2001/091 OFFSHORE TECHNOLOGY REPORT Inspecting and auditing the management of emergency response

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2001/091 OFFSHORE TECHNOLOGY REPORT Inspecting and auditing the management of emergency response
Health & Safety
Inspecting and auditing the
management of emergency response
Prepared by
LINK Associates International Ltd
for the Health and Safety Executive
Health & Safety
Inspecting and auditing the
management of emergency response
LINK Associates International Ltd
Aspen Drive
DE21 7SG
United Kingdom
© Crown copyright 2002
Applications for reproduction should be made in writing to:
Copyright Unit, Her Majesty’s Stationery Office,
St Clements House, 2-16 Colegate, Norwich NR3 1BQ
First published 2002
ISBN 0 7176 2321 1
All rights reserved. No part of this publication may be
reproduced, stored in a retrieval system, or transmitted
in any form or by any means (electronic, mechanical,
photocopying, recording or otherwise) without the prior
written permission of the copyright owner.
This report is made available by the Health and Safety
Executive as part of a series of reports of work which has
been supported by funds provided by the Executive.
Neither the Executive, nor the contractors concerned
assume any liability for the reports nor do they
necessarily reflect the views or policy of the Executive.
Link Associates International Ltd had prepared this report under contract to the Offshore Safety
Division of the Health and Safety Executive. Its primary intended purpose is as a source of
information for use by HSE specialist inspection teams when drawing up inspection and audit
initiatives in the field of emergency response management. The Report gives background
information on the importance of offshore emergency response, on the content of emergency
response systems, on the mechanisms established in Great Britain for assessing the emergency
command capabilities of offshore managers, and it contains suggestions for the Regulator
regarding inspection and auditing.
For the purpose of this report an emergency response system is considered to comprise of two
parts; emergency command and the remainder of the emergency response system. The report
examines the health and safety legal duties applying to these two areas and provides suggestions
to the Health and Safety Executive on how it might be involved in influencing and regulating
emergency response standards. The report contains detailed information on the Offshore
Petroleum Industry Training Organisation (OPITO) Standard for emergency command, and on
how the Standard is applied by OPITO approved bodies. It is suggested that this information
should be used as a knowledge base to inform and stimulate discussion rather than in direct
regulatory interventions.
The report concludes that:
emergency response, which forms part of the emergency preparedness of an
installation, remains important to offshore health and safety and that it is
appropriate for interest in this subject to be continually revitalised;
emergency response systems must reflect the ability of an installation to
withstand an emergency, the risks from which are required to be demonstrated
ALARP under the safety case assessment and acceptance procedures and, in
particular, must reflect the performance standards of the accepted safety case
for mustering and the endurance times of egress routes and temporary
refuges, and for evacuation and escape.
emergency command capabilities of the offshore management team is at the
centre of the emergency response system, and can only be developed and
assessed using scenario based training and assessment techniques conducted
by expert organisations;
the OPITO Standard on emergency command sets the agreed approach to the
training and approved assessment of emergency command for the offshore
industry and that the Regulator should continue to work with OPITO on
reviewing the Standard and accreditation procedures;
the remainder of the emergency response system can be regulated following
the relevant statutory requirements, most of which appear in the Offshore
Installations Prevention of Fire end Explosion and Emergency Response
Regulations, the Pipelines Safety Regulations and the Offshore Installations
Safety Case Regulations. Ideas on how this might be done are included in the
1. Purpose of Report
2. Background to Emergency Response Systems
2.1. Purpose of Offshore Emergency Response Systems
2.2. Legal Requirements
2.3. The Piper Alpha Disaster
3. Emergency Preparedness
3.1. Overview
3.2. Characteristics of an Installation
3.3. Management of Emergency Response System
4. General Principles of Inspection and Audit
5. Inspection and Audit of Emergency Command Capabilities
5.1. Questions for the Regulator
6. Inspection and Audit of the Remainder of the Emergency
Response System
6.1. Emergency Response Plan
6.2. Detection of Incidents
6.3. Communication and Alarms
6.4. Mustering
6.5. Drills and Exercises
6.6. Information to Personnel-The Station Bill
6.7. Facilities Check List
7. Inspection and Audit of Emergency Response Hardware
7.1. General
7.2. Helideck Emergencies
7.3. Additional Background Information
8. Conclusions
page iii
page v
page 1
page 2
page 2
page 2
page 3
page 5
page 5
page 5
page 6
page 9
page 10
page 10
Appendix 1 – OPITO Emergency Response Standards
· Emergency Control Standard
· Standard for those having Specialist Responsibilities
· Standard for those having no Specialist Responsibilities
Appendix 2 – Arrangements in the Offshore Industry for Assessing
Emergency Command Capabilities
· Importance of Command Capabilities
· Coaching and Assessing Emergency Command Capabilities
Appendix 3 – Implementation of the OPITO Standard
· Principles of Scenario Based Assessments
· Selecting Scenarios
· Component Analysis
page 26
page 26
page 26
page 27
page 28
page 29
page 29
page 29
page 31
page 31
page 31
page 36
Annex A – Generic Check List for the Assessment of
Command Capabilities
Annex B – Components of Emergency Response Systems
Annex C – Overarching Emergency Response Prompt Sheet
Annex D – Typical Emergency Procedures Prompt Sheet
Annex E – Drills and Exercises Prompt Sheet
Annex F – Station Bill Prompt Sheet
page 38
page 46
page 48
page 49
page 50
page 51
page 13
page 19
page 19
page 20
page 21
page 21
page 22
page 23
page 23
page 24
page 24
page 25
Annex G - Generic Check List for the Inspection and Audit of
Emergency Response Hardware and Software
Annex H – Typical Emergency Response Facilities for Platform
Annex I – Facility Considerations During Emergencies
page 52
page 57
page 58
page 61
page 63
This report provides background information and practical help to the Regulator on the
inspection and audit of emergency response arrangements for offshore installations. Although a
matter for the Regulator, it is intended that the Report or parts of the Report should be used
mainly by specialist groups within the Offshore Division of HSE to devise guidance to
inspectors for use in general inspection and in targeted initiatives directed at emergency
response management.
Emergency response forms that part of the emergency preparedness of an offshore installation
that comes into play once an emergency has occurred and contributes to reducing risks to
ALARP. The other part of emergency preparedness relates to the characteristics of an
installation in respect of its ability to militate against initiating events, to detect potential and
actual emergency situations and to withstand an emergency should such an event occur and
which have to be demonstrated to be ALARP under the safety case assessment and acceptance
procedures. Although this report is concerned with the first of these parts, the characteristics
associated with the second influences the starting parameters and the performance standards that
have to be achieved by the emergency response arrangements.
For convenience of analysis and action, it is normal to consider the management of emergency
response under two headings. First, there are the overarching command and control capabilities
of those charged with the management of emergencies and, second there are all the other issues
of competence, hardware and external support arrangements that form vital parts of the system.
The report aims to address all of these matters but special attention is given to providing
information on how the Regulator might be involved in appraising the coaching and assessment
of emergency command capabilities by approved bodies to the OPITO Standard.
The report is for use by the Regulator but will be of interest to duty holders and those supplying
expert advice and assessment capabilities to the offshore industry. It has been prepared by Link
Associates International Ltd under contract to the Offshore Safety Division of the Health and
Safety Executive. It does not contain all the information and knowledge deployed by Link
Associates International Ltd when carrying out appraisal of emergency response capabilities of
offshore installations. Nor does it contain all the information required to successfully assess
every facet of an emergency response system since, in general, the knowledge, experience and
time resource required for undertaking such assessments would go beyond what the Regulator
might elect to support. But the report does aim to provide the Regulator with sufficient
information to enable judgements to be reached by inspectors on whether or not satisfactory
standards of emergency response are being achieved by offshore duty holders.
Although the report is aimed at the management of emergency response for offshore
installations in British waters, it is based on the worldwide in depth and diverse experiences of
the staff of Link Associates International in the fields of providing expert consultancy, training
and assessment services to a wide range of on shore and offshore industries.
The objective of the management of emergency response is to safeguard the health and safety of
persons on or near an installation in the event of an emergency. Such management systems
ensure that offshore installations are prepared for any emergency that might arise and help
contain and control such events to safeguard persons who might be affected and to minimise
damage. The systems form part of the ‘protection in depth’ philosophy applied to safeguarding
against risks to persons from activities associated with the exploration and production of sub-sea
Offshore emergency response systems are primarily aimed at dealing with the immediate
aftermath of a low frequency event that has either escalated or has the potential to escalate into a
major accident or environmental incident but such systems have relevance to other unexpected
events that might affect only one or a small number of persons, for example, a man overboard
situation. Emergency response systems are not concerned with control over initiating events and
are only concerned with the control over escalation to the extent that is necessary to facilitate
the evacuation, escape and rescue of persons. Other hazard management mechanisms forming
part of an installation’s safety management system deal with the management of risks falling
outside of the scope of emergency response systems. In short emergency response systems are
concerned with managing emergencies, not preventing emergencies from occurring.
Emergency response systems are addressed in the Offshore Installations (Safety Case)
Regulations (SCR), more specifically, in the Offshore Installations (Prevention of Fire and
Explosion, and Emergency Response) Regulations (PFEER), and in the Pipelines Safety
Regulations (PSR).
SCR requires duty holders to include in design and operational safety cases particulars relating
to the protection of persons for as long as they need to remain on an installation following an
emergency against the hazards of explosion, fire, heat, and toxic gas or fumes. These particulars
include the provision of temporary refuge, evacuation routes, the means of evacuation and
escape, and the facilities in the temporary refuge for monitoring and control of the incident and
for organising evacuation. In addition, there are requirements relating to the establishing
performance standards for the minimum period for which the provisions are to be effective
following an emergency and for a demonstration, using suitable and sufficient quantified risk
assessments that the risks are being controlled to the lowest level that is reasonably practicable.
Most of these considerations are outwith the scope of this report and will already have been
assessed by the Regulator as part of the safety case acceptance procedures. But the performance
standards for the capabilities of temporary refuges, escape routes, means of evacuation and
escape and the control and monitoring facilities are important inputs to the preparation of an
emergency response system that need to be taken into account.
PFEER also has requirements relating to the characteristics of an installation to prevent, detect
and withstand emergencies arising out of fire and explosion hazards. Again, these form part of
the overall emergency preparedness of an installation but mainly fall outside the scope of this
report. This report is concerned with those parts of PFEER that require duty holders to prepare
for emergencies by having a competent command structure, sufficient competent persons for
emergency duties, to provide adequate training and instruction, to have emergency response
plans, which are tested and practiced as often as appropriate, and the provision and maintenance
of emergency plant and equipment. These requirements embrace the concepts of critical
individuals being competent at command and control and the provision of adequate training,
including command training.
PSR applies both on shore and offshore and include provisions requiring operators of major
hazard pipelines to have in place emergency procedures and emergency plans. Pipelines and
emergency shut down valves connected to, and that are within 500 metres of an offshore
installation are deemed to be part of that installation. Therefore, there is overlap between
PFEER and PSR in respect of emergency response duties. But an installation duty holder and
pipeline operator for pipelines within the 500 metre zone are usually the same, and control over
pipeline emergency shut down valves, whether located on an installation or sub-sea within the
500 metre zone are installation controlled. The physical demarcation of responsibilities between
installation and pipeline duty holders is usually remote from the installation but this is not
always the case; for example, a loading pipeline for a floating storage vessel. Putting aside these
considerations of overlaps and the location of duty interfaces, it is indisputable that the fluid in
major hazard pipelines connects the emergency response system for an offshore installation to
that for any connected major hazard pipeline. This needs to be taken into account in the
respective emergency response plans, which need to be compatible and include communication
Notwithstanding these legal requirements, history shows that for all industries, as the length of
time from the last major accident increases so does the propensity to allow slippage to occur in
the importance afforded to the maintenance, development, testing and assessment of emergency
response systems. This is equally true for the offshore industry. In short, the temptation to be
simplistic and superficial in verifying emergency response systems may become the norm. This
is understandable as the offshore industry rightly moves its attention towards concentrating on
the elimination of disaster initiating events rather than on dealing with the consequences of an
escalating disaster scenario. But emergency response is too important to be neglected, both
aspects are equal imperatives. The time is right to heighten the interest of duty holders and the
regulator in ensuring progressive improvement in the well being of the emergency response
capabilities of offshore installations. This report aspires to stimulate this heightened interest.
It is worth briefly reflecting on what Lord Cullen stated in his report into the Piper Alpha
disaster. The immediate cause was a breakdown in the permit to work system. This led to the
use of machinery that was undergoing maintenance, which in turn caused the escape of
condensate from an insecurely fastened temporary blank flange. Thereafter, there was a series of
misjudgements that contributed heavily to the scale of the loss of life. Many of the men on
board were unfamiliar with the layout of the installation and had not been properly trained or
practised in emergency procedures. Those in the accommodation block were encouraged to stay
put by the Offshore Installation Manager [OIM] to await rescue. Yet, as the Cullen Report
makes clear, to remain there meant certain death.
Lord Cullen was critical of the OIM who died in the disaster, for not exercising effective
command as the disaster developed. It was argued that many of those lost could have been
saved if the OIM had been more decisive. However, Brian Appleton, one of the two technical
assessors who assisted Lord Cullen is on record as saying that he did not blame the OIM for
these failings since he had been given no training in emergency command and that the
installation emergency command capabilities had not been subject to realistic test, development
or assessment. This was a very telling observation, the effect of which appears to have been
diluted with the passage of time since the Piper Alpha disaster. There are many other examples
where decisions taken by management under pressure, time constraints and conditions of
isolation at the time of a developing disaster could, if taken more competently, have resulted in
much improved outcomes.
As a consequence of the concerns over emergency command capabilities, Lord Cullen
recommended that a duty holder’s formal emergency command organisation, together with the
criteria used for assessing the command ability of OIMs, should form part of the safety
management system for the installation, and that there should be a system of exercises that
provide opportunities to practice decision making in an emergency.
In addition, amongst other things, Lord Cullen recommended that duty holders should be
required to submit to the Regulator an evacuation, escape and rescue analysis for each
installation. These requirements are embodied in the Offshore Installations (Safety Case)
The emergency preparedness of an offshore installation is a combination two interdependent
factors. These are:
the characteristics of an installation that influence emergencies;
the pre-arranged emergency response system that becomes operative in the event of an
emergency and which deals with the management and the provision of plant and
equipment to facilitate the evacuation, escape, rescue and recovery of persons
following an emergency.
In respect of emergency preparedness, the characteristics of an offshore installation determine
the likelihood of an emergency arising, the existence and capability of systems to detect
emergencies, and the ability of an installation to withstand an emergency for the period of time
required to effect the evacuation and escape of all persons. Under the provisions of SCR, duty
holders submitting design and operational safety cases are required to demonstrate that all major
accident risks are being controlled to the lowest reasonably practicable level and are required to
include in design and operational safety cases, amongst other things, particulars of:
wells and well control arrangements;
connected pipelines and associated safety systems;
detection systems for flammable or toxic gases and fires;
plant and arrangements for the prevention and mitigation of fires;
the arrangements for protecting persons from explosions, fire, heat, smoke,
and toxic gas or fumes following an emergency until such time as they can be
evacuated or escape from the installation;
the provision of temporary refuge that remains effective for the period
following an incident until such time that persons can be evacuated;
safe escape routes to temporary refuges and from the refuges to the evacuation
safe means of evacuation;
means within the temporary refuge for the control and monitoring of an
emergency, and for organising evacuation.
In addition, SCR requires duty holders to establish performance standards for the arrangements
to protect persons against explosions, fire, heat, smoke, and toxic gases or fumes, and for
temporary refuges, escape routes, means of evacuation.
PFEER also has provisions on prevention of fire and explosion, detection of incidents and
mitigation of fire and explosion.
These characteristics of an installation are considered as part of the Regulator’s procedures for
assessing and accepting or otherwise safety cases and are not part of the emergency response
system for an installation since such systems come into play once an emergency has
commenced. However, the characteristics, and particularly the performance standards, are very
important parameters effecting the preparation of an emergency response plan. For example, the
muster times in an emergency response plan have to be compatible with the performance
standards for the endurance times of the escape routes; the evacuation and escape times from the
temporary refuge have to be compatible with the performance standards for the endurance time
of the temporary refuge; etc. In other words, the characteristics of an installation are relevant
inputs to the preparation of an emergency response system but the underlining analysis of the
worth or otherwise of these characteristics is outwith the scope of this report which is concerned
with the inspection and audit of the management of emergency response.
An emergency response system is the second part of the emergency preparedness of an offshore
installation. It is concerned with being prepared for the management of the situation and the
provision of plant and equipment to safeguard persons on or near an offshore installation once
an emergency has arisen. The main elements of an emergency response system for an offshore
installation are listed below.
Identification of Reasonably Foreseeable Emergencies. Prior to any emergency,
all reasonably foreseeable emergencies should have been identified but it should
always be remembered that the emergency system might well have to deal with a
situation that was not previously envisaged. The principle to be followed is that of
maximum preparedness for all reasonably foreseeable emergencies. This can be
best achieved by identifying reasonably foreseeable emergencies and then ensuring
that these are covered by the emergency plans, and by the emergency exercise and
drill programmes for the installation. The starting point for identifying possible
emergencies should be the risk assessment section of the safety case for the
installation and the assessment carried out in pursuance of Regulation 5 of PFEER.
Amongst other things, the latter requires duty holders to identify the events which
could give rise to the need for evacuation, escape or rescue, and requires
performance standards to be established for these measures. But risk and the need
for evacuation, escape or rescue should not be the only determinants of whether or
not a hazard is addressed in the emergency plan. The plan should address all
reasonably foreseeable emergencies including those of a low probability. There will
be some emergencies that fall outside of the five defined major accident categories
listed in the Offshore Installations (Safety Case) Regulations that also need to be
considered. These might include a helicopter ditching into the sea, a man overboard,
an incident on a neighbouring offshore installation, a major pollution incident etc.
The Emergency Response Plan. This details the organisation and arrangements for
handling any emergency including who does what and the procedures to be
followed in different circumstances. Guidance on the content of emergency
response plans can be found in the UKOOA publication ‘Guidelines for the
Management of Emergency Response for Offshore Installations’. This document
contains high-level guidance applicable to all circumstances. Understandably it
lacks practical details applicable to the varying offshore situations. It was finalised
after close consultation and involvement with the Regulator.
Arrangements for Monitoring the POB. Monitoring the POB and keeping the
personal details of all the persons on an offshore installation is a requirement of the
Offshore Installations (Management and Administration) Regulations.
Command Structure. The command structure should be clearly established and
should take into account the selection criteria, training and development of plans
and assessments for persons occupying emergency command and other critical
posts. This should cover the arrangements for persons to deputise in the event of the
unavailability of any critical post holder. The critical command and control posts
should include:
an on shore emergency support manager;
an offshore site main controller (the offshore installation
an offshore operations coordinator
installation manager or equivalent);
offshore fire team leaders/on site controllers;
an offshore muster coordinator;
offshore muster checkers.
deputy offshore
Competence of Personnel in Emergency Response. The role, leadership, training
and competence assurance arrangements for the emergency management team and
the emergency support teams such as the medical team, the fire fighting/emergency
response teams, the helideck team, the radio operator, the control room operator, the
lifeboat coxswains, the muster checkers, the muster coordinator etc should be
Incident Detection.
Duty holders should provide detection systems for
emergencies such as a fire and gas system; hydrogen sulphide monitoring; carbon
monoxide monitoring; loss of HVAC facilities; loss of power; an impending ship
collision, instructions to persons of reporting emergencies detected by the eye, nose
or ear such as hydrocarbon or other fluid releases, smoke, fire, a man overboard etc;
flare or vent stack irregularities; etc. PFEER Regulation 10 and the Schedules to
SCR dealing with the particulars to be included in design and operational safety
cases are relevant.
Raising the Alarm. The installation should be equipped with a general platform
alarm system and broadcast communication system complying with Regulation 11
Communication Systems. Communication systems including internal systems and
external marine and helicopter band radios, external satellite telephone system,
VHF radios, installation telephones, status lights etc, should be provided. PFEER
Regulation 11 is relevant.
Muster Arrangements. Regulation 14 of PFEER addresses mustering of persons.
These requirements are a central part of an emergency response system and not only
include accounting for all persons on an installation but also the very important
issues of the provision of safe muster areas, safe routes to these areas from working
places and the accommodation, and safe routes from the muster areas to the
evacuation points.
Once an emergency has been detected, a platform general alarm
sounded and all persons have commenced mustering, the emergency command
team have to collate all the available information to make a competent assessment
of the situation to facilitate and decide on the appropriate response.
Evacuation means leaving an installation without entering the sea.
Safe evacuation, as far as is reasonably practicable, is a requirement of Regulation
15 of PFEER. The associated approved code of practice states that preferred means
of evacuation should be the normal means of getting persons to and from an
installation. This would usually be by helicopter. In addition, an alternative means
should be provided which would normally be by a TEMPSC. But in certain
circumstances it might not be reasonably practicable to provide two methods of
evacuation, for example, on small normally unattended installations where the risks
in providing and maintaining a TEMPSC would outweigh the risks of not providing
a TEMPSC or for divers in hyperbaric chambers.
Escape. Regulation 16 of PFEER addresses means of escape. Means of escape is
the method of leaving an installation when the evacuation systems have failed.
Escape systems include hardware such as escape routes, life rafts, escape systems to
the sea, immersion suits and other personal protective equipment usually associated
with a grab bag etc.
Rescue and Recovery. Rescue and recovery are addressed in Regulation 17 of
PFEER. For persons who are evacuated or who escape to the sea from an
installation or who are near an installation, the emergency response system must
provide a good prospect of recovery, rescue and being taken to a place of safety.
Familiarisation. All persons on an offshore installation must be familiar with the
emergency arrangements and of what would be expected of them should an
emergency arise.
Exercises and Drills. All persons on an offshore installation should be provided
with sufficient emergency response training and assessment proportional to their
emergency responsibilities. These arrangements should include familiarisation
exercises, drills and professionally organised scenario based testing and
performance assessment of the whole emergency response system.
These elements are shown in a functional form at Annex B (page 46). Examples of the hardware
and software associated with each main functional component are included.
Inspection and audit are ubiquitous words that are used in many different contexts. In respect of
regulatory interventions, over a period of time particular meanings have been accepted for these
words and it is these meanings that are being explained in this Chapter.
Neither inspection nor audit represents complete coverage of the situation or activities being
appraised. Both are sampling techniques aimed at gaining an overall impression of the
acceptability or otherwise of whatever is being scrutinised. Audit is more thorough, focused and
time consuming than inspection. Regulatory inspection and audit is an activity carried out on
behalf of society and other more direct stakeholders to assess and influence standards of health,
safety and welfare, and to take proportional enforcement action if legal contraventions are
discovered. In the field of emergency preparedness, regulatory inspection and audit is different
to the activities undertaken by duty holders to ensure that their emergency response capabilities
meet their legal duties and company policies.
But there is a distinction to be made between regulatory inspection and audit. Inspection is a
more limited exercise than audit. It involves an informed person, but not necessarily a specialist,
taking a relatively limited look at a situation and then using the outcomes to determine whether
or not there is sufficient concern to warrant a more detailed look at any of the hardware or
activities that has been the subject of the inspection. Although the worth of the systems being
inspected would be considered, there would be a distinct tendency towards testing that the
systems were properly understood and competently implemented. Whereas for auditing the
approach would be more systematic, would be conducted with increased resources and expertise
and would question the value of the systems as well as witnessing the end to end application of
the system. But there is no clear point where inspection stops and auditing starts.
The legal basis for inspection or audit of the command capabilities of offshore installation
management teams lies in Regulation 6 of PFEER. In paraphrase, this requires duty holders to
prepare for emergencies by ensuring:
competent offshore emergency command;
sufficient competent persons offshore to deal with any emergency;
for manned installations, a helicopter landing officer and helideck crew;
the names of the persons fulfilling the above tasks to be posted at suitable
locations on the installation;
the provision of adequate training for every person on the action to take in
an emergency, and access for every person to information on emergency
In relation to the emergency command capabilities of offshore management teams, regulatory
inspectors should pursue three direct lines of inquiry.
First, questions should be asked about the policy of the duty holder towards ensuring emergency
command competencies of its offshore management teams. Inspectors should verify that the
offshore installation managers and deputies have successfully attended OPITO approved
offshore installation managers’ emergency command training and assessment courses with the
appropriate endorsements for the installation concerned. If the answer to these questions were to
indicate that some or all of the installation managers or deputies have not been trained and
successfully assessed then this would appear to be a contravention of Regulation 6 of PFEER.
OPITO has been appointed by the Government to be the National Training Organisation for the
upstream petroleum industry and, amongst other things, sets the training standards and
arrangements for offshore emergency response. More information on the role of OPITO appears
in Appendices 1, 2 and 3 of this Report (pages 26 to 37).
Second, questions should be asked about how long ago was the training and assessment
undertaken and about the duty holders policy on the frequency of refresher training. If the
answer to these questions indicate that refresher training has not been undertaken within three
years of the last emergency command and control training then this, although more
judgemental, also could be viewed as contravening Regulation 6 of PFEER. The importance of
offshore installation managers and their deputies periodically practicing and progressively
improving their command and control skills cannot be over emphasised. Without the use of
professionally run and assessed emergency exercises based on realistic scenarios, coupled with
appropriate coaching, it is the view of Link Associates International that there cannot be any
confidence in the ability to cope in the event of a real emergency. Simplistic drills should be run
on a regular basis. They are a useful means of keeping offshore personnel familiar with some
aspects of the emergency procedures but are no substitute for the periodic testing and
enhancement of the command capabilities of the management. A reasonable frequency for this
in depth practising of the command system would be once every three years.
Third, questions should be asked of duty holders to test whether or not they are setting the
approved assessment of command capabilities in the wider context of selecting suitable persons
for offshore management posts. The ability to exercise command in emergencies is an important
attribute for an offshore installation manager but there are also other essential health and safety
requirements. These include offshore experience, career profile, track record in engineering
management, technical qualifications, maturity and knowledge of the installation. Inspectors
should pursue the familiarity of the offshore emergency management team with the layout of the
installation, the characteristics of the wells and process plant, the emergency response
procedures and hardware, the capabilities of the emergency support teams etc. For example,
what happens to the process plant in the event of any one of the various levels of process plant
trips occurring; what happens to the hydrocarbon inventories in the various sets of
circumstances. This is a highly judgemental area for the Regulator and care needs to be taken
not to reach firm conclusions on weak evidence.
During routine offshore visits or as part of a campaign, inspectors should show an interest in
emergency command competencies and the experience of offshore installation managers and
their deputies when undertaking command training and assessment. Enquiries could be made
into how confident such individuals are of their ability to react satisfactorily. Undoubtedly this
would stimulate a wider discussion that in turn would reinforce the demonstration of the
Regulator’s interest in emergency preparedness.
Inspectors would be wise to avoid the temptation to get directly involved in reaching
judgements on the quality of the emergency command training and assessment provided to
individuals by an OPITO approved body. It should be sufficient to know that the approved
arrangements have been followed. OPITO has its own mechanism for ensuring that
organisations that have been approved maintain standards of training and assessment and is
itself is subject to periodic Government assessments in order to retain its National Training
Organisation this status.
But it would be valuable and influential for inspectors and more senior managers from the
Regulatory body to demonstrate support for this process by, from time to time, witnessing
emergency command training and assessment taking place, either on site or at a simulator. Apart
from the specialist knowledge and skills required to assess scenario based command training
and assessment that are already in place, arrangements to ensure the quality of this training and
assessment, the amount of time and other resources that would be involved for the Regulator,
would be prohibitive if it were to engage in a meaningful way with this work. Typically it takes
around five days to complete a training and assessment course.
Notwithstanding the recommendation for caution above in respect of inspectors getting involved
in inspecting scenario based command assessments for offshore installations, managers and
their deputies and inspectors should be aware of the techniques and assessment criteria used in
these processes. They would then be able to enter into wider conversations and be able to set the
approved training and assessment in context from a standpoint of knowledge. Amongst other
things, the assessment process for offshore installation managers and their deputies addresses
the question of leadership skills. Inspectors should talk about the issues surrounding leadership
without being too authoritative. The two most common leadership patterns are first, the
autocratic leader where there is propensity to centralise authority and rely on command and
coercive power to control subordinates, and second, democratic leadership where authority but
not responsibility is delegated to others, participation in decision making is encouraged and
leadership skills play a big part in maintaining the power to give influence to subordinates and
others. Of course, in reality there is a blurring between the two styles of leadership and in one
organisation it is sensible to change from one to the other according to the situation being
addressed. For example, on an offshore installation the democratic style would be best suited for
every day management but for an emergency situation, the command and control ethos of the
autocratic style will have some part to play.
But the most fruitful line of influence for the Regulator in the detail of emergency command is
through the OPITO standard making and associated approval processes. This is what actually
happens at the moment. Through this route, combined with regulatory action to ensure that the
Standard and approved assessments are being used and applied by offshore installation duty
holders, it should be possible for the Regulator to exert maximum influence on offshore
emergency command capabilities. For example, if the Regulator were to be of the view that the
present approved standard ‘OIM Controlling Emergencies’ and the associated approval process
is in need of revision, partly to incorporate the concepts of component assessment etc referred to
in Appendix 3 (page 31) of this Report, then the Regulator should raise this matter through its
representative on the OPITO training Standards Committee.
Information on OPITO Emergency Response Standards, the arrangements for assessing
emergency command capabilities in the offshore industry and the use of scenario based training
and assessment for offshore managers is given in Appendix 1 to 3 of this Report (pages 26 to
37). A generic check list for the assessment of offshore command capabilities appears in
Annex A (page 38).
The non-command aspects of Regulation 6 of PFEER are dealt with in Chapter 7 of this report
(page 23).
6.1.1. Meaning of an Emergency Response Plan
When inspecting the remainder of an emergency response system for an offshore installation,
the natural starting point is the emergency response plan. Regulation 8 of PFEER effectively
defines the emergency response plan as a document setting out the organisation, arrangements
and procedures for use in an emergency. This is a narrower definition than might be expected.
The plan has to be prepared in consultation with all who are likely to be involved in its
implementation, including persons external to the installation such as the Coastguard, and to
give guidance on the organisation and arrangements, and the procedures to be followed in the
event of an emergency. Regulation 8 also requires the plan to be made available to all persons
on an installation and that those who are required to assist in its implementation are informed of
the content of the plan that is relevant to them. And finally, Regulation 8 requires that the
organisation, arrangements and procedures forming the plan be tested as often as is appropriate.
This will be referred to later.
6.1.2. Relationship between the Emergency Response Plan and the Safety Case
A major input to the preparation of an emergency response plan should be the characteristics of
an installation in relation to the ability to be able prevent, detect and to withstand an emergency.
These issues are required to be addressed in the design or operational safety case for an
installation and are considered by the Regulator as part of the safety case assessment and
acceptance procedures.
Safety cases are required to demonstrate that all major accident risks are being controlled to the
lowest reasonably practicable level and are required to contain performance standards for the
measures taken to safeguard persons against explosions, fires, heat, smoke and toxic gases or
fumes. In addition, performance standards are required for temporary refuges, egress routes to
temporary refuges and from temporary refuges to the evacuation or escape points, the means of
evacuation or escape, and the facilities in temporary refuges for monitoring and control of
emergencies and for organising evacuation and escape. Clearly, these performance standards set
the standards that must be achieved by the emergency response plan for the mustering,
evacuation and escape. Inspectors should look for strong links between installation safety cases
and emergency response plans. Inspectors should compare safety case endurance times for
escape routes and temporary refuges and the times for muster, evacuation and escape with what
appears in the emergency response plan and, where appropriate, with the achievements in drills
and exercises. Any discrepancies in which the emergency response plan or the outcomes of
drills or exercises exceeds the safety case performance standards should be pursued.
6.1.3. Structure of the Emergency Response Plan
The structure of an emergency response plan will reflect the type of installation and the range of
hazards. There is no one correct structure but whatever structure is adopted, the result should
provide a concise source of information that would be readily accessible and retrievable in the
event of an emergency. A typical structure for a large production installation would be an over
arching document dealing with the detection of an emergency, communicating the emergency to
all persons offshore, the mustering arrangements and the on going management of the
emergency. This over arching plan would be supported by a second tier of documentation would
deal with the plan and procedures for dealing with the different types of reasonably foreseeable
6.1.4. Consultation on the Emergency Response Plan
Regulation 8 of PFEER, amongst other things, requires a duty holder to consult on the
emergency response plan with persons who are likely to be involved in responding to an
emergency. This effectively means consultation with every person on an installation and with
those external to the installation that might be involved in providing assistance in the event of
an emergency. These would include, as appropriate, HM Coastguard, helicopter provider,
standby vessel provider, supply boat provider, operators of any connected pipelines,
neighbouring installations, on shore medical services, police etc.
6.1.5. Behavioural Issues
The success or otherwise of involving people in a consultation exercise on emergency response
is dependent on the safety culture on the installation. Inspectors should consider the safety
culture that exists on the installation with a view to assessing if this is conducive to the total
ownership of the emergency response system by all persons offshore. Culture is difficult to
define but it embraces such issues as organisational structure, the degrees of recognition given
to each level of management or individuals, the values and respect attached to individuals, the
degree of reliance on individual competencies and motivations, whether or not an organisation
is an open and listening organisation, etc. All of these factors have influence on health and
safety in the workplace but are particularly relevant in the event of an emergency.
Closely linked to the cultural issue is the extent of team working on an installation. There are
four main reasons for promoting team work, all of which align well with the natural human trait
of feeling comfortable when brigaded together rather than standing alone. First, a group
approach is necessary because of the complexity of the problems being faced that require a
range of knowledge and skills wider than that possessed by any individual and a level of activity
that goes beyond that of an individual. Second, a high degree of cooperation is required over
interrelated and overlapping tasks. Third, each member of the team will develop ownership of
the whole and will be better placed to assess the impact of narrow contributions and decision on
the well being of the whole. Fourth, the mutual support that arises out of teamwork achieves a
sense of belonging that enables the team to achieve much more than would be possible from a
summation of the individual efforts and is of particular relevance to the offshore industry where
the workforce lives remote from home and away from the normal social support systems. These
factors are important at all times but are vital in the event of an emergency. Inspectors should
talk around these issues when offshore and attempt to reach judgements on the degree and
success of team working on the installation. Feedback to duty holders and the offshore
workforce should be given in a manner that encourages and strengthens teamwork.
6.1.6. Main Elements of an Emergency Plan
The main elements of a plan are listed below. However, it should be remembered that
Regulation 8 of PFEER and the associated ACOP, both of which deal with emergency response
plans, are drafted in very general terms and that it would therefore be wrong to conclude that an
omission from the list automatically meant that the installation concerned was in contravention
of the law. The principle of proportionality needs to be applied since there may be a very good
reason for an installation not addressing the whole of the list. Inspectors should look at the
installation emergency response plan to see if there are any omissions.
Give an emergency response philosophy.
Take account of the installation safety case including the performance
standards that define the starting point for the emergency response system
and that establish the endurance, evacuation, escape and rescue times that
the emergency response system must meet.
Define roles and responsibilities of personnel.
Provide clear directives.
Identify and detail specific emergency procedures.
Provide a definition of a major incident.
Describe the communication facilities.
Describe the emergency response organisation.
Describe the mustering arrangements.
Detail the reporting and notification requirements.
List the emergency facilities.
Contain an emergency contact list.
Contain proformas for emergency public address announcements.
Meet the relevant legislative requirements.
State the arrangements for making all offshore personnel familiar with the
part of the plan relevant to them.
Specify the type and frequency of the training, tests, and practises
necessary to ensure and maintain competence.
Describe the mechanisms for judging the results of tests and practises
against performance standards and for taking action to address any
6.1.7. Command Structure
Offshore installations come in a variety of types, shapes and sizes covering small fixed normally
unattended production installations, large attended fixed production installations, floating
production installations, floating storage units, jack up drilling installations, jack up
accommodation installations, semi-sub drilling installations etc. Notwithstanding the wide
variations in the hazards associated with the different types of installations and the wide
variation in the management structures and number of persons typically on an installation type,
the emergency organisation should contain a command structure that embraces the following
Emergency support manager. This is an on shore post. The post holder has to be
available for 24 hours each day on every day. The person or persons involved
should be sufficiently familiar with offshore hazards and activities, and have the
necessary authority within the duty holder’s structure to carry out these functions.
At the time of an emergency, the remoteness of this person from the scene of the
emergency limits immediate involvement. But this person should act to reduce the
communication load on the offshore emergency command team and should provide
a coordinating role with the Coastguard, helicopter operators, standby ship and
supply ship companies operating in the area, companies operating neighbouring
installations, with the police, the Regulator, the media, the relatives of persons
working offshore, etc. Support for this person would come from the wider technical
and managerial capabilities within the duty holder’s structure and, if appropriate,
from outside of the duty holder.
Inspectors should determine the identity of the emergency support managers and the
arrangements that that have been made to fulfil the roles described above. The
emergency response system for a particular installation will be set out in some
detail in the safety case. Inspectors should familiarise themselves with the relevant
part of the safety case and then enquire of the general approach to emergency
response being followed by the duty holder. Any discrepancies with the safety case
should be pursued. These enquiries should extend to the competency of the
management team, those having specialist emergency response duties, and all
offshore personnel in respect of dealing with emergencies. From the narrow
standpoint of the Regulator, one of the roles of the emergency support manager
would be to oversee the arrangements for making the statutory notifications of
reportable accidents, dangerous occurrences and reportable incidents of ill health
and enquiries should be made about these arrangements. Inspectors should satisfy
themselves that these arrangements are workable.
Offshore Installation Manager or Site Main Controller. This is the person in
overall command in the event of an emergency arising and is the leader of the
offshore emergency team. It is this person that directs the management of the
emergency but the situation can be more complicated when combined operations
are taking place when there will be two offshore installation managers. In this case
the nature of the incident will dictate which manager takes command. For example,
for a combined operation between a drilling installation and a production
installation, the manager of the drill rig would take command for a well control
incident involving the well being worked; for a production incident, the manager of
the production installation would take command. But there will be envisaged
emergencies where natural divisions of responsibility are much more blurred. There
should be a clear written understanding between the parties on these matters. Where
there is a Combined Operations Safety Case, this should address the division of
responsibilities although detail might be in a separate reference.
The site main controller leads the offshore emergency management team and is
responsible for making initial and ongoing assessments, taking an overview of the
emergency and how it might develop, managing the flow of information, making
decisions in consultation with others, directing activities, directing the use of the
resources, supporting the leaders of the emergency specialist teams, communicating
with all the offshore personnel, communicating and liaison with external bodies,
and providing the emergency support manager with sufficient information. One of
the early tasks is establishing the status of the escape routes.
Inspectors should enquire of designated site main controllers to test whether or not
they are clear about their roles, how they would undertake their duties in the event
of an emergency and, in the case of combined operations, are the two managers
involved clear about the scope of their respective responsibilities in the event of an
emergency arising.
Inspectors should also enquire when the persons involved last undertook OPITO
approved training and assessment for emergency command.
Deputy Offshore Installation Manager or Equivalent or Operations
Coordinator. On a drilling installation the equivalent person might be the Barge
Master or Senior Tool Pusher. On a floating production or storage unit the
equivalent might be the Chief Mate. This person assists in managing an emergency
and should be capable of acting as the site main controller in the event of the
installation manager not being available for whatever reason. This person will form
the main communication link between the fire team leader/on site controller and the
emergency management team. The role needs to be undertaken by a technically
competent person capable of précising complex issues into simple language and
knowing the source of additional technical information should that be required
either by the emergency management team or the fire team leader/emergency
response on site controller.
Inspectors should enquire of designated operations coordinators whether or not they
are clear about their roles, how they handle information overload, whether they
would be comfortable operating as the site main controller in the event of the
installation manager not being available etc.
Again, inspectors should also enquire when the operations coordinators last
undertook OPITO approved training and assessment in emergency command.
Fire Team/Emergency Response Team Leader or Site Incident Controller.
This is the person who takes charge at the actual site of an emergency and is
responsible for directing the use of resources at the site. The person should have an
in date certificate for having successfully attended an OPITO approved fire team
leader training and assessment course. Inspectors should verify this.
One of the critical areas of competence for fire team/emergency response team
leaders is that of understanding the limiting parameters applicable to the safe use of
breathing apparatus for either fire fighting or entering confined spaces. Such
persons should know how to operate a time based control system for persons
wearing breathing apparatus. In addition, they should have a good knowledge of the
hazards of the installation.
Muster Coordinator. This person is responsible to the site main controller for the
checking and recording of the headcount on the installation following the sounding
of a general platform alarm. There should be an accurate list of person on board
available to the muster coordinator so that discrepancies can be identified. This
person will monitor the movement of personnel and casualties as the emergency
develops and should meet the OPITO Competence Standard for a muster
Muster Checkers. These persons will be designated to the pre-arranged muster
points around the installation and will check and record the presence of persons at
the allocated muster point. The information will then be forwarded by one of the
installation’s communication systems to the muster coordinator. Regulation 14 of
PFEER requires that each person on an installation is assigned to a muster area and
that there is an up to date muster list held at each muster area. Inspectors should
enquire to see that the designated muster checkers properly understand these duties
and that they do not conflict with any other emergency duties. Persons undertaking
these roles should meet to OPITO Competence Standard for muster checkers.
6.1.8. Persons having Specialist Emergency Response Duties
In addition to the above formal appointments that are common to most emergency response
plans, whether for offshore installations or otherwise, there are a number of other key
emergency posts for an offshore installation. These are as follows, the competencies for which
are all covered, except for the medic, by OPITO approved training and assessment courses. In
the case of an offshore medic, a training and assessment course approved by the Health and
Safety Executive has to be successfully taken.
Lifeboat coxswain.
Radio operator.
Offshore medic.
Control room operator.
Helicopter landing officer.
Fire/emergency response team member.
Inspectors should discuss with duty holders these roles, paying particular attention to the
competency and physical capabilities of the persons involved, and whether or not there are any
conflicts between the emergency roles that they are expected to perform. For example, fire team
members should be physically capable of negotiating ladders and obstacles when wearing
breathing apparatus; with the reductions that have occurred in the number of persons working
on an offshore installation, it is possible for a person to be allocated two emergency tasks that
might, in some circumstances, be required to be undertaken simultaneously. This is not
6.1.9. Persons having no Specialist Emergency Response Duties
Persons falling within this category, in the event of an emergency, are mainly concerned with
their own personal safety, evacuation and escape. With the exception of occasional visitor, these
persons should hold current certificates to show that they have successfully attended an OPITO
approved Basic Offshore Induction and Emergency Training Course. In addition, all persons
should received adequate instruction and training on the layout, safety system and emergency
response system for the particular installation. Information should be provided on the location
of personal protective equipment for use in emergencies and life-saving appliances. PFEER
Regulations 6, 8 and 21 refer. Inspectors should satisfy themselves that duty holders are meeting
these requirements to a satisfactory standard.
6.1.10. Emergency Procedures
The emergency response procedures should align with the structure of the emergency response
plan referred to paragraph 6.3. There should be an over arching procedure that directs the work
of the emergency command team supported by individual procedures linked to the identified
hazards. A list of the issues that should be addressed in the overarching procedures is at Annex
C (page 48). For the individual procedures, the hazards would arise out of the safety case and or
from any other reasonably foreseeable event that falls out of the major accident definitions in
the Offshore Safety Case Regulations but nonetheless would still be an emergency requiring a
response as required by PFEER.
Procedures for dealing with emergencies need to be codified and set out in a user friendly
manner such as a flow diagram. They should cover what is expected to happen from the initial
detection of a potential emergency situation through to the ultimate conclusion of casualties
being transported to a place of safety, any evacuations completed and the installation has
returned to a stable state.
A typical list of emergencies to be addressed by the emergency response procedures is at
Annex D (page 49).
Inspectors should be reasonably familiar with most of the procedures since those dealing with
major accidents will be set out in the installation safety case. Inspectors should check to see that
the emergency management team on an offshore installation are familiar with the emergency
procedures and that all offshore personnel are familiar with those parts of the procedures that
affect them.
Regulation 10 of PFEER requires detection and control room alarm systems to be provided for
fire, accumulations of flammable or toxic gases, and leakages of flammable liquids. These
issues are all linked to major accident risks and so will be addressed in the installation safety
case. Nevertheless, inspectors should make enquiries about these systems. In particular,
consideration should be given to what actions are taken following the detection of a leak and
who makes the decision on what action to take, what happens when part of a detection system is
not available for use, what controls are exercised over apparent spurious outputs, how are the
calibration intervals decided, are the results of the pre-calibration tests recorded so that an
informed view can be reached on the appropriateness of the maintenance intervals etc? In
addition, from time to time the assistance of specialist inspectors should be sought on such
matters as reliability of the detection systems, dispersion patterns for the fluids being detected,
and the use of novel techniques in special circumstances.
Regulation 11 of PFEER, in paraphrase, requires
a system for giving an audible and, where necessary, a visual alarm in the
event of an emergency in accordance with a prescribed pattern of signals;
systems to allow communications between persons on the installation,
between the installation and the standby vessel, any supply boat, any
interconnected neighbouring installation whether the connection be by a
bridge link or a pipeline, and between the installation and the Coastguard, the
on shore emergency centre, the on shore medical support centre etc.
All installations are equipped with alarm systems and both internal and external communication
systems. But it is possible that the alarm system and internal communication systems might not
be universally effective at all places on an offshore installation. Inspectors should look for and
make enquiries to see if there are any serious black spots. If serious black spots do exist then
appropriate action should be taken.
Inspectors should also pursue the human factor and behavioural aspects of communications.
Effective communications are vital to health and safety performance in general as well as in
emergency situations, and are a wider issue than the provision of effective and reliable
hardware. It should always be recognised that upward and horizontal communications are just
as important as downward communications. Failures are often not related to hardware
shortcomings but to either a lack of clarity in the message or a misunderstanding by the
recipient. Such factors as disbelief in the information being passed, failure to give sufficient
attention to the information, information being couched in terms that disturb the sensitivities of
recipients and recipients allowing themselves to be over sensitive to the tenor of information
rather than concentrating on its content, all contribute to communication failures.
In addition, communication barriers can result from either individual shortcomings or from
failures in the organisational systems. Individual shortcomings can arise from the use of poor
semantics and syntax, confusion over the messages being transmitted, interpersonal emotions,
preconceived perceptions about what is in messages without fully examining the content,
assuming more knowledge and competence than actually exists within the other communicating
parties etc. Organisational barriers can arise from status and power differences, a reluctance to
pass on bad news, departmental boundaries and parochial considerations causing messages to be
misinterpreted, structural shortcomings in the communication networks, the absence of formal
communication channels etc.
Also, the experiences of past relationships can have a strong influence on the success or
otherwise of the communication link. If not handled in a positive way by the parties concerned
this can have a highly detrimental effect. Distrust must be banished and care exercised in the
choice of words and in demonstrating listening skills. Communication barriers can be seen at
two levels. Similar to an iceberg there is the obvious skill level associated with communication.
But the great mass of the iceberg cannot be seen. This represents the subliminal barriers to
communication of attitude, behaviour, motivation etc. To make lasting improvements both
levels need to be given constant attention.
Two overriding considerations for effective communications are the attitude and behaviour of
the parties involved. Unless there is a conscious attempt to clear the system of bias and
preconceived ideas and for all parties to start from a common point of reference, then there will
always be scope for misunderstandings. In addition to the above, active listening skills are vital
to the communication process.
Regulation 14 of PFEER lays down requirements on mustering. The parts that are of direct
relevance to the management of an emergency require that each person is assigned to a muster
area, that at each muster area there is displayed an up to date list of names of the persons
assigned to that area, and that there are procedures for mustering and accounting for all persons
on an installation.
The mustering system comprises of local muster checkers at the designated muster station and a
central muster coordinator. When an emergency alarm sounds, persons offshore report to their
muster stations where the appropriate muster checker marks them present on the local muster
list. Then each muster checker communicates with the muster coordinator and passes over the
head count for the particular area. Once the muster coordinator has received all the reports, a
total head count is prepared which, if no one is missing, should align with the POB. This sounds
a simple arithmetic task. But it is not. Experience shows that errors often occur. It is usual for a
muster drill to be programmed for each offshore duty tour. Inspectors should witness any such
drills that take place when they are offshore. More crucially, they should enquire about how
often muster drills are being conducted and how quickly the muster takes. These times should
be compared with the performance standard in the safety case. Inspector should also compare
the POB with the maximum declared in the safety case for the installation. If the actual POB
should exceed this maximum then this should be pursued.
But the requirements of Regulation 14 of PREER are wider than accounting for all persons on
an installation in the event of an emergency. They extend to the provision of safe muster areas,
safe routes from the muster areas to the evacuation and escape points, and safe means of egress
from working places and the accommodation to the muster areas. This last requirement needs
special attention since it can involve the provision of equipment such as emergency breathing
apparatus, smoke hoods, torches, heat resistant gloves etc.
It is a requirement of Regulations 6 and 8 of PFEER for training to be provided and tests to be
conducted on the emergency response system. Although the primary purpose of routine drills
and exercises is to meet these legal requirements and to maintain familiarity and competence,
they can also be used as part of the duty holders own audit systems. Regular drills should be
designed to test specified facilities and parts of the system. All parties that would be involved in
a real emergency falling within the scope of the drill or exercise should be involved. This could
embrace organisations external to the installation such as neighbouring installations, the standby
vessel, any supply boat that might be in the area, the operator of any pipeline that might be
connected to the installation, the Coastguard, the on shore emergency support manager, etc.
Typical topics to be covered in a programme of drills and exercises are at Annex E (page 50).
Inspectors should show an interest in the scheduling of drills and, whenever possible, observe
them taking place. A good starting point would be to enquire if any drills were planned and then
to seek to be excluded from the drill so as to be better placed to observe as many facets of the
drill as possible. But inspectors should be cautious not to interfere in a manner that might
increase risks, and not to underwrite the quality of the performance in response to a drill or
exercise. The results of drills should be retained on the installation and comparisons made with
the performance standards in the safety case. Inspectors should pursue serious discrepancies. A
list of points to consider when judging the outcome of drills and exercises is at Annex E
(page 50).
Records should be maintained of the routine drills and exercises conducted and of any lessons
learnt. Feedback from the debriefing sessions held following a drill or exercise should be
inputted into the review procedures for the emergency response system. Inspectors should make
enquiries to ensure that the review process for drills and exercises functions to produce
progressive improvements in performance and in a manner that gives life to any lessons learnt.
The usual way of informing persons on offshore installations about the emergency response
plan is through the inductions that take place when a person visits an installation for the first
time, and using the Station Bill, copies of which are strategically placed around the installation.
The induction should cover alarms, muster points, means of escape, use of lifeboats, the
provision and use of personal protective equipment, man overboard procedures, dealing with
fires, stopping work in the event of an emergency etc. Particular instruction and training should
be included for special items of equipment such as hydrogen sulphide escape breathing
apparatus sets, special escape systems for reaching the sea or any other installation specific
systems. With the reduction in time spent on basic offshore safety training courses, it is
important that the offshore inductions are properly executed. It was the trade off between
general safety training provided on the basic offshore training courses and the installation
specific training that led to the time spent on the basic courses being reduced. Against this
background, inspectors should consider whether or not the offshore induction training is
sufficient to allow persons to act correctly in an emergency.
The Station Bill for an offshore installation sets out in the form of a poster the emergency
instructions for all offshore personnel. Copies are displayed at appropriate places around the
installation including at the muster points, the heli-admin area, and the dining area.
Inspectors should consider whether or not the Station Bill contains sufficient information, the
manner in which the information is displayed and the location and number of sites at which the
Station Bill is displayed. There is no direct legal requirement covering the use of the Station
Bill. However, Regulation 8 of PFEER lays down that every person on an installation should be
provided with adequate instruction and training in what action to take in the event of an
emergency, and that the emergency response plan should be available to all persons on an
installation. For persons not having any specialist emergency response duties, the Station Bill
coupled with the instruction and training provided in a normal induction process would appear
to meet this requirement and inspectors should take this into account.
An example of the information that should appear on a Station Bill is at Annex F of this Report
(page 51).
A generic check list for helping with the inspection of the non-emergency command aspects of
the emergency response system is at Annex G of this Report (page 52).
A number of systems and arrangements are available on installations that together provide the
facilities and procedures necessary for emergency response. So far the control and command
aspects of EER have been discussed, for example people and plans. But the implementation of
these relies on the use of hardware such as equipment and facilities designed to cope with all
foreseeable incidents. These hardware aspects of EER range from structural arrangements
(passive fire protection, deluge systems, design of the installation etc) to small items of
equipment (personal survival equipment, communication facilities, etc). Together, the control
and command arrangements and the hardware should be sufficiently robust to ensure effective
emergency response on offshore installations.
The facilities identified as having a role in the response to an emergency should be operational
and usable by participants. Furthermore, operation and usage should be demonstrable.
Legislation requires that where equipment is safety critical, as defined in the amended Offshore
Safety Case Regulations, it must be subject to verification arrangements under Regulation 15A
of those Regulations. Plant and equipment on offshore installations provided to comply with
PFEER may also be subject to the Provision and Use of Work Equipment Regulations
(PUWER) 1998. Where equipment is of a personal nature, it is subject to the Personal
Protective Equipment at Work Regulations (PPEWR) 1992.
Regulation 19 of PFEER requires duty holders to ensure that plant, other than personal
protective equipment for use in an emergency, provided in compliance of PFEER is:
suitable for its purpose and is maintained in an efficient state;
subject to a suitable written scheme of systematic examination by an
independent competent person, which should specify the nature and
frequency of examinations and where appropriate provide for an
examination to be carried out prior to equipment being made available for
use or after modification or repair.
In broad terms, the plant covered by Regulation 19 is provided for the purposes of:
ensuring safe processing;
preventing uncontrolled releases of flammable substances;
preventing ignitions of flammable substances;
mitigating the effects of fire or explosion;
detecting fire or the accumulation of flammable or toxic gases;
communications and the control of emergencies;
means of evacuation;
means of escape;
life saving appliances.
Notwithstanding that every item in the above list could have relevance to an emergency
situation, the list is wider than the plant that would be used in direct response to an emergency.
Therefore, for the purpose of this report, consideration of plant will be limited to that that is
provided in direct support of persons on an installation faced with an emergency. A typical list
of such emergency response hardware facilities for an offshore installation is provided in Annex
H (page 57). It should also be remembered that Regulation 6 of PFEER requires written
information to be available on the use of emergency plant.
An example of industry standards and guidelines that inspectors should take into account would
be the UKOOA Guidelines for the Management of Emergency Response for Offshore
Installations (1995), which states alternative evacuation provisions such as TEMPSC should be
easy to deploy, reliable in launch, give protection against hazards such as fire and smoke, be
able to move away quickly from the installation and, where it is reasonably practicable, should
be oriented away from the installation on completion of launch.
Inspectors should check for compliance with Regulation 7 of PFEER by seeing whether or not
there is suitable and sufficient mechanical cutting, levering, and tugging equipment available in
the vicinity of helidecks to facilitate the release of any persons that might be trapped in the
event of a helicopter incident on or in the vicinity of a helideck. There should be available an
inventory of the equipment provided for this purpose and inspectors should enquire about
evidence to show that the equipment is being periodically checked and maintained. The
equipment should be suitably housed at a location in the vicinity of the helideck but not so close
that its accessibility might be compromised by a helideck incident.
Annex I (page 58) shows the relationship between the components of an emergency response
system, the issues linked to the individual components and the physical systems that address the
issues. This is provided as background information.
The main conclusions of this report are:
emergency preparedness, which embraces the characteristics of an
installation to withstand an emergency and the emergency response
system, remains a central part of the ‘protection in depth’ philosophy
applied to safeguarding the health and safety of persons on offshore
with the passage of time from the last major offshore accident it is
appropriate for a stimulus to be given to the total provision of emergency
response capabilities of offshore installations;
the performance standards in design and operational safety cases relating
to the endurance times of escape routes and temporary refuges, and
muster, evacuation, escape and rescue times, all of which are based on
ALARP considerations, are important inputs into the preparation of an
emergency response plan;
emergency response systems can be considered in two parts, first the
command capabilities of the management team and, second, all the other
support systems and hardware;
emergency command capabilities of offshore management teams is of
vital importance and, as in other fields involving the possibility of low
frequency, high consequence events, professionally organised scenario
based training and assessment is the only way of developing and assessing
individuals likely to be engaged in offshore emergency command
the offshore industry standard for providing training and assessment for
emergency command is set by OPITO and only OPITO approved bodies
can undertake training and assessments to this standard;
the regulator should be aware of the background to the OPITO Standard
and the assessment process and should measure whether or not duty
holders are meeting their legal responsibilities in respect of the emergency
command capabilities of their offshore management teams;
the remainder of the emergency response systems can be inspected by the
Regulator by following the legal requirements in PFEER, SCR and PSR.
Ideas on how this might be done are included in the report.
APPENDIX 1 (Page 10 refers)
OPITO is the body that has been given official recognition as the Government’s National
Training Organisation for the up stream petroleum industry. It is truly tripartite. One of the
responsibilities placed on National Training Organisations by the Government is the
establishment of training standards for a defined sector of industry. The influence of the
Regulator on these standards is achieved through direct representation. The Offshore Safety
Division of HSE is represented on the OPITO Training Standards Committee and at the OPITO
Board Meetings.
For the offshore industry, there is an OPITO Standard for the training and assessment of
offshore installation managers and deputies in controlling emergencies. This Standard has been
single out for a more detailed exposure than the other OPITO emergency response standards
since it is of paramount importance to success in dealing with offshore emergencies. It is
applied on an individual basis to offshore installation mangers and deputy installation managers
or their equivalents. However, the persons being assessed are examined when playing a leading
role in the emergency management team for their installation. From this it follows that,
notwithstanding the focus on the individual during assessment, the performance of the team as
an entity is also observed, together with the use of the hardware and the links to and capabilities
of the emergency response support teams. In this sense, the assessment process also forms part
of a wider testing of the whole of the emergency response system.
The Standard is based on a core unit for all installations with a system of awarding
endorsements for the various types of installation. Both the core and the appropriate
endorsement for the particular installation involved must be assessed. Endorsements cannot be
awarded on a stand-alone basis. The endorsements cover:
production operations (fixed);
production operations (floating);
drilling operations (fixed);
drilling operations (floating);
mobile/floating installations.
This Standard specifies that the training and assessment must be done using scenario based
exercises and the manner in which the assessment must be carried out. Only an organisation that
has obtained OPITO accreditation can undertake training and assessments to this Standard. The
coaching and assessment areas covered include:
maintaining a state of emergency preparedness;
evaluating the initial situation following an event requiring and emergency
mustering all personnel and determining whether or not any one is
developing a plan of action;
how to take an overview of the situation and not get overloaded with
establishing and maintaining effective communications both on the installation and
externally with the Coastguards, the standby vessel, other installations that might be
involved, other ships, helicopters in the area etc;
delegating authority to act;
dealing with stress;
determining the procedures to be followed including predicting the likely
determining as far as possible the state of the critical pieces of hardware
on the installation;
controlling the flow of information;
taking time out to reflect on the whole situation.
Although the OPITO Standard for emergency control only applies to the training and
assessment of offshore installation managers and their deputies, it is usual to train and assess the
performance of other members of the emergency response team when carrying out scenariobased events. These other members would include muster coordinators, muster checkers,
control room operators, fire team leaders/on site controllers etc.
A next step wider question for the Regulator is whether it should be encouraging, and be
involved in, establishing a National or International Standard for emergency response that
covers all major hazard industries, but this is not a question for this Report.
In addition to the OPITO Emergency Control Standard, there is a suite of other OPITO
Emergency Response Standards for persons having special emergency response duties. These
are listed below. All persons undertaking these roles except for the roles of offshore medic,
muster coordinator and muster checker, should have successfully completed the appropriate
OPITO training courses and be in possession of a current certificate to that effect. In the case of
the offshore medic HSE sets the training standard and approves the training courses. Therefore,
the role of offshore medic does not appear in the list below. In the case of muster coordinators
and muster checkers, whilst there is an approved OPITO competence standard for these posts,
the relatively straightforward nature of these duties are such that the training and competence
assessment is carried out offshore and does not warrant the involvement of an approved training
Fire team leader/on site controller.
Fire team member/on site team member.
Muster coordinator.
Muster checker.
Radio operator.
Lifeboat coxswain.
Helicopter landing officer.
Emergency helideck team member.
Control room operator.
There is an OPITO Standard for a basic safety induction and emergency response course. All
persons except occasional visitors should have attended such a course and be in possession of a
current certificate to that effect.
APPENDIX 2 (Page 10 refers)
For the purpose of regulatory inspection, it has to be recognised that there is a natural dividing
line between the command and control aspects of an emergency response system and the
provision of emergency hardware, individual competencies and an emergency response plan
setting out the organisational arrangements, the procedures to be followed and identifying the
roles to be undertaken by individuals. No matter how good is the emergency hardware, the
individual competencies, the emergency response plan etc, none of these provisions will be
effective unless there is a clear, competent and practiced installation command structure.
The very nature of command, which is characterised by the need for a management team to
perform, to manage a developing crisis under time and consequence pressures, often with
insufficient resources and information and with a varying dependency upon outside help,
requires a different training and assessment approach than is appropriate for the rest of the
emergency response system. Assessing and progressively improving the command capabilities
of individuals and management teams is highly specialised and requires skills that are not
traditionally used by regulatory inspectors.
Fortunately, the offshore industry is not alone with its needs to train, assess and progressively
improve the emergency command and control capabilities of its offshore management teams.
Perhaps the most publicised use of techniques for this purpose is in military command structures,
and in training and ongoing competence assurance procedures followed for airline pilots. In the
second of these the infamous flight simulator is used to generate stressful emergency conditions
that are used to both train and assess the performance of the flight deck crew. But the military
command and airline flight deck operations are by no means the only examples of the use of
scenario-based exercises for training and assessment purposes. In all cases the basic principles are
the same and involve a mixture of teaching, progressive learning through practical exercises, and
competence assessments during the exercises to make sure that only the competent are allowed to
practice in posts where emergency command and control duties are likely to arise.
Clearly there are serious limitations on the scope of the practical exercises that can be
undertaken on any major hazard site and some equally or more effective alternative methods of
simulating emergencies have to be found. For example, in respect of a potential offshore fire,
prospective offshore installation managers cannot sensibly be given the opportunity to practice
and be assessed with a real offshore fire. Similarly, in the airline industry it would not be
sensible to practice taking off on an actual aeroplane with a serious defect developing such as an
engine failure. Therefore, a realistic alternative has to be found. The training and assessment
technique used is to simulate a range of emergency situations, either on an offshore installation
or in an on shore simulation centre, by running a realistic exercise scenario with role players.
The offshore installation managers and their deputies undertaking the training are the
progressively coached and observed when managing these simulated emergency culminating
them being formally assessed on the last three exercises.
One of the advantages of using a simulation centre as opposed to an actual installation is that the
centre is completely separate from the day-to-day affairs associated with running an offshore
installation. And, using systems of one-way glass partitions, video cameras, voices recorders etc
it is possible to both enhance the learning and the assessment processes. This is a highly
professional business that needs to take care in generating sufficient realism in the scenarios but,
at the same time, needs to take care not to damage the persons under going the learning
experience and assessment. Just as in the case of military command and flight deck crews, the
employment consequences for the individuals who do not meet the standard are serious which
adds to the stress of those involved.
APPENDIX 3 (Page 10 refers)
The OPITO Emergency Command Standard follows the same principles as used for the training
and assessment of critical individuals for other high consequence situations requiring decision
making under stress and subject to very tight time constraints, for example, the training and
assessment of air line pilots, military commanders, managers of on shore major hazard plants.
The Standard requires the approved training and assessment provider to develop a number of
emergency scenarios that are relevant to offshore installations. Initially these are used as
training tools for the individual offshore installation manager or deputy being assessed and then
for the actual assessment. A different scenario is used on each occasion.
The method of assessment is by direct observation of the performance, when controlling a
simulated emergency, of the offshore installation manager or deputy offshore installation
manager being assessed. At least two qualified assessors holding NVQ D32 assessment
qualifications are used for each scenario. The OPITO Standard requires that for each individual
being assessed, at least three different simulated emergency major incident scenarios should be
used. These have to be drawn from the prescribed list below:
well control incident;
explosion and fire;
accommodation fire;
helicopter incident;
pipeline incident;
collision or wave damage causing structural collapse;
loss of stability (mobile installations).
The mechanism for selecting, developing, running and appraising the outputs from scenarios are
illustrated by the flow chart set out in figure 1 below. Objectivity and consistency in the
assessment process is achieved by breaking down the assessment into components. Outcomes
are set for each component. A top-down analysis of the system breaks down the components
into high-level statements of intent and then into individual components from which measurable
criteria can be identified. Scenario development and execution must be linked to the desired
output and it is recommended that measurable criteria are established to allow feedback on the
results, analysis of the strengths and weaknesses, and benchmarking across time, shift patterns
and installations.
Figure 1
A flowchart based on auditing through a scenario driven approach
The variation between scenario-based exercises can be large, ranging from a simple fire team
exercise through to a complete evacuation exercise. A plan defining the overall programme,
which illustrates how the complete system is to be assessed, should be developed. This can be
subdivided into more manageable units but a full test will need to be scheduled.
Examples of objectives:
testing information flow and communication through the platform control room;
testing the implementation of plans and decision making in the control room;
examining muster control and evacuation arrangements;
testing event recognition and reaction;
reviewing the evacuation of injured personnel;
testing alternative points of control;
examining rescue and recovery.
For each objective an output must be defined, what is acceptable within the safety case, the
emergency response system, industry guidance or company policy. The output may be a high
level statement that is subjective, for example:
Within the context of a drill or a large scale exercise a number of objectives and
outputs could be defined. For example a scenario based on a process plant event:
To test communication and information handling through the platform control room.
The control room to demonstrate its capability for handling verbal and visual information, by
assimilating, recording and briefing the correct personnel within an acceptable time frame.
To allow analysis and feedback against the objective, it is necessary to breakdown the system
into components that can be monitored, tested and measured. A system can be broken down into
hierarchical elements by considering the command structure and the organisation, for example,
offshore installation manager, fire team, first aid, muster control etc. Alternatively the system
can be built from the bottom up using a detailed analysis of equipment and a tasks analysis. For
a given platform a matrix of components can be compiled and referred to when recording the
components to be tested.
Using the control room example a range of components covering the people, plans and facilities
can be identified:
To test communication and information handling through the platform control room.
The control room can demonstrate its capability to handle verbal and visual information,
assimilate, record and brief the correct personnel within an acceptable time frame.
NB components monitored to achieve output
a) Facilities
Communications equipment
Information display equipment
Information recording equipment
Fire and gas panels
Stability controls
Wind speed and sea state
Process status
Isolation status
Fire pump status
b) Plans
Emergency response plan
Operating procedures
Incident Checklists
PA announcements
c) People
Suitable numbers
Ergonomics of the control room
Decision making
Information loading
For the approach to work the scenarios must be developed to meet defined objectives. They
have to be platform specific, based on the vulnerabilities of the platform and its operation, use
realistic techniques for initiation and escalation and ensure decision-making and tasks are
suitable. The scenario should not assume the response works according to the plan. The scenario
should be structured to allow opportunities for errors to be made, in observing the exercise a
textbook response is not to be expected. The object is to test effectiveness of the system to
deliver key performance criteria based on teamwork.
It is not necessary for the scenario to be complex but it is important that the expected events can
be analysed and the person developing the exercise must have a good understanding of the
event, its escalation paths and the planned response. The expected events refer to the actions of
teams, potential for mitigation, timescales for achieving various key points on decisions etc. A
range of inputs should be identified and the resulting actions analysed. Where a number of
components have been identified the scenario should be independently checked to ensure the
events and the possible outcomes will test the desired components.
Whilst the risks and events may be taken from the safety case it is not necessary to construct
scenarios that strive to replicate top events. Relatively small problems if correctly observed will
generate suitable analysis. It is however important to ensure realistic conditions are provided,
information flow, background noise etc are key examples of this.
The assessment is carried out by qualified and experienced assessors from OPITO approved
body appointed by the duty holder to undertake the work. Structured checklists are used to
ensure that the activities are being properly assessed, that there are no gaps in the scope of the
assessment, to provide consistency, and as part of the quality assurance arrangements of the
approved body. Annex A (page 47) gives a generic checklist used when assessing emergency
command capabilities. Repeating what has already been stated, such check lists should only be
used in real assessments by qualified and experienced assessors under the auspices of an OPITO
approved body. The process is illustrated in figure 2 below.
Figure 2
When using the assessment proformas, it sometimes happens that all components cannot easily
be assigned values or quantitative ratings. A combination of components may be grouped into a
time-based value such as the availability of a first aid team or fire fighting team within a set
time. The assessor monitoring the running of the scenario then makes an observation on whether
or not this time for the group of activities has been met and makes a corresponding entry on the
proforma being used.
Separate scenarios are selected for training and assessment. The training scenarios are graded in
an increasing order of difficulty so as to enable those involved to progressively improve. At
least a set of three different scenarios are used to assess the command performance of the
individuals fulfilling the roles or designated for the roles of offshore installation manager or
deputy offshore installation manager. The scenarios sets are not chosen so as to be a
comprehensive package covering all possible types of emergency but each set is assembled to
capture emergencies involving a fire, a helicopter crash and a hydrocarbon release. As well as
performing assessment functions and making the scenarios work, role players from the
approved assessment body are used to simulate the actions and communications of those who
would be involved if the simulated emergency were to be real.
Before the start of a scenario, a full breakdown is made of the components that will be used for
assessing the performance of the individual being assessed. The generic checklist forms the
starting point for the component analysis that takes place during the running of the scenario.
To test the emergency response system, assessors use component analysis in the following
first, by breaking down the emergency response system into a series of
components, for example, detection, action, response and conclusion, and
taking into account, examine in relation to the key elements of emergency
response including People, Plans and Facilities.
second, determining the salient emergency response actions that are
relevant to each of these components. The components and the salient
actions are then used as the basis for carrying out the performance
assessment of the individual being assessed.
Part of this process includes predetermining the acceptable performance under each of the
components. The outputs are then measured during the assessment process to determine whether
or not the person under assessment has demonstrated competency under each of the
components. The techniques used included:
observation (although observation is subjective, the subjective
measurements can be aggregated to achieve a degree of objectivity, again
this is an area where the OPITO accreditation process and the quality
assurance procedures with the approved assessment body come to the
comparing the component against pre-determined levels, for example,
performance standards and specifications;
attributing a number from the 5 point scale (good to unsatisfactory) in
relation to how close the component performed in relation to the ideal
aggregating components together to measure the response.
The results of this process are assembled and moderated through the peer review and quality
assurance procedures of the approved body. A final report is then prepared. The process is
illustrated in figure 3 below.
Figure 3
Stages of component analysis
ANNEX A (Page 12 refers)
This checklist is provided as background information. It is an example of the issues considered
by an OPITO approved training and assessment organisation when carrying out an assessment
to the OPITO OIM Emergency Control Standard.
Verbal reports noted and action taken
Alarm inputs noted
Incident status checked
Equipment status checked
Correct communications established
Personnel location identified
Personnel at risk identified
Continual updating takes place
Communication to
individual/team provided
sufficient information for
team to assess response
Response is appropriate to
type of alarm raised
Fire and gas detection,
CCTVs, reports from SOI
Plant status checked
Both internal and external
eg SBV, MCA, Duty
Use of PTW board, PA
system, muster point
Safety of at risk
personnel checked
Information is continually
and actively gathered
through observation,
communication, active
Recognition and
evaluation of risk
Action to report and escalate required
response taken
Understanding of impact demonstrated
Appropriate isolation considered
Dangers of ongoing work evaluated
Information sources reviewed
Leader communicates current position
and intended actions
Identify equipment
and controls
Systematic check of equipment and
controls conducted
Communications equipment checked
Security of ECR checked
Alternative equipment identified or used
Equipment well maintained
Positive action is taken to
obtain information or
updates from and to SOI,
Possibilities of escalation,
weather conditions,
location of incident,
inventories considered.
Actions indicate
awareness of impact
Isolation procedures
Dangers from other
operations considered
Alternative sources of
information explored
A ‘timeout’ is held during
which time information is
shared, objectives are
identified and plans
Warm clothing, suitable
footwear, grab bags etc.
Individuals can use the
equipment correctly under
realistic conditions (noise,
light etc)
Vulnerability of
communications equipment
considered and
contingencies identified
Vulnerability of ECR
considered and use of
alternate considered
Back-up fire pumps,
emergency generator,
alternate muster points
Checks on records show
correct maintenance
Control staff assessed by company as
Training records available
Roles and responsibilities known
Decision making
Facts reviewed and analysed
Decision communicated
Actions implemented
Actions monitored
Decision reviewed
Leader demonstrates knowledge of
escalation paths
Actions to prevent escalation are taken
Safety of personnel assessed
Risks of escalation communicated
OIM updated on escalation
Verification of training
and assessment records
Records of onboard drills
and exercises and training
matrix in place
Roles and responsibilities
clearly identified in ERP /
Station Bill
Reviewed as a group or
with individuals, possibly
during timeout, updates
on boards, plot plans etc
Recorded on action list,
through observation and
Record checked against
exercise/drill objectives
Individual monitors that
actions are implemented
Changing circumstances
are considered
particularly during
Leader identifies possible
escalation paths
Boundary cooling, deluge,
reduction of inventory,
may be appropriate
Determine whether the
effect of escalation on
safe areas and escape
routes eg TR, lifeboats is
Team members highlight
escalation risks during
Feedback given from SOI,
Actions follow a defined plan
The plan is approved
The plan is communicated
The plan allows for escalation
The plan is reviewed
Dealing with stress Behavioural observation indicates
Leader controls his stress levels
Stress in team members is observed and
acted on
Impact of room environment suitable to
control stress
Determine whether a plan
has been devised and if it
complies with the ERP
Variations to the plan are
recognised and approved
in accordance with the
command structure
Determine whether clear
instructions are given,
roles defined and tasks
Determine whether leader
identifies possible
escalation paths and
whether effects of
escalation (particularly on
safe areas and escape
routes) are considered
From brief discussions
during ‘timeouts’, from
discussions with MCA,
Duty Manager etc.
Indicators such as
breathing, posture, voice
etc and particularly self
Stress reactions are
identified eg agitation,
trembling, loss of
concentration etc and
support provided in the
form of reallocation of
task, removal from the
situation etc
Room layout, noise level
and environmental
conditions should be
Take effective
Mitigation actions are identified
Mitigation is implemented
Actions are communicated
Actions are monitored
Opportunities for error are controlled
Issue clear
Instructions are short and to the point
Personnel do not require repeated
Instructions are implemented
Communication is two way
Barriers to communication are controlled
Containment, down
manning, manoeuvring may
be considered
Mitigating factors
identified are
Clear instructions are
given both internally and
Feedback is requested,
obtained and independent
checks are conduced
Communication is clear
and two way, monitoring
takes place, overload and
stress on individuals are
Instructions are clear and
Determine whether
individuals ask for
clarification and
repetition of instructions
Select specific
instructions and follow
Determine whether
feedback is apparent (this
indicates two way
Language is understood
environmental factors are
Updates of information are reviewed
Focus is not concentrated on single
Decisions are reviewed in light of new
Is behaviour rule or knowledge based?
Team Work
Individuals work as a team
Remote teams are part of extended team
Objectives and goals of team clear
Feedback given on objectives
Open communication and ideas accepted
Changing circumstances
are considered
particularly during
Priorities are identified
and an overview is
Changing circumstances
are considered
particularly during
Are procedures / flow
charts appropriate for
the incident and are they
being used? Are the
required decisions skills
rules or knowledge based?
Good communications,
clear task allocation
Good communications and
obvious concern for the
welfare of remote teams
Objectives are clearly
communicated and
Feedback parameters are
set and followed
Team members are
encouraged to contribute
during timeouts
Task overloads monitored
Correct skills present
Sufficient personnel available
Missing skills can be resourced
Loss of key
Control of personnel occurs
Replacement for key personnel available
Clear roles and responsibilities displayed
Alternatives have correct
Personnel act on the authority of the
Tasks are delegated to the correct
Feedback is monitored
Personnel have resources to act on the
Determine whether tasks
are being given
unnecessarily (eg the
stress associated with
inaction - the need to do
Refer to training records
and job descriptions
Determine whether
personnel have too many
tasks and whether tasks
are evenly distributed
Determine whether
personnel are multi-skilled
in ER duties and whether
clear checklists are
available for stand in
Is the loss recognised in a
timely manner?
Determine whether the
responsibilities were
delegated / shared
ERP and / or checklist
available and utilised
Records checked
Authority is clearly
Consider criticality of
task, suitability and
workload of individual
Determine whether
feedback is clearly
requested during
delegation and whether
milestones are identified
Correct resources are
identified and made
Information overloads monitored verbal
and electronic
Determine if the team are
able to cope with number
and frequency of alarms
and instructions
Check response boards,
plot plans and event
narrative are accessible
and maintained up-to-date
Determine whether panel
operator is able to
identify key information
despite number and
frequency of alarms and
Atmosphere is calm and
controlled, GPA is muted
in a timely manner
Check response boards,
plot plans and event
narrative are up-to-date
and contain correct
(Track piece of
information from
insertion to recording)
Recording and retrieval of information is
Identification of key process variables is
not obscured by information overload
Noise does not restrict information flow
Information is acted on and not lost
ANNEX B (Page 8 refers)
Examples of Hardware
Examples of Software
Automatic systems
Manual systems
Elements of emergency
Training and competence
Lines of command
Raising the alarm
Automatic systems
Manual systems
Audible/visual signal
Training and competence
Lines of command
Emergency response plan
Mustering of persons
Escape routes
Muster areas
Temporary refuge
Medical equipment
Diving provisions
Short Duration BA
Account for POB
Training and competence
Emergency response plan
Lines of command
Casualty provision
Remote facilities
Temporary refuge
Short Duration BA
Lines of command
Training and competence
Emergency response plan
Evacuation routes
On installation
Medical equipment
Diving provisions
Lines of command
Training and competence
Emergency response plan
Ease of use
Casualty provision
Examples of Hardware
Examples of Software
Primary Systems
Secondary Systems
Escape routes
Escape equipment
Medical equipment
Lines of command
Training and competence
Emergency response plan
Ease of use
Casualty provision
Medical equipment
Diving provision
Lines of command
Training and competence
Emergency response plan
Casualty provision
ANNEX C (Page 18 refers)
Matters to be addressed in the over arching emergency procedures should include:
communicating the emergency to all persons on an installation;
mustering arrangements;
external communications;
interfaces with the emergency response plans of the operators of any
connected pipelines;
actions to be taken by the standby vessel, any supply boats available and any
helicopters available;
the management of the emergency including the use of an incident log and
event matrices for such matters as process plant upsets, availability of fire
water, availability of electrical power etc;
informing any divers working in the vicinity of an installation of an
emergency arrangements for rescuing and evacuation of any divers involved in
a diving emergency near the installation;
the availability of external assistance including search and rescue services;
arrangements for decision making on and actioning precautionary down
arrangements for decision making on, and actioning abandonment of an
ANNEX D (Page 19 refers)
A typical list of emergencies to be addressed by the second tier procedures is as follows:
fire or explosion;
blow out of a well;
leak or spillage of hydrocarbon fluids;
a pipeline incident;
severe weather affecting the stability of an installation;
movement of the sea bed affecting stability of an installation;
structural failure;
failure of the means for keeping an installation on station;
collision involving the installation;
helicopter accident;
person over board;
death or serious injury of a person on an installation;
terrorist activity.
In the context of the above list, inspectors should consider:
are the emergency response procedures fit for purpose;
are they available to all persons on the installation and to all organisations that
might be involved in responding in some way to an emergency;
are the procedures understood;
have all parties connected with the procedures been consulted;
are they periodically reviewed and updated to reflect lessons from exercises,
drills or other sources?
ANNEX E (Page 21 refers)
The programme of drills and exercises should include the subject areas listed below.
· Musters and the use of alternative muster points.
· Location and handling casualties.
· Fire fighting.
· MOB.
· Helideck incident.
· Helicopter incident.
· Well incident.
· Hydrocarbon production incident.
· Ship collision incident.
· Preparation for evacuation.
· Preparation for abandonment.
A typical drill could be used to test aspects of the emergency response system by determining
the effectiveness of the following:
· reaction to alarms;
· mustering arrangements;
· familiarity with equipment;
· evacuation procedures;
· internal and external communications;
· compliance with procedures;
· familiarity with installation layout.
ANNEX F (Page 22 refers)
The information of the Station Bill covers such matters as:
the emergency telephone number;
action to be taken on discovering an emergency;
the alarm system;
the normal and alternative muster points;
the lifeboat stations;
evacuation systems;
details of the emergency control and response teams;
instructions about ceasing work and smoking in the event of an emergency.
ANNEX G (Page 22 refers)
This check list is an aid memoir for persons having an interest in emergency response
systems. It should be of use to inspectors assessing the effectiveness of emergency response
response plan
Does the plan comply with Regulation 8
of PFEER and do the roles and
responsibilities follow the plan?
Command established in accordance
with the plan
Communication routes follow the plan
Test availability and knowledge of ERP
Safety Case
Organisation complies with safety case
Response meets performance criteria
Equipment suitable and sufficient
Risks and escalation routes known to
Event matrix
(A matrix linking
cause and effect
for process plant
Cause and effect of process upsets
Mitigation of problem implemented
Information available to meet operator
Examine ERP
Examine roles and
responsibilities within ERP
Refer to communication
flowchart within ERP
Sample management and
personnel generally
Refer to Safety Case
Refer to Safety Case
Refer to Safety Case
Decisions reflected the
escalation risks and times.
Loss of key services
Check whether specific
event matrix is available
and up to date
Actions correctly
implemented in a timely
manner to mitigate event,
actions monitored and
corrections made if
Check whether specific
event matrix is available,
up to date and is
Alarm lists
Alarm sequence interpreted by operators
Prediction of escalation realistic
Monitoring of alarms carried out
Are instructions and information
provided in accordance with Regulations
6 and 8 of PFEER and are the
instructions followed as appropriate?
Instructions known to operators
Instructions in an appropriate format
Means of detection Does the emergency detection
arrangements comply with Regulation 10
of PFEER and are appropriate actions
implemented on detection?
Maintenance of equipment suitable
PFEER Regulation 19 refers
Compare operator’s
conclusions against
scenario outline
Determine whether
monitoring and
interpretation of
secondary alarms is
Determine whether
secondary alarms are
Appropriate instructions
are identified and
Personnel are aware of
the location and content
of standing instructions
Easy to identify, locate
and use (user friendly) eg
flow diagrams and matrix
Automatic actions are
confirmed and manual
intervention considered
Are alarms audible?
Refer to maintenance
Refer to planned
maintenance and
inspection records
Scenario allows for
individuals to detect
Consult noise survey
Do alarms comply with PFEER
Regulation 11 and UKOOA guidance
Refer to legislation and
Can there be confusion over the type or
nature of an alarm?
Check particularly local
package and module alarms
Refer to ERP and local
standing instructions
Refer to records
Testing of equipment carried out
Personnel demonstrate knowledge of
actions on discovery of event
Are control room staff aware of the
action required on alarms?
Is the alarm history available for
Correct action implemented on alarm
Action follows ERP
Life saving
Are life saving appliances available at
the muster and / or embarkation stations?
PFEER Regulation 20 refers
Determine the most
suitable location for
emergency equipment eg
survival suit in ECR
Refer to inspection
records / visual sampling
of actual equipment
Refer to test certificates
Refer to training records
Check against procedures
Is the equipment well maintained?
PFEER Regulation 19 refers
Are test certificates in date?
Have personnel been trained in its use?
Was it used correctly during the
Can personnel demonstrate how to use
Are instructions available for its use?
PA System
PFEER Regulations 6 and 8 refer
Is guidance provided on who is
authorised to use it during an
Are personnel provided with prepared
Is the system accessible for use?
Is the equipment readily available and
does it meet the requirements of
Regulation 11 of PFEER?
Personnel know how to use equipment
Equipment is suitable for the
Alternative arrangements in place
Refer to drill records
Determine whether
instructions exist and are
correctly placed
Refer to ERP and standing
Check ERP for proformas
Check accessibility from
various locations ie
lifeboat and helideck
Local to the SOI, at
muster and command
Correct procedures
Includes issues such as
suitable for hazardous
areas, suitable for noisy
environment, waterproof
Personnel know and can
demonstrate alternative
Muster station
Regulation 14 of PFEER refers. Is a list
of names readily available for personnel
mustering at various muster stations
Inspection eg POB lists,
muster lists, t-card
Observation, questioning
and consider special
inputs to scenario
Determine vulnerability of
muster stations
Monitoring of access and
egress routes is carried
Re identification of
personnel, readability of
lists etc.
Sufficient space is available to muster
and not interfere with required
Location remains safe
Access and egress routes remain
Lighting main and emergency
Control Room
PFEER Regulations 6, 8, 11 and 12 are
particularly relevant.
Maintenance is carried out
Plans and procedures are available
Means for recording key information
Back up lighting is available
Evacuation and
escape routes
Torches are provided
Regulations 14 and 15 of PFEER refer.
Are escape routes available
Alternative routes are known to all
Personnel practice using different routes
Platform and external
communications are
Records are available and
up to date
Available and used
Include loss of normal
lighting in exercise
Check emergency
response boards,
particularly plot plan to
ensure unavailable routes
are identified
Routes should be clearly
identified on the plot plan
Training records
Evacuation and
escape equipment
PFEER Regulations 15, 16, 18 and 19
TEMPSC are available as a secondary
means of evacuation.
Escape items such as life rafts, chute
systems, ladders to the sea, other
controlled descent devices etc are
available as a means of escape
Grab bags are available to all personnel
Suitable protective equipment is
available as defined in the safety
Personnel are trained in the use of the
First aid equipment is available
Personnel have been instructed and
trained and are able to demonstrate
correct use
Rescue and
PFEER Regulations 7 and 19 refer.
Equipment to rescue persons from
helicopters is available.
Equipment is suitable and maintained
PFEER Regulation 17 refers.
Arrangements to recover persons
following evacuation or escape.
Arrangements for rescuing persons from
the sea.
Arrangements for taking persons to a
place of safety
regarding plant
PFEER Regulation 21 refers.
Information on areas where flammable
liquids and gases can occur, and on the
location of fire fighting plant, personal
protective equipment and life saving
External resources
Communication maintained with OIM
Requests from Fire Team dealt with
Control of remote response teams
Grab bags are utilised
Survival suits, lifejackets,
immersion suits
Training records and
Inspection and
Use is checked under
realistic conditions if
Periodically check the
availability of the
Check performance
standards for achieving a
good prospect of recovery
and that the facilities
provided meet these
performance standards
Check availability of
information on zoning, on
the location of portable
fire fighting equipment
and on the location of life
saving appliances
Check event narrative on
response boards and
observe OIM or delegate
Check action list and
listen for feedback
Determine whether clear
tasks, delegation, careful
monitoring are conducted
ANNEX H (Page 24 refers)
Audible and visual alarm systems for
GPA, PAPA, and where appropriate,
toxic gas
Evacuation / Escape Routes
Muster points
POB lists
Evacuation list and other proformas
T-cards / Swipe cards
Emergency signs
Survival suits
Grab bag (flash light, fire resistant
gloves, smoke hood)
Life jackets
Emergency lighting
Lifeboat loading instructions / procedure
Communications eg radios, PA system
Escape set (short duration BA set)
Water curtains (protection for people
eg stairways to lifeboats)
Fire fighting systems – deluge cools
vessels down gives personnel time to
Medical Equipment
Station Bill
Diving Provisions
Emergency Response Status Boards
POB board
When considering this plant inspectors should take into account relevant industry standards and
guidelines and should pursue the following questions:
· is the equipment working to the correct specifications;
· ease of use;
· location;
· identification and markings;
· training in the use of facilities, etc.
ANNEX I (Page 24 refers)
The table below shows the relationship between the components of an emergency response
system, the issues linked to the individual components and the physical systems that address the
issues. These are provided as background information.
Raising the
Typical elements
Single or multi-detection
Area classification
Widespread / isolated
Reliability of detection
Availability and survivability
Heat detection
Smoke detection
Gas detection
Type of alarm
Type of event occurring
Possible outcome
Special operations
Availability and survivability
Fire and gas detection
Local alarms
General platform alarm
PA system
Flashing signal/indicator
Manually activated call
point (MAC)
equipment eg radios
Egress routes
Muster station
POB list
Muster list
T cards/swipe cards
Emergency signs
Emergency lighting
Emergency equipment
status board
POB board
Station Bill
Temporary refuge (TR)
Fire and gas detection
system (to show further
Feedback from ERT
Decision making flow
Areas affected by incident / ·
protection of routes
Safety of personnel
Personnel missing
Weather conditions
Availability and survivability
Nature of incident
Event escalation
Time restraints
Failure of ESD systems
Availability and survivability
Typical element
Mitigation (eg blow down,
boundary cooling)
Availability and survivability
Equipment availability /
Access to equipment
Weather conditions
Wind direction
Maintain communication
Equipment availability /
Access to equipment
Safe access to sea
Fire on water / gas cloud
Portable fire fighting
Fire fighting vessel
Water curtain
Ventilation /extraction
Life jackets
Survival suit
Grab bag
Emergency lighting
Evacuation routes
Fire dampers
Pressurised areas
Medical equipment
eg stretcher
Station Bill
Diving provisions
Water curtains
Electrical isolation
Escape set
Evacuation sheets
Escape set
Grab bag
Survival suit
Life jackets
Life raft
Dacon scoop
Ladder to sea
Escape routes
Emergency lighting
Temporary Refuge
Typical element
Resources available
Maintain communication
Recovery to SBV
Installation manoeuvrability
Other vessels
Dacon scoop
Other installations
Casualty reception centre
Lord Cullen
ISBN 0 10 113102
KENNETH miller, University of Strathclyde
HSE Conference of Changing Health and Safety Offshore: The Agenda for the Next 10 Years,
Aberdeen, July, 1998
Brian Appleton
ISBN 0 7176 1165 5
ISBN 0 7176 0874 3
ISBN 0 7176 0938 3
IBSN 0 7176 1193 0
IBSN 0 7176 1182 5
ISBN 0 7176 1238 4
Link Associates International Ltd
Link Associates International Ltd
HSE Conference of Changing Health and Safety Offshore: The Agenda for the Next 10 Years,
Aberdeen, July, 1998
C McWhirr
HSE Conference of Changing Health and Safety Offshore: The Agenda for the Next 10 Years,
Aberdeen, July, 1998
T Brighton
Step Change Forum
Offshore Petroleum Industry Training Organisation
F Golden and M J Tipton
2nd International Workshop, Conference and Exhibition on Evacuation, Escape and Rescue,
Aberdeen, March, 2000
D M Menarry
2nd International Workshop, Conference and Exhibition on Evacuation, Escape and Rescue,
Aberdeen, March, 2000
S Haddock
HSE Research Report
RG Flin and G M Slaven
Approved Code of Practice
Breathing apparatus
Close circuit television
Daughter craft
Emergency control room
Evacuation escape and rescue
Emergency response plan
Emergency response team
Emergency shutdown
Fast rescue craft
General platform alarm
Helicopter landing officer
Heating, ventilation and air conditioning
Health and Safety Executive
Manually activated call
Maritime and Coastguard Agency
National vocational qualification
Offshore installation manager
Offshore Petroleum Industry Training Organisation
Public address
Prepare to abandon platform alarm
Offshore Installations (Prevention of Fire and Explosion, and Emergency
Response) Regulations 1995
Permit to work
Standby vessel
Offshore Installations (Safety Case) Regulations 1992
Site of incident
Temporary refuge
Persons on board
Personal Protective Equipment at Work Regulations 1992
Pipelines Safety Regulations 1996
Totally enclosed motor propelled survival craft
United Kingdom Offshore Operators Association
Printed and published by the Health and Safety Executive
ISBN 0-7176-2321-1
OTO 2001/091
9 780717 623211
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