Hydrocarbon Active Fire Protection

The Offshore Hydrocarbon Active Fire Protection Inspection Guide Open Government Status Fully Open Publication Date July 2025 Review Date August 2028 Internal Reference CM 2025/165171

Review History Date Changes

August 2021 Approved for issue July 2025 Updated for scheduled review. Update includes transfer to new template as well as defining and structuring the guide to include relevant topics for active fire protection for hydrocarbon incidents.

Target Audience ED Offshore Inspectors

Contents • Summary (p.2) • Introduction (p.2) • Relevant Legislation (p.3) • Action (p.4) • Background (p.4) • Supplementary Information (p.6)

• Specialist Advice (p.7) • Organisation (p.7) Recording & Reporting Health and Safety • Appendices (p.8) Appendix 1 – Pre-visit information request Appendix 2 – Success criteria Appendix 3 – Inspection questions Appendix 4 – Dutyholder performance assessment Summary This Inspection Guide (IG) outlines an approach to the inspection of dutyholder arrangements with respect to Active Fire Protection on offshore installations and the key areas that inspectors should consider when inspecting this topic. This includes the criteria for satisfactory performance factors against which dutyholder performance will be rated. Reference is made to technical standards and guidance that inspectors will use to form an opinion regarding legal compliance.

Introduction The purpose of this Inspection Guide is to provide information and guidance to Energy Division (ED) Offshore Inspectors to support the delivery of consistent and effective inspection of dutyholder arrangements, to comply with the Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995 (PFEER), requirements for Active Fire Protection, as a mitigation measure for hydrocarbon fires from production and well related activities. The scope for Active Fire Protection for this inspection guide includes:

• Fire pumps; • Fire water ring main; • Deluge systems; • Chemical dosing systems for marine growth; and • Corrosion prevention.

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

Note. Accommodation type firefighting systems for cellulosic fires are not part of the scope for this inspection guide. However, it is expected that dutyholders install appropriate measures in line with hierarchy of control. Also out of scope of this inspection guide are helideck firefighting systems, water mist systems (these may be found in accommodation areas and also in other areas such as engine rooms), and inert gas systems.

Relevant Legislation The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015, (referred to as the “Offshore Safety Case regulations” in the rest of this document: • Regulation 9 requires that a verification scheme is established to check safety and environmental critical elements. • Regulation 16 requires that the management and control of major accident hazards are described in the Safety Case. This includes safety and environmental control elements such as active fire protection. The Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995 (referred to as the “PFEER regulations” in the rest of the document: • Regulation 4 places a general duty on a duty holder to take appropriate measures with a view to protecting persons on the installation from fire and explosion and to securing effective emergency response. • Regulation 5 requires an assessment to be undertaken to identify major accident hazards, to evaluate related risks and to identify measures necessary to protect people and provide means of evacuation, escape and rescue. • Regulation 13 requires the duty holder to take appropriate measures to protect persons on the installation during an emergency from the effects of fire and explosion. • Regulation 19 requires the duty holder to maintain the measures provided for the PFEER regulations. The Management of Health and Safety at Work Regulations 1999: • Regulation 3 requires a suitable and sufficient assessment of the risks of health and safety at work for employees and others affected by that work. • Regulation 5 requires appropriate arrangements for the planning, organisation, control, monitoring and review of the preventive and protective measures, which also have been identified in the risk assessment.

Action Inspectors should review relevant documentation (see Appendix 1 Pre-visit Information Request) prior to the installation visit and test compliance during the installation visit against the “Success Criteria” given in Appendix 2).

By the conclusion of the inspection it should be possible to: • score the installation against the guide and provide evidence for this score.

When carrying out inspections covered by this IG, inspectors should: • Assess dutyholder responses against the success criteria in Appendix 2; • Use the performance descriptors in Appendix 3 to: o Determine the appropriate performance rating; o The initial enforcement expectation; and o Consider how and when the issues raised during an inspection are to be closed out.

Background Active Fire Protection (AFP) is a key mitigation measure for many offshore installations to protect people on the installation during an emergency. It is one of a set of mitigation measures (such as passive fire protection) that are normally present on offshore installations to fulfil the requirements of the Offshore Installations (Prevention of Fire and Explosion and Emergency Response) Regulations 1995 (PFEER). Regulation 13 – Mitigation of fire and explosion. As described by L65 “Prevention of fire and explosion, and emergency response on offshore installations” ACOP paragraph 176: “The objective of active systems should be to deliver the required quantities of the fire-fighting media within the required time to the required locations.”

The findings from Lord Cullen’s report “The Public Inquiry into the Piper Alpha Disaster” influenced the development of offshore regulations such as the Offshore Safety Case regulations as well as the PFEER regulations. There were many contributors to the Piper Alpha disaster. In relation to the active fire protection system, the relevant deficiencies from the report were as follows: • Pump vulnerabilities: o The poor practice of keeping the diesel fire pumps on manual mode when diving was taking place, no matter how far away the divers were from the pump inlets, meant that automatic activation was unavailable. o With the diesel fire pumps on manual mode, the electric fire pumps could not activate as initial fires and explosions likely disconnected the power.

o Manual mode put operators at risk because they had to move through areas affected by the fire and explosion to reach the pump to start them. • Ring main vulnerabilities: o Small branches on the ring main were thought to have failed in the initial explosion preventing the supply of water to the deluge system. • Deluge vulnerabilities: o The deluge nozzles had a history of blockages. o Increasing the frequency of wet testing (for troubleshooting) led to increased corrosion and more blockages. o The material of construction was carbon steel, which corroded when exposed to seawater, which was the firewater media. The section of deluge system constructed with cunifer reported no problems with blockages.

Between 2011 and 2013 HSE carried out a programme of onshore and offshore inspections of the Ageing and Life Extension and Asset Integrity Management systems to establish whether the risks were being managed effectively and to encourage improvements. HSE published its report in the findings as Key Programme 4 (KP4) “Ageing and life extension programme”. Page 20 of the report documented that overall the industry had “plans in place for the inspection and maintenance of metallic firewater deluge systems, with some dutyholders replacing some or all systems with fire- resistant non-metallic pipework for greater longevity". But, highlighted that: • “While plans were in place for integrity management of firewater deluge systems, there were widespread internal corrosion problems, and nozzle blockages of galvanised carbon steel systems”. • “To guarantee availability of firewater at times of need, there must be reduced reliance on defined repairs. To overcome compromised integrity there should be greater forward planning to ensure pipework is managed to minimise corrosion, perhaps by chemical treatments”. • “Performance data should be trended to avoid ‘fix on fault’ maintenance of gas detection and emergency shutdown equipment (in this case – the fire water system), to ensure long-term risks are predicted and proactively managed”. The expectation is for the root causes of failures (such as internal corrosion mechanisms or marine growth) to be determined to allow for the identification of sustainable solutions that would prevent recurring deficiencies (such as nozzle blockages). • Note that simply flushing and cleaning a deluge system following a failure, in order to meet a performance standard, should also be accompanied with a root cause investigation for the failure of the systems and actions taken to resolve the issues identified. This is because a

failure of the performance standard the first time would indicate that blockages (corrosion or marine growth) had developed between tests. That is, the system would not have operated effectively on demand.

Supplementary information • Offshore Information Sheet 5/2009 Provision of active fire protection on offshore installations www.hse.gov.uk/offshore/infosheets/is5-2009.htm • Offshore Information Sheet 1/2010 Water deluge systems: Testing and performance measurements www.hse.gov.uk/offshore/infosheets/is1-2010.htm • Energy Institute’s “Guidelines for the corrosion management of firewater deluge systems”.

Specialist Advice Specialist advice should be sought from ED5 Fire Explosion and Risk Assessment (FERA) team in the following circumstances: • When there is uncertainty over the requirements for AFP within this inspection guide and the level of enforcement. • When there are complexities, e.g. interactions between a number of measures that include active fire protection.

Organisation

Recording & Reporting

The dutyholder performance ratings should be entered on the Inspection Rating (IRF) Tab of the relevant installation Intervention Plan Service Order.

Health and Safety Parts of the AFP system can sometimes be : • In restricted areas. For example, firewater pumps are sometimes located inside of shafts or pontoons or equivalents that may require special access. • difficult to access. For example deluge or firewater pipework may need special set up in order to allow for safe access. Therefore, the inspector should liaise with the dutyholder management and complete steps that would ensure their health and safety to inspect the equipment.

Appendix 1: Pre-visit Information Request

The information listed below is to be requested to inspect prior to arriving on site. • Independent Competent Person (ICP): most recent reports for the Active Fire Protection/deluge testing/wet testing as a minimum the last 2. . • List of currently open SECE deferrals and ORA’s relating to Active Fire Protection • Summary of recorded safety related near misses, incidents, and accidents for last 12 months, relating to active fire protection. • Performance Standards and Planned Maintenance Routine or Task Routine for Active Fire Protection. These should include performance criteria for: o Firewater pumps o Firewater ring main (including the isolation and control type valves) o Deluge nozzles • Management procedures for AFP SECEs.

Appendix 2 – Success Criteria

The main aim of an offshore active fire protection system should be to fulfil one of the measures required by Regulation 13 of the Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995. This regulation states that: “The duty holder shall – (a) take appropriate measures with a view to protecting persons on the installation during an emergency from the effects of fire and explosion; and (b) ensure that, so far as is reasonably practicable, any arrangements made and plant provided pursuant to this regulation are capable of remaining effective in an emergency.”

L65, “Prevention of fire and explosion, and emergency response on offshore installations” ACOP provides further information upon the requirements to fulfil regulation 13 such as: • 173, “The measures selected for major accident hazards should be based on the assessment required by regulation 5. The roles of different measures should be considered in an integrated way so that the functioning of one measure does not prevent another from meeting its required performance standard”, i.e. it should be a measure against a major accident hazard determined by an assessment; • 174, The measures taken should: (a) be appropriate for the hazards; (b) include provision of appropriate fire-fighting media and portable equipment; (c) provide for automatic systems, or manual operation where this can be justified in the assessment; (d) provide adequate levels of protection for key locations (e.g. temporary refuge and escape routes) and emergency systems where they have been identified as requiring protection; • 176, “The objective of active systems should be to deliver the required quantities of the fire- fighting media within the required time to the required locations”; • 178, “For measures to remain effective in an emergency, dutyholders must consider suitable contingency arrangements, including operational arrangements and diversity and redundancy in protective systems”; • 179, “These should take into account the hazards, the role of the system in mitigating them and the consequences of its failure, where all or part of the main system may be unavailable; for example, due to damage during an accident or when equipment is undergoing maintenance”;

• 180, “Dutyholders should also take into account any increased vulnerability to the system as a whole by the addition of redundancy”.

Firewater pumps

Firewater pumps should: • have sufficient capacity for the largest firewater duty expected on the installation. If any firewater pumps are not available because of maintenance there should be enough capacity from the remaining pumps. • be ready to start operation in an emergency. • meet their performance standard requirements, e.g. pump tests at or above the required target. • have been designed to reduce vulnerability and avoid common mode failure, for example firewater pumps should be segregated to avoid the same incident, have sufficient diversity in power source such as electrical and diesel pumps. This should be true for any temporary pumps that are installed during maintenance of the permanent pumps. • have intake and discharge systems designed and maintained to avoid common-mode failures (e.g., blockages from marine growth or debris at shared intake points).

Firewater mains The firewater main should: • be maintained in an efficient state, in efficient working order and in good repair. • have methods for avoiding blockages in the system which are fully functional and effective, e.g. filtration to keep solids out of water and dosing to prevent marine growth. • have functional isolation valves between systems.

Deluge systems – branches and nozzles Deluge systems should have: • clean and functional nozzles – signs of damage or blockages kept to minimum. For example, blockages should not exceed 5% unless the dutyholder demonstrates through testing or modelling that coverage remains adequate per the performance standard. • pipework in good condition with no blockages. • pipe supports in good condition. • branch design should preferably be free flowing with no deadlegs, if deadlegs exist these should be identified and managed adequately • deluge nozzles that respond inside of the specified times in the performance standards.

• records of functional tests that fulfil the criteria from the relevant performance standard, such as measurement of flow and coverage of the deluge system. Furthermore: o tests should have been performed as the system is found. That is, rectification work must be performed after the test and not prior. o the deluge system should be put into a suitable safe condition after the test is performed e.g. the clean out and drain down of the deluge pipework and nozzle. This is because untreated seawater can lead to corrosion in carbon steel pipework. o tests should check that water reaches all expected areas, which should confirm nozzle orientation. o tests should check that the correct deluge system water application rate is achieved. • good housekeeping so that nozzle spray paths are not blocked, e.g. by scaffolding – unless there are other suitable measures in place. If scaffolding is required in the area, the time that the scaffolding is in place should be kept to a minimum.

Dosing System – chemical dosing system for the inhibition of marine growth (such as a hypochlorite system) Should be: • maintained in an efficient state, in efficient working order and in good repair.

Appendix 3 – Question Set The following are a list of proposed questions to guide inspectors with their inspections of the Active Fire Protection Systems. In cases where the installation has very complex systems, the inspectors should select the questions based upon the sample that was selected for inspection as appropriate.

Question Set Topic Questions Duty Holder Response/ Inspector Comments MANAGEMENT AND SAFETY Who are the individuals that have responsibility MANAGEMENT SYSTEM for AFP systems? Which Technical Authorities are responsible for the AFP system? Is maintenance/testing performed by Core crew or contractors?

Review the Safety Case in advance, From the Safety Case: • Is the installation permanently manned? • How many firewater pumps are on the in- stallation? • What is the minimum flow for the pre- dicted worse case? • What is the capacity of the individual fire- water pumps?

• How has diversity and redundancy been addressed? This includes not only the pump itself but the firewater pump inlets + outlets as well as their starting arrange- ments and power sources. • How is pressure maintained in the firewa- ter mains? • How are common blockage issues han- dled, e.g. is filtration in place and is dos- ing used to control marine growth? • Which locations have deluge (including foam)?

Are personnel trained to operate AFP systems under emergency conditions, and are human error risks (e.g., manual overrides) mitigated?

Have there been changes/improvements have been made to any of the AFP systems on the installation? What prompted these changes? Was Management of Change systems used? Have records been kept regarding the changes on the installation? Defect management and root cause Have there been any defects identified? analysis. Have defects been documented and tracked? Have the root causes for these defects been determined to prevent future ongoing deficiencies? Have opportunities been identified to take advantage of technological and technical

progress to improve work methods and make them safer.

Question Set Topic Questions Duty Holder Response/ Inspector Comments FIREWATER PUMPS What is the operational status of the firewater pumps? Are all available?

What is the AFP philosophy/strategy? I.e. how many firewater pumps