an opportunity to take a global lead in this area – so active engagement of the sector is strongly encouraged. Forge Risk will be supporting this initiative. [Acknowledgement: Thanks to BSI (PEL/88 & Mark Spring (Lloyds Register).] To express an interest in supporting this project please contact your national association (e.g. BSI) or mark.spring@lr.org.

Cable Burial Risk Assessment

Interesting Blog from Cathie Associates on Defining Acceptable Risk for Cable Burial. It follows previous discussions on Cable Burial Risk Assessment Methods and references the Carbon Trust Cable Burial Risk Assessment Guidelines. [The Carbon Trust Cable Burial Risk Assessment (CBRA) Guidelines offer a standardized, repeatable and qualitative method to improve risk management of subsea cables, improve estimates of risk through reducing undue conservatism, and ultimately reduce the installation and insurance costs for subsea cables.]

Cathie Associates state existing guidance provides a good framework for undertaking clear and repeatable assessments, however, they don’t always provide significant detail for assessing every aspect and several uncertainties remain such as Seabed Mobility and Anchor Penetration Depth. They also acknowledge the challenges when trying to determine what is an “Acceptable Risk” – a common challenge for all risk practitioners. [Source: Cathie Associates]

Temperature in the Workplace HSE has reminded duty holders of its frequently asked questions on temperature in the workplace. They have also highlighted their advice on outdoor working in hot environments to:

• Reschedule work to cooler times of the day• Provide more frequent rest breaks and introduce shading to rest

areas• Provide free access to cool drinking water• Introduce shading in areas where individuals are working• Encourage the removal of personal protective equipment when

resting to help encourage heat loss• Educate workers about recognising the early symptoms of heat

stress

The advice includes a reminder of the risks of exposure to ultraviolet (UV) rays in sunlight.

BEAMA Updates

• RCD Handbook - Guide to the Selection and Application of RCDs: BEAMA have published a new Handbook: BEAMA Guide to the selection and application of Residual Current Devices (RCDs). This Guide provides specifiers, installers and end users, guidance on the selection and application of the wide range

of RCDs now available. It details the specific applications of Types AC, A, F and B RCDs which are now recognised in BS 7671: 2018 IET Wiring Regulations 18th Edition. Guidance is also given on the installation and maintenance of RCDs, including many of the installation conditions that cause ‘unwanted tripping’.

• BEAMA: New Product Guides & Bulletins: BEAMA have published a series of Guides & Bulletins to coincide with the publication of the 18th Edition of the Wiring Regulations. They include:

– Technical Bulletin: Overload protection of an RCCB or switch in an LV assembly to BS EN 61439-3:

– Technical Bulletin: Coordination of wiring accessories, low voltage switchgear and control gear assemblies with conductors operating at a temperature exceeding 70 °C e.g. XLPE.

– BEAMA Guide to Arc Fault Detection Devices (AFDDs): – The RCD Handbook: BEAMA Guide to the selection and

application of Residual Current Devices (RCDs): – BEAMA Guide to Surge Protection Devices (SPDs) – Selection,

Application and Theory:

Construction: Offsite manufacturing for improved safety

HM Government has published details of its construction sector deal as part of the wider Industrial Strategy. One of the key themes is to promote the adoption of digital and to encourage the move to offsite manufacturing to strengthen local supply chains across the UK. These are both seen as having significant safety benefits.

Horizon scanning report 2018 Business Continuity Institute’s Horizon Scan Report 2018 sets out the top threats, disruptive factors and investment priorities as seen by business leaders around the world, together with the key standards that help organizations carry out horizon scanning. The report puts forward five conclusions:

1. Cyber incidents remain the biggest concern both in the long and the short term

2. Physical security challenges of different types are also a significant threat to organizations

3. New laws and regulations are not considered as one the main challenges for organizations in the short term

4. The potential emergence of a global pandemic is perceived to be an issue in the longer term

5. A growing number of professionals are becoming aware of benefits of business continuity. (Source: BCI & BSI)

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BIM: Health and Safety Outcomes in Construction Interesting report published by HSE (Improving Health and Safety Outcomes in Construction Making the Case for Building Information Modelling (BIM)). [“Building Information Modelling (BIM) supports the digitisation of construction and uses information relating to the assets to build a three-dimensional model with supporting intelligent, structured data attached to them. It is a way of working underpinned by digital technologies to unlock more efficient methods of designing, creating and maintaining assets. The information contained within the models facilitates better decision making, resulting in better business outcomes, improved communication, and enables de-risking of construction activities; all of which leads to improvements in efficiency”]. There appears significant opportunity for renewables and energy infrastructure to recognise the value BIM principles and practice could offer. (Source HSE. See also http://bim-level2.org/en/standards/)

The Healthy Profit Interesting new guidance issued by IOSH (The healthy profit) setting out how investments in safety, health and wellbeing are

giving businesses the edge. The report examines why and how smart businesses are transforming themselves as employers to respond to social and commercial pressures to protect and optimise their number one asset.

REGULATION

STOP PRESS: H&S EU Exit Regulations 2018 Government have published The Health and Safety (Amendment) (EU Exit) Regulations 2018. The Regulations ensure that EU-derived health and safety protections will continue to be available in domestic law after the UK has left the EU. Part 2 amends subordinate legislation and Part 3 amends retained direct EU legislation in relation to the field of health and safety.

HSE Business Plan: 2018/19 HSE have published their Business Plan for 2018/19. It commits to a sustained momentum on “our Helping Great Britain work well strategy”, focusing on the highest-risk sectors and building on the stakeholder engagement and commitments made to widen the reach of the campaign to new audiences. Examples of priorities include:

• Managing and updating the regulatory framework including making technical changes to ensure retained EU law still functions effectively on exit

• Preparing necessary changes to the chemicals regime as part of work on the UK’s exit from the European Union

• Working across the health and safety system to share learning on blue tape issues and identify ways to promote proportionality in the system

• Deliver 20 000 proactive inspections to prevent harm, with increasing use of campaigns that focus these inspections on specific issues and activities found in high-risk industries

• Work with stakeholders, including trade associations, on strengthening leadership and worker engagement across all the major hazard sectors

• Take a leading role in the UK’s agenda on dealing with cybersecurity in the safety sphere across industries

• Deliver targeted interventions focusing on the control of high-consequence risks.

Health and Safety Law Pocket Cards

HSE have issued a new set of pocket cards which are a legal alternative to the HSE approved Health and Safety Law poster. The pocket cards are suited to issuing to workers, providing them with a personal copy of the health & safety law. They are particularly helpful for workers who do not have a fixed base, common in renewables and energy infrastructure development and operations.

New Gas Safety Regulations The Gas Safety (Installation and Use) Regulations 1998 have been amended via new 2018 Regulations which came into force on 6th April 2018. It is supported by a new Approved Code of Practice (ACOP) and guidance which includes practical advice to those with responsibilities under: (a) the Gas Safety (Installation and Use) Regulations 1998 (SI 1998 No 2451) as amended; and (b) sections 2(1), 2(2)(c), 3(1) and 3(2) of the Health and Safety at Work etc Act 1974 with regards to standards of training in safe gas installation. The PPE Directive and the PPE Regulation The new PPE Regulation (EU) 2016/425 came into force on 21 April 2018 and will be fully effective on 21 April 2019. While many suppliers have been proactive in communicating the changes, many duty holders have not fully taken account of the changes and especially show a lack of understanding on the different categories of PPE. BSI have provided helpful guidance including an informative white paper. (Source: BSI). See also the Personal Protective Equipment (Enforcement) Regulations 2018 which provides for the enforcement of Regulation (EU) 2016/425 and designates market surveillance authorities for the purpose of EU Regulation 2016/425 and these Regulations.

GDPR & Health & Safety The media coverage following the introduction of the implementation of GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)) understandably did not discuss the implications for the health & safety community. However taking account the sensitive information often collectively held by companies (e.g. Health/Medical; Personal; Financial), GDPR is highly relevant. Good guidance is set out by the Information Commissioners Office and the European Commission. However it is vital that companies have clearly set out policies covering GDPR that actively takes

(Source: IOSH)

6 FORGE RISK

account relevant health & safety information. Forge Risk have already see examples where overzealous GDPR “compliance” is leading to the loss of access to potentially vital information that could compromise the safety, health & wellbeing of employees and others. Best practice is still developing in this area and we hope a sensible balance between privacy and proportionate risk management will be achieved over the next few years.

Independent Review of Building Regulations and Fire Safety: Final Report

The review’s final report, which makes recommendations on the future regulatory system following the Grenfell Tower fire has been published. (Building a Safer Future Independent Review of Building Regulations and Fire Safety: Final Report).

It makes sobering, with Dame Judith Hackitt expressing her personal

views of the key issues underpinning the system failure including: Ignorance; Indifference; Lack of clarity on roles and Inadequate regulatory oversight and enforcement tools.

Grenfell Tower Enquiry: Expert Evidence Valuable and informative Expert Evidence Report has been submitted to the Grenfell Enquiry (Legislation, Guidance & Enforcing Authorities Relevant to Fire Safety) by C S Todd & Associates Ltd. It reinforces the complexity and often opacity of much of the fire safety regime.

Environment: Legal Briefs

• Environment Agency enforcement and sanctions policy: The Environment Agency has updated its guidance on how it uses its enforcement and sanctioning powers to secure compliance with laws that protect the environment.

• Environmental Principles & Governance after EU Exit: DEFRA is consulting on the development of an Environmental Principles and Governance Bill. This new piece of legislation will mark the creation of a new statutory and independent environmental watchdog to hold government to account on our environmental ambitions and obligations once the UK has left the EU. This new body will work alongside a new policy statement setting out the environmental principles that will guide successful and sustainable policy-making, marking the beginning of a new era for our environment. (Source: DEFRA).

• Breach Offences Definitive Guideline: In accordance with section 120 of the Coroners and Justice Act 2009, the Sentencing Council has issued new definitive guidelines. It applies to all offenders aged 18 and older, who are sentenced on or after 1 October 2018, regardless of the date of the offence.

Chemicals HSE: Chemicals & BREXIT: HSE have provided an update on the developments in the EU withdrawal negotiations for businesses affected by chemicals regulatory processes. It explains the terms of the political agreement reached between the negotiators of the United Kingdom and the European Union in March 2018. The terms of that agreement are not yet legally binding and remain subject to signature and ratification/conclusion between the parties. Subject to conclusion and ratification of the draft Withdrawal Agreement, the implementation period will start on 30 March 2019 and last until 31 December 2020. Guide on safety data sheets and exposure scenarios: The European Chemicals Agency (ECHA) has published a new Guide to help suppliers and recipients of safety data sheets to compile and understand substance and use information more easily. It includes:

• Examples of safety data sheets and exposure scenarios• Descriptions of what information is contained in each section of

the safety data sheet and exposure scenario• Advice on what to do to promote safe use and regulatory

compliance• Tips for suppliers on information that downstream users need• Tips for recipients on actions they may need to take based on the

information received.

EU-OSHA Dangerous substances: EU-OSHA has updated its website section detailing essential information on dangerous substances at the workplace. It covers the main legislation, explains its principles and provides tips on how to manage dangerous substances at work. It also includes sections on carcinogens, biological agents, and emerging risks – and provides many useful links to further information for workers and employers. It also provides a link to the Healthy Workplaces Manage Dangerous Substances Campaign 2018-19.

HSE Safety Alerts

• Scaffolding and work platforms: HSE have issued a Safety Alert: Preventing unauthorised access onto scaffolding and other work platforms. (11/7/18). The Alert is issued to remind contractors, and those in control of construction work involving scaffolding and access ladders, of the need to assess the site and ensure suitable and sufficient measures are in place to prevent members of the public, and especially children from climbing scaffolds and ladders.

• Cylinders manufactured from aluminium alloys: HSE have issued a Safety Alert (Cylinders manufactured from aluminium alloys HE30/AA6082 and AA6351 and used primarily for gases for underwater breathing apparatus) following several recent catastrophic failures of aluminium cylinders used primarily to contain gases for underwater breathing apparatus and manufactured from aluminium alloys HE30/AA6082 and AA6351. These cylinders should only be used if they have undergone thorough visual inspection and testing with an eddy-current device by a competent inspector.

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HSE Diving Information Sheets HSE have updated several Diving Information Sheets (DVIS). DVIS 5 (Exposure Limits for Air Diving Operations); DVIS 7 (Bell run & Bell Lock out times); and DVIS 9 (Diver’s breathing gas standard and the frequency of examination and tests) have been significantly updated. DVIS 12 (Cleaning of Diving Equipment); DVIS 13 (Differential pressure hazards in diving); and DVIS 14 (The noise exposures of working divers) incorporate minor updates to align with the current version of the ACoPs.

Workplace fatal injuries: GB 2018 HSE have published the latest statistics for workplace fatal injuries. Headline figures were a total of 144 workers were killed at work in Great Britain in 2017/18. Although an increase from 2016/17 in statistical terms the number of fatalities has remained broadly level in recent years. Construction remains the highest (38) in absolute terms. Falls from height remains the highest by accident kind. (Source: HSE).

“Think again” before investing in “off-the-shelf” manual handling training Off-the-shelf manual handling training should become a thing of the past, according to new HSE advice. The new advice is aimed at helping

employers decide what type of help they need to tackle the MSD risks in their workplace. It illustrates different approaches with examples, and identifies who may be able to help address their needs.

CAA/HSE/HSENI Memorandum of Understanding guidance CAP 1484 An updated CAA/HSE/HSENI MOU has been published The MOU provides guidance to Civil Aviation Authority (CAA), Health and Safety Executive (HSE) and Health and Safety Executive Northern Ireland (HSENI) colleagues to support the strategic goals of the CAA/HSE/HSENI Memorandum of Understanding. It provides details on areas of potential enforcement overlap. The guidance will also be of interest to other stakeholders in the aviation industry that may be subject to safety regulation by the CAA, HSE and HSENI. (Source CAA)

FOCUS ON...

Electronic Permits: Why are we still using paper?

“Technological developments impact on every aspect of our working and personal lives. Renewables and energy infrastructure is embracing technology and understandably this is often focused on enhancing operational efficiencies and driving down costs. But how much of this is risk or safety focused? Are we maximising the opportunities that could come out of advances in Data Management, Smart Devices and Diagnostics to name a few

especially in providing real time, predictive and value added “risk” information?” (See Risk Matters 01:18).

Forge Risk fully supports these developments, but are we missing some “quick wins”? As a specific example why are still using paper systems as our default “compliance” tool and specifically should we be actively supporting the move to electronic documentation for Safety Permits (e.g. WTSR)?

Our summary below is prompted by the recent update of the Wind Turbine Safety Rules (“WTSR”) Guidance (Edition 3: 2015 - Issue 2 - 15/06/18) which includes a new Support Procedure P8 – Procedure for Approval of Electronic Safety Document Systems.

Legislation & Guidance

Legislation and guidance to support the implementation and operation of Electronic Permits remains confusing, with limited detail specifically related to health & safety. However relevant sources include:

• Electronic Communications Act 2000 • Electronic Signatures Regulations 2002 (SI 2002 No. 318) • Data Protection Act 2018 • GDPR (Regulation (EU) 2016/679) • Electronic Signatures Guide (2014) - Department for Business

Innovation & Skills • HSG – 250 Guidance on permit-to-work systems: A guide for the

petroleum, chemical and allied industries (2005) • BS EN ISO/IEC 27002:2017 Information technology. Security

techniques. Code of practice for information security controls • BS ISO 15489-1:2016 Information and documentation. Records

management. Concepts and principles General Requirements The Guidance (P8) sets out important general requirements to take account of before moving to an Electronic Safety Document System (“ESDS”). These include:

• A risk assessment to be completed before moving to an ESDS. • Company to write and issue a Management Instruction to detail

how the use of an ESDS shall be implemented and maintained. • Support Procedure P2 and the relevant Management Instructions

for the approval of tools, equipment and processes shall be met prior to implementing an ESDS.

• The Safety Document System is fully supported and updated to prevent it from becoming outdated and or/incompatible with operating systems on electronic devices.

• The ESDS shall have a unique identity for each of the Appointed Persons who are intending to use the system.

• Appointed Persons shall not provide other persons (Appointed or not) with their login/identity details.

General Safety

Safety from the System

Safe System of Work

+ =

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• The ESDS shall not allow any technical or safety content of the Safety Document to be changed once it has been Approved by the Authorising Engineer.

• The electronic device shall have suitable and sufficient security so that the input of the required data on to the Electronic Safety Document (“ESD”) can only be controlled by the Competent Technician or Authorised Technician in charge of the Working Party.

• ESDs shall only be updated/uploaded/managed and Approved in accordance with the correct procedure for document issue/update as detailed in the Management Instruction.

• There shall be a process available to follow by Appointed Persons, that in the event that the electronic system fails or is unavailable, Safety From The System can be maintained and that an Approved audit trail can be maintained.

• Company to ensure that any wireless networks crucial to the successful operation of the ESDS are proven to be robust enough to allow reliable use of the system.

• ESDs shall be safely archived for a period of time as defined in the Management Instruction.

• ESDs shall be archived in such a way that they can be readily audited by the relevant Managers, safety professionals and independent parties.

• The device that is used to interact with an ESD shall be physically robust enough and managed in such a way that it can cope with the rigors of the working environment.

• The device that is used when using an ESD shall be configured in such a way that the time and date cannot be changed by the Appointed Persons.

• Hyperlinks can be contained within ESD to enable easy cross reference against method statements, risk assessments and other associated supporting safety documentation.

• ESDs shall meet the same minimum standards of content and formatting as described within the WTSR as that of paper-based Safety Documents.

P8 also sets out specific requirements for Approved Written Procedures (AWP’s) and Routine Operating Procedures (ROP’s) including the ability to accept counter signatures and secondary signatures on the ESD. In addition the Approved Written Procedure should be capable of being put into ‘virtual’ safe custody for the purposes of Surrender so that only an Authorised Technician with the relevant appointment can gain access to the Safety Document when work is to be resumed.

The Guidance also makes clear that before introducing an ESDS operators shall ensure that: 1. A suitable system (e.g. password-protected electronic signatures)

is in place to prevent unauthorised issue or acceptance 2. Documents (e.g. AWP’s) cannot be issued remotely without a

site visit3. Systems are in place to prevent documents already issued from

being altered without the alterations being communicated to all concerned

4. The facility exists for paper documents to be produced for display at the job site

5. Training is provided to ensure that operators assess the specific job and do not rely on ‘cutting and pasting’ existing sections from other documents.

6. Suitable back-up systems are available in the event of a software failure or power outage.

The guidance issued by RenewableUK is to be supported and is an example where the wind sector is taking a proactive lead. However, the awareness of this guidance to support the WTSR remains low and so stakeholders are encouraged to assist in its dissemination – but also to look at the wider opportunities that can be gained through a move to electronic documentation in variety of health & safety critical applications. It is also hoped that overzealous GDPR “compliance” does not put back what are clearly positive and risk-based improvements that will benefit the whole sector.

[Note: The above includes edited text from P8. Please refer to the original guidance. Acknowledgement: RenewableUK]

STANDARDS

WEC’s: Marking lighting of wind turbines

IEC TC88 have put forward a New Work Item Proposal (NP) for marking and obstruction lights of wind turbines that build on and complement the IEC 61400 series. It is intended to provide a set of technical requirements for marking the surface of Wind Energy

Converters (WECs) to ensure the integrity of aeroplanes flying above wind farms. The proposed scope covers:

• Colorimetric quantities and the luminance factor or ordinary colours and the type and shapes of marking to make conspicuous to pilots during daylight• Requirements for usage, installation positions, number of light fittings installed at each level, angle for installation of obstruction • Marking and lighting system(s) which adapts to all possible climate conditions

• Risk assessment and features of lighting with ADS • Requirement for IR radiation from WECs lights to make visible to

rescue teams performing flights at low altitude.

Contact your National Standards Association (e.g. BSI) for more details.

9 FORGE RISK

Box 1: Other Standards: Other recent draft and published standards of interest to risk professionals in renewables, construction and energy infrastructure:

• ASTM E2505 - 07(2014)e1. Standard Practice for Industrial Rope Access.

• BS 45002-0:2018. Occupational health and safety management systems. General guidelines for the application of ISO 45001.

• BS 10754-1: 2018 Information technology - Software Trustworthiness - Part 1 – Governance and management specification

• BS 31111:2018 Cyber risk and resilience – Guidance for the governing body and executive management.

• BS 7671:2018. Requirements for Electrical Installations. IET Wiring Regulations.

• BS EN 1568-3:2018. Fire extinguishing media. Foam concentrates. Specification for low expansion foam concentrates for surface application to water-immiscible liquids

• BS EN 16719:2018. Transport platforms. • BS EN 16991:2018. Risk-based inspection framework. • BS EN 50527-2-2:2018. Procedure for the assessment of the

exposure to electromagnetic fields of workers bearing active implantable medical devices. Specific assessment for workers with cardioverter defibrillators (ICDs)

• BS EN 689:2018. Workplace exposure. Measurement of exposure by inhalation to chemical agents. Strategy for testing compliance with occupational exposure limit values.

• BS EN IEC 60079-0:2018. Explosive atmospheres. Equipment. General requirements

• BS EN IEC 61010-2-120:2018. Safety requirements for electrical equipment for measurement, control, and laboratory use. Particular safety requirements for machinery aspects of equipment

• BS EN IEC 61010-2-201:2018. Safety requirements for electrical equipment for measurement, control, and laboratory use. Particular requirements for control equipment

• BS EN IEC 61204-7:2018. Low-voltage switch mode power supplies. Safety requirements

• BS EN IEC 61730-1:2018. Photovoltaic (PV) module safety qualification. Requirements for construction

• BS EN IEC 61730-2:2018. Photovoltaic (PV) module safety qualification. Requirements for testing

• BS EN IEC 62046:2018. Safety of machinery. Application of protective equipment to detect the presence of persons.

• DC. BS EN 61496-1. AMD 1. Safety of machinery. Electro-sensitive protective equipment. Part 1. General requirements and tests

• BS EN IEC 62485-1:2018. Safety requirements for secondary batteries and battery installations. General safety information

• BS EN IEC 62485-2:2018. Safety requirements for secondary batteries and battery installations. Stationary batteries

• BS EN IEC 62485-4:2018. Safety requirements for secondary batteries and battery installations. Valve-regulated lead-acid batteries for use in portable appliances

• BS EN IEC 62561-2:2018. Lightning protection system components (LPSC). Part 2: Requirements for conductors and earth electrodes (IEC 62561-2:2018)

• BS EN ISO 15085:2003+A2:2018. Small craft. Man-overboard prevention and recovery.

• BS EN ISO 16147:2018. Small craft. Inboard diesel engines. Engine-mounted fuel, oil and electrical components.

• BS EN ISO 22300:2018. Security and resilience. Vocabulary. • BS EN ISO 9004:2018 Quality management – quality of an

organization – Guidance to achieve sustained success • BS ISO 18079-2:2018. Ships and marine technology. Servicing

of inflatable life-saving appliances. Inflatable life rafts• BS ISO 18079-3:2018. Ships and marine technology. Servicing

of inflatable life-saving appliances. Inflatable lifejackets• BS ISO 19703:2018. Generation and analysis of toxic gases

in fire. Calculation of species yields, equivalence ratios and combustion efficiency in experimental fires.

• BS ISO 45001:2018. Occupational health and safety management systems. Requirements with guidance for use.

• BS ISO/IEC 20000-1:2018 Information technology — Service management — Part 1: Service management system requirements.

• DC. BS 45002-3. Occupational health and safety management systems. Part 3. General guidelines for the application of ISO 45001. Guidance on incident investigation

• DC. BS 7671. IEC 60364-5-57. Low-voltage electrical installations. Part 5. Selection and erection of electrical equipment. Clause 57. Erection of stationary secondary batteries

• DC. BS 8081 AMD2. Code of practice for grouted anchors. • DC. BS 8599-1. Workplace first aid kits. Part 1. Specification

for the contents of workplace first aid kits• DC. BS EN 1004. Mobile access and working towers made of

prefabricated elements. Materials, dimensions, design loads, safety and performance requirements.

• DC. BS EN 15154-5. Emergency safety showers. Part 5. Water overhead body showers for sites other than laboratories

• DC. BS EN 15154-6. Emergency safety showers. Part 6. Plumbed-in multiple nozzle body showers for sites other than laboratories

• DC. BS EN 50110-2. Operation of electrical installations. Part 2. National annexes

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ISO/DIS 29400 Ships & Marine: Offshore Wind Energy

An update to this standard is currently out for enquiry. This second edition cancels and replaces the first edition (ISO 29400:2015). Changes include Clause 3: Terms and definitions revised; new definitions inserted; — Clause 7: “Metocean Requirements” fully revised; — Clause 20: “Cable load-out and offshore transfer” new subclauses added. While the standard has been improved – it still needs changes that reflect current and emerging practices. Consultation on the original standard was poor – with the wind sector not being actively informed or engaged in its drafting. Contact your trade/industry association or your national standards body (e.g. BSI) to participate in the enquiry. Voting Closes 19 September 2018.

Withdrawal and replacement of IEC 61400-22:2010 - Wind turbines - Part 22 IEC will withdraw IEC 61400-22:2010, Wind turbines - Part 22: Conformity testing and certification, effective 31 August 2018. It will be replaced by the IECRE conformity assessment system. For further details including the IECRE publication Verifying the safety, performance and reliability of renewable energy equipment and services, see www.iecre.org/documents/presentations.

Global standards for fire safety

More than 30 organisations have united to create The International Fire Safety Standards (IFSS) Coalition to develop industry standards to globally address fire safety in buildings. The coalition consists of local and international professional bodies and standard-setting organisations, committed to developing and supporting a shared set of standards for fire safety in buildings. The standards aim to set and reinforce the minimum requirements professionals should follow to ensure building safety in the event of a fire. (Source: Fire Industry Association)

IEC 62351-8 Power systems management

IEC are consulting on an IEC 62351-8 Power systems management and associated information exchange – Data and communications security – Part 8: Role-based access control. The scope of the standard is to facilitate role-based access control (RBAC) for power system management. RBAC assigns human users, automated

systems, and software applications to specified “roles”, and restricts their access to only those resources which the security policies identify as necessary for their roles. As electric power systems become more automated and cyber security concerns become more prominent, it is becoming increasingly critical to ensure that access to data is restricted. Contact your National Standards Association (e.g. BSI) for more details.

GRI 403: Occupational Health and Safety 2018

The Global Reporting Initiative (GRI) have published an update of the Occupational Health & Safety Reporting Standard (GRI 403). The Standard has been revised to focus on the presence of robust occupational health and safety management systems, and the processes and programs that prevent harm and promote worker health. The new Standard aligns with key international instruments from the International Labour Organization (ILO) and with ISO 45001.

BS EN ISO 19011:2018 Guidelines for auditing management

The 2018 standard has been extensively revised and now includes: • A risk-based approach to the principles of auditing• Expanded guidance on audit planning• Adjusted, more user-friendly terminology• Expanded guidance on newer concepts such as context, leadership

and commitment

In view of the recent publication of 45001 - this is an important complementary standard to be aware of.

ISO 22316:2017 Security and resilience

This standard (ISO 22316:2017 Security and resilience. Guidelines for organizational resilience) defines “resilience” and provides a framework and strategy to develop, implement and evaluate organizational resilience. It is the first international standard to provide the terminology, principles, attributes and activities that support an organization in enhancing its resilience. ISO 22316 recognizes resilience as the ability of an organization to absorb and adapt in a changing environment to enable it to deliver its objectives and to survive and prosper. It covers resilience in the context of an organization (rather than a community, society or country). (Source: BSI)

BS ISO 10005:2018 Quality management

BS ISO 10005:2018 has been updated to align with ISO 9001:2015. It includes a greater emphasis on use by service industries. The revision also includes an increased focus on the concept of risk-based thinking, and guidance on the importance of context when developing quality plans. (Source: BSI)

Continues on page 12...

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Box 2: Other Standards: Other recent draft and published standards of interest to risk professionals in renewables, construction and energy infrastructure:

• BS EN ISO 41001:2018 Facility management • BS 8572:2018 Procurement of facility related services• DC. BS EN 50676. Electrical equipment used for detection

and concentration measurement of refrigerant gases or SF6. Performance requirements and test methods.

• DC. BS EN 54-13. Fire detection and fire alarm systems. Part 13. Compatibility and connectability assessment of system components

• DC. BS EN 60050-195. International Electrotechnical Vocabulary. Part 195. Earthing and protection against electric shock

• DC. BS EN 60079-10-1. Explosive atmospheres. Part 10-1. Classification of areas. Explosive gas atmospheres

• DC. BS EN 60079-25. Explosive atmospheres. Part 25. Intrinsically safe electrical systems

• DC. BS EN 60255-27. Measuring relays and protection equipment. Part 27. Product safety requirements

• DC. BS EN 60825-2. Safety of laser products. Part 2. Safety of optical fibre communication systems (OFCS)

• DC. BS EN 61010-2-120. Safety requirements for electrical equipment for measurement, control, and laboratory use. Part 2-120. Particular safety requirements for machinery aspects of equipment

• DC. BS EN 61025. Fault tree analysis (FTA). • DC. BS EN 55011 AMD 2. Industrial, scientific and medical

equipment. Radio-frequency disturbance characteristics. Limits and methods

• DC. BS EN 61293. Marking of electrical equipment with ratings related to electrical supply. Safety requirements.

• DC. BS EN 61318. Live working. Conformity assessment applicable to tools, devices and equipment.

• DC. BS EN 61400-7. Wind turbines. Part 7. Safety of wind turbines power converters

• DC. BS EN 61439-1. Low-voltage switchgear and control gear assemblies. Part 1. General rules

• DC. BS EN 61496-2. AMD 1. Safety of machinery. Electro-sensitive protective equipment. Part 2. Particular requirements for equipment using active opto-electronic protective devices (AOPDs)

• DC. BS EN 62061. Safety of machinery. Functional safety of safety-related electrical, electronic and programmable electronic control systems.

• DC. BS EN 62282-2-100. Fuel cell technologies. Part 2-100. Fuel cell modules. Safety

• DC. BS EN 62423 AMD1. Type F and type B residual current operated circuit-breakers with and without integral overcurrent protection for household and similar uses.

• DC. BS EN 62446-2. Photovoltaic (PV) systems. Requirements for testing, documentation and maintenance. Part 2. Grid connected systems. Maintenance of PV systems

• DC. BS EN 62477-1. Safety requirements for power electronic converter systems and equipment. Part 1. General

• DC. BS EN 63104. Solar trackers. Safety requirements. • DC. BS EN 764-7. Pressure equipment. Part 7. Safety systems

for unfired pressure equipment • DC. BS EN IEC/IEEE 62271-37-013. High-voltage switchgear

and controlgear. Part 37-013. Alternating-current generator circuit-breakers

• DC. BS IEC 62125. Environmental considerations specific to insulated electrical power and control cables.

• DC. BS ISO 14117. Active implantable medical devices. Electromagnetic compatibility. EMC test protocols for implantable cardiac pacemakers, implantable cardioverter defibrillators and cardiac resynchronization devices.

• DC. BS ISO 24409-1. Ships and marine technology. Design, location and use of shipboard safety signs, fire control plan signs, safety notices and safety markings. Part 1. Design principles

• DC. BS ISO 7010 AMD 239 & 243. Graphical symbols. Safety colours and safety signs. Registered safety signs.

• PAS 3002:2018. Code of practice on improving health and wellbeing within an organization.

• PAS 7100:2018. Code of practice on consumer product safety related recalls and other corrective actions: Part I: Business Part II: Regulators.

• PD IEC TR 61511-0:2018. Functional safety. Safety instrumented systems for the process industry sector. Functional safety for the process industry and IEC 61511

• PD IEC TR 62246-3:2018. Reed switches. Reliability data for reed switch-devices in typical safety applications

• PD IEC/TS 62915:2018. Photovoltaic (PV) modules. Type approval, design and safety qualification. Retesting.

• PD ISO/IEC TS 17021-10:2018. Conformity assessment. Requirements for bodies providing audit and certification of management systems. Competence requirements for auditing and certification of occupational health and safety management systems

• PD ISO/TS 19837:2018. Safety of machinery. Trapped key interlocking devices. Principles for design and selection.

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Electrical Energy Storage (EES) systems Part 1: Vocabulary (IEC 62933-1:2018)

This new standard defines terms applicable to electrical energy storage (EES) systems including terms necessary for the definition of unit parameters, test methods, planning, installation, safety and environmental issues. The terminology is applicable to grid-connected systems able to extract electrical energy from an electric power system, store it internally, and inject electrical power to an electric power system. The step for charging and discharging an EES system may comprise an energy conversion. (Source: BSI)PAS 3002:2018: Improving health and wellbeing within an organization

This Code of practice on improving health and wellbeing within an organization provides recommendations that should help organizations establish, promote, maintain and review the health and wellbeing of their workforce. It considers how health and wellbeing are incorporated into the working environment and how leadership is demonstrated by way of the available health and wellbeing related services. (Source: BSI)

BS EN ISO 14118:2018 - Safety of machinery - Prevention of unexpected start-up

BS EN ISO 14118:2018 - Safety of machinery - Prevention of unexpected start-up specifies requirements that design-in ways to prevent unexpected machine start-ups. This allows humans to work in machine danger zones. This is an update of the international standard published in 2000 and a replacement for BS EN 1037:1995+A1:2008 which has been withdrawn. (Source: BSI)

SECTOR UPDATES

Leadership on Onshore Health and Safety

RenewableUK have provided an update following the Bootle onshore health and safety event held at HSE (February 2018). Leading companies and associations in onshore wind have agreed to establish and be leading members of an organisation dedicated to supporting the delivery of world class health and safety leadership and performance in onshore wind here in GB. The Organisation will work to reduce health and safety risk and the relative rate of incidents in onshore wind in an efficient and co-operative manner.

The next step, for this organisation, will be to meet and formalise the establishment of this Organisation. Priorities are expected to include:

• Establishing Onshore Health & Safety Data recording and reporting • Coordinating a programme of workshops on chosen industry

design areas • Developing good practice guidance for identified topics• Delivering an events, communication, and consultation

programme to ensure industry leadership and engagement.

Further updates are expected in September 2018. (Source: RenewableUK)

Extending Turbine Lift Statutory Inspection

Interesting case study produced by ORE Catapult (Sally Shenton and Conaill Soraghan | January 2018 | CS-0018). The case study sets out the purpose and scope of a Written Scheme of Examination and how the case study organisation (Siemens Gamesa (at the time Siemens Wind Power)) successfully extended the intervals of wind turbine lift statutory inspections using this mechanism. Key findings included:

• Extending the lift inspection interval has reduced turbine visits and , and enabled integration of scheduled activity, unlocking significant cost reductions and operational efficiencies.

• In a representative 100-turbine offshore wind farm, annual inspections can reduce personnel and vessel costs of the supplier by £93,334 and a reduction of 400 personnel transfers. Downtime is reduced to 400 hours: equivalent to a saving of £66,240 in lost production.

• In general, most stakeholders are supportive of the objective to extend these inspection intervals, including asset owners and the Health and Safety Executive (HSE), given the potential reduction in man hours, turbine visits and downtime.

The full Case Study is available via ORE Catapult.

Emergency Response Intervention at an Offshore Wind Farm

ORE Catapult have published a case study (Dr Conaill Soraghan and Sally Shenton June 2018 CS-00211) on the Benefits of advanced medical training for technicians. The summary was:

“Offshore wind farm operators undertake a regular review of emergency response arrangements, taking on board learning from risk identification workshops, drills, and significant near-misses. To supplement its existing basic first aid training, provided through the Global Wind Organisation/ RenewableUK standard, one offshore

13 FORGE RISK

FORGE RISK - SERVICES

Corporate H&S Briefing: Check out our bespoke training services that reflect new and emerging regulatory requirements, enforcement activity and prosecution and sentencing trends. We highlight our Corporate Health & Safety Briefing that can be run as a 1-2 hour briefing through to a full day interactive session which can also be IOSH accredited. Live topics being requested by clients include updates on:

• Update on Sentencing Guidelines• New draft Manslaughter Sentencing Guidelines• New/Draft Wind Turbine & Energy Storage Safety standards• Brexit – what will happen to health & safety?• CDM – application to wind projects• HSE Enforcement Priorities• ISO 45001 – Implications for senior management• Crisis management & Emergency Response• Personal & Board H&S responsibilities

For details on our training services or anything in this newsletter – please do not hesitate to get in touch.

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wind operator (who preferred not to be identified) implemented advanced medical training for many of its offshore technicians and support staff. This advanced training was put into practice during an incident whereby a worker was injured in a turbine hub. Evaluation of the treatment provided, and the emergency response undertaken, highlighted that the advanced training was a significant factor in getting the injured party successfully transferred to hospital, and was material in ensuring his injuries did not become life-threatening. In light of this real-life incident, others in the industry are being encouraged to consider their arrangements, and to drive further adoption and standardisation.” (Source: ORE Catapult) Good practices for international standardisation

IRENA have published a report on the benefits of good practices for international standardisation in the offshore wind sector. The report recognises that “As the offshore wind power generation spreads to more countries, standardisation can help to overcome market barriers and spur further deployment.” Headline findings include:

• Widely recognised standards can strengthen trade, enhance co-operation through international organisations, and increase consumer confidence

• Successful implementation depends on quality infrastructure, including metrology, testing, certification and accreditation schemes

• Comprehensive standardisation involves cross-cutting work related to local policy, marine conditions, offshore wind technologies, and offshore oil and gas experience

• Existing standards largely reflect the requirements of the European offshore wind industry.

• Health and safety standards for the industry need to be harmonised

Further work is also needed on standards for control systems, operation and maintenance, shipping, stowage and clamping of wind turbine components, and wind farm end-of-life procedures.

GWO Training Standards Review 2018-2019

GWO have been consulting on some important changes to their portfolio of training standards. These cover:

• BST Sea Survival • BTT (Mechanical Module) • BTT (Electrical Module) • BTT (Hydraulic Module)

Responses to the consultation will be compiled by the GWO Secretariat and fed into the review for consideration by the GWO Training Committee.

Chris Streatfeild | Forge Risk

E: chris@forge-risk.co.ukW: www.forge-risk.co.ukM: 07375 512 261