Offshore First Aid and Medical Provision Inspection Guide

OFFSHORE MAJOR ACCIDENT REGULATOR

Offshore Petroleum Regulator for Environment & Decommissioning

The Offshore First Aid and Medical Provision Inspection Guide Open Government Status Fully Open

Publication Date April 2026

Review Date April 2029

Review History Date Changes

Target Audience OMAR Inspectors / ED Offshore Inspectors / ED Specialist Inspectors

Contents • Summary (p.2) • Introduction (p.2) • Relevant Legislation (p.3 to 4) • Action (p.5 to 6) • Background (p.6 to 11) • Other relevant Inspection Guides (p.11) • Specialist Advice (p.11) • Organisation (p.11 to 12) Targeting Timing Resources Recording & Reporting

Health and Safety • Appendices (p.12 to 19) Appendix 1 – Plan, Do, Check, Act for First Aid and Medical Provision Appendix 2 – Application of EMM and Dutyholder Performance Assessment

Summary This guidance outlines an approach to inspection of dutyholder’s arrangements for managing risks offshore associated with providing first aid and basic health care for all personnel, including visitors, who may be injured or become ill while on offshore installations. It also sets out criteria for satisfactory and unsatisfactory performance factors against which the dutyholder performance will be rated for each of these areas. References are made to technical standards and guidance that inspectors will use to form opinion for legal compliance. The effectiveness of such systems is a key component of occupational health and safety risk management. Securing effective control of risks will ensure that arrangements and facilities provided are adequate and appropriate in circumstances for enabling first aid to be rendered to employees and others shall they be injured or become ill whilst at work.

Introduction The aim of this Inspection Guide (IG) is to provide information and guidance to OMAR inspectors to support the delivery of consistent and effective first aid management. It does this by highlighting current key areas to be covered during inspections, providing a framework for inspectors to judge compliance, assign performance ratings, and decide what enforcement action to take should they find legislative breaches. In doing so, it complements HSE’s Enforcement Policy Statement (EPS) and Enforcement Management Model (EMM).

The operational guidance outlines HSE’s priorities for inspection of first aid and medical provision offshore. It is important to note that this guidance does not include detailed information on other offshore health risks such as Hazardous Substances, Noise, Vibration, Asbestos, Ergonomics/ Manual Handling, Ionising and Non-Ionising Radiations, Thermal Environment, Respiratory/ Personal Protective Equipment, Potable Water, and Welfare, which continue to form part of the remit of the ED Industrial Hygiene Team.

Relevant Legislation Health and Safety at Work etc Act 1974, Section 2(1) – It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees.

Health and Safety at Work etc Act 1974, Section 3(1) – It shall be the duty of every employer to conduct his undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in his employment who may be affected thereby are not thereby exposed to risks to their health or safety.

The Management of Health and Safety at Work Regulations 1999, Regulation 3 – Requires every employer shall make a suitable and sufficient assessment of the risks to the health and safety of his employees to which they are exposed whilst they are at work; and the risks to the health and safety of persons not in his employment arising out of or in connection with the conduct by him of his undertaking.

The Management of Health and Safety at Work Regulations 1999, Regulation 5 – Requires employers make and give effect to such arrangements as are appropriate, having regard to the nature of his activities and the size of his undertaking, for the effective planning, organisation, control, monitoring and review of the preventive and protective measures.

The Management of Health and Safety at Work Regulations 1999, Regulation 7 – Requires employers to appoint one or more competent persons to assist him in undertaking the measures he needs to take to comply with the requirements and prohibitions imposed upon him by or under the relevant statutory provisions

The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015, Regulation 16 – Requires a dutyholder who prepares a safety case pursuant to these Regulations demonstrate that the dutyholder’s management system is adequate to ensure that the relevant statutory provisions will, in respect of matters within the dutyholder’s control, be complied with.

Offshore Installations and Pipeline Works (First-Aid) Regulations 1989 (OFAR), Regulation 5 –

Requires a person in control of an offshore installation, pipeline works or any of the following activities in connection with an offshore installation carried on from a vessel, that is to say construction, reconstruction, alteration, repair, maintenance, cleaning, demolition, dismantling and any activity immediately preparatory thereto, to (a) provide, or ensure that there are provided, such equipment, facilities and medications and such number of suitable persons as are adequate and appropriate in the circumstances for rendering first aid to, and treating in accordance with the directions of a registered medical practitioner (who may or may not be present) persons who are injured or become ill while at work; (b) provide, or ensure that there is provided, such number of suitable persons as is adequate and appropriate in the circumstances for giving simple advice in connection with the health of persons at work; (c) make, or ensure that there are made, such arrangements as will enable– (i) the work of the suitable persons referred to in sub-paragraphs (a) and (b) of this paragraph to be supervised by one or more suitably qualified registered medical practitioners, and (ii) the advice or presence, as appropriate, of a suitably qualified registered medical practitioner to be obtained when needed;

The Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995, Regulation 8 – Requires the duty holder shall, after consulting persons who are likely to become involved in emergency response, prepare and, as often as is appropriate, revise a document (in this regulation called “the emergency response plan") containing sufficient information, for the guidance of such persons, on (a) the organisation and arrangements which are to have effect in an emergency; and (b) procedures by way of emergency response to be followed in different circumstances. The duty holder shall also ensure that (a) the emergency response plan is available to all persons on the installation; and (b) each person on the installation, and each person who may be called upon to assist in implementing the emergency response plan, are given such notification of its contents as is sufficient for them. The duty holder shall ensure that the organisation, arrangements and procedures are tested, by practice and otherwise, as often as may be appropriate and every person on the installation shall, in an emergency, so far as is practicable, conform to the appropriate procedure in the plan.

The Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995, Regulation 8 – Requires everyone to co-operate with the operator or owner of an offshore installation and the employer of people engaged in connected activities, so far as is necessary to enable them to fulfil their legal responsibilities, including their responsibilities under OFAR. The duty to co-operate falls

on everyone on the installation and their employers, as well as anyone who has agreed to provide medical support.

Action Inspectors should review relevant documentation outlined within the IG prior to the installation visit and test compliance during the installation visit against the “Success Criteria” given in Appendix 1.

Inspection of this topic should include both inspection of the priority areas as well as an inspection of the overall policy, procedures and organisation for managing occupational health and safety risks to establish a consistent and complete coverage of the topic. In inspecting individual topic areas, it may be necessary to have input from the relevant specialist inspectors where there are technical issues beyond the competence of the IMT inspector.

First Aid and Medical Provision - A dutyholder is required to have a first aid management system in place with appropriate organisational arrangements to ensure the management, control and monitoring of all aspects of first aid and medical provision. Arrangements are to be appropriate to provide adequate first aid and basic health care for all personnel, including visitors, who may become injured or ill while on offshore installations. Arrangements must consider the role, responsibilities and competencies of offshore medics and offshore first-aiders, medical supervision, clinical governance and the assessment of basic first aid and healthcare needs.

“first aid” means – (a) in cases where a person will need help from a medical practitioner or nurse, treatment for the purpose of preserving life and minimising the consequences of injury and illness until the appropriate help is obtained; and (b) treatment of minor injuries or illnesses which would otherwise receive no treatment or which do not need treatment by a medical practitioner or nurse.

OFAR requires first aid and basic healthcare facilities for everyone on an installation or engaged in any of the specified activities. However, ACOP L123 and guidance indicates that offshore installations, pipelaying barges/vessels and heavy lift vessels involved in construction and related activities need their own facilities. People based elsewhere (eg carrying out maintenance work from a support vessel) should have access to facilities on the associated offshore installation, vessel or barge, but there is no requirement for the support vessel to provide its own facilities beyond those required by maritime law. Nor does the duty extend to the crews of such vessels.

For diving operations, the definition of ‘pipeline works’ within OFAR excludes diving operations meaning that OFAR does not apply to diving projects in connection with pipeline works. Under the Diving at Work Regulations 1997 the diving contractor is required to provide first aid and medical equipment during a diving project. The person in control under OFAR is therefore entitled to assume that the diving contractor will provide the necessary people and facilities. But the person in control does need to cater for members of a diving team when they are not actively engaged in a diving project.

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

• Have undertaken a targeted proactive inspection of the first aid management system • investigate concerns associated with first aid and medical provision • decide whether the measures in place were adequate to control the risk of exposure; and take any necessary enforcement action where these are deemed inadequate

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 1 and 2 to: o Determine the appropriate performance rating o The Initial Enforcement Expectation (IEE) o Consider how and when the issues raised during an inspection are to be closed out

Background Good medical standards are an important part of a dutyholder’s philosophy to maintain a safe working environment where individuals can function safely without risk to plant, the environment or others. This document sets out principles that HSE expects duty holders to have adopted to provide adequate provision of first aid and medical care for workers offshore. Whilst to date there have been no formal interventions to inspect this topic, through general offshore health inspections undertaken by the ED Industrial Hygiene Team, numerous dutyholder management inconsistences/regulatory noncompliance’s have been identified which has resulted in enforcement being served at the time and therefore has prompted the creation of this topic inspection guide in collaboration with HSE’s medical unit within the Technical Support and Engagement Group (TSEG).

The essential requirements for managing occupational health matters are the same as those for any management system. Any sub-system for managing occupational health risks (including first aid and medical provision) should therefore have the key features of an adequate management system i.e., policy, organisation, planning and setting standards, performance measures and auditing and review. Confirmation should be obtained that a recognised code, standard or body of guidance has been considered in determining the required performance of the occupational health management system.

First aid arrangements should be part of wider arrangements to manage health and safety and emergency response offshore. The risk assessment required by regulation 3 of MHSWR will feed into an assessment of first aid and basic healthcare needs by identifying potential sources of injury and illness. The assessment required by regulation 5 of PFEER will also contribute. The offshore safety case assessment process should ensure that dutyholder’s have carried out an assessment of needs including provision of equipment, facilities, and medications and the numbers of ‘suitable persons’ and have identified suitable arrangements for rendering first-aid to people who are injured or become ill while at work.

For the purposes of OFAR, a person is not suitable unless they have undergone training and have obtained qualifications approved by HSE. ACOP L123 defines suitable persons as offshore medics and or offshore first aiders. It defines these terms as follows: Offshore first aider means a person who holds a current OFA certificate issued by an organisation approved by HSE to train, examine and certify offshore first aiders. Offshore medic means a person who holds a current OM certificate issued by an organisation approved by HSE to train, examine and certify offshore medics.

Note employers may need offshore first aiders and medics with specific training additional to OFA and OM courses, for example so they can provide first aid in incidents arising from work with particular hazards such as hydrofluoric acid, cyanide or confined spaces. The content of these additional training courses is not specified by HSE, and HSE approval is not required to run them. They can be provided as an extension to OFA or OM courses, or as stand-alone courses. The certificate issued following successful completion of additional training should be separate from the OFA or OM certificate.

Dutyholder’s should always ensure that all offshore workers are fully informed, among other things, about where and how to access first aid provision, including location(s) of medical equipment and facilities and how to contact the offshore medic or offshore first aiders rapidly in case of an

emergency. Workers should be made aware of any alterations in the arrangements (for example, when they are required to use different facilities or go to different personnel). New workers should be informed of first aid and medical arrangements when they come aboard the offshore installation.

First Aid Needs Assessment – FANA The person in control should make an assessment of first aid and basic healthcare needs appropriate to the offshore installation (including those normally unattended), pipelaying barge or other vessel on which there are activities under their control, to determine the type and scale of provision they need to comply with the Regulations.

As a minimum, all normally attended offshore installations, pipelaying barges/vessels and heavy lift vessels used in offshore construction, repair, dismantling or related activities should contain a sick bay (a room for the medical treatment and care of sick and injured persons). The size, layout, equipment, medications and facilities of the sick bay should be sufficient for the number of people regularly present at one time on the installation or vessel, and appropriate for the type of activity carried out (refer to ACOP L123 and OEUK guidance for further advice). People in control will need to review their first aid and healthcare needs from time to time, particularly after any operational changes, to ensure that provisions remain appropriate.

OFAR requires sufficiently trained and competent first-aid and medical personnel to be available, along with the necessary equipment, facilities and medications necessary to give assistance. The FANA must include an assessment of how many offshore medics and offshore first-aiders are required. This will normally indicate that an offshore medic needs to be available at all times. If only small numbers of people (eg 25 or fewer) are regularly present, or if the installation or vessel has access to onshore medical services at all times, then continuous cover by an offshore medic may not be required. There must always be an adequate number of offshore first-aiders, both where an offshore medic is available and where there is no need for one. Arrangements should ensure cover for absence, especially of the offshore medic.

A FANA requires to be site specific, representative and requires to undergo regular audit and review. This has been a common area of Dutyholder non-compliance, either with a FANA being found absent or not subjected to regular audit and review.

Normally unattended installations (NUIs)

The FANA is likely to indicate that there is no need for a sick bay on NUIs, and the same may be the case for first aid equipment. However, if they are provided, arrangements must be made to maintain their effectiveness since equipment left unattended may deteriorate. Arrangements should be made to provide cover for work crews visiting normally unattended installations. Normally, the assessment will indicate that the crew should include an offshore first-aider. If this is not the case, the assessment must consider the need for the crew to have: (a) basic first-aid training (see basic first-aid training within the ACOP L123); (b) appropriate first-aid equipment which they have been trained to use; (c) means for making contact with the appropriate person in case they need help.

Medical Emergency Response Plan (MERP) A MERP differs to the FANA requirements outlined above. Dutyholder’s must have plans in place to respond effectively to health and safety incidents and other emergencies that might occur at an event. A MERP should clearly outline the objectives of the plan, classifications of medical emergency events, multiple casualty provision and any triage arrangements, roles and responsibilities and specific actions/responses to be taken during a medical emergency event, key emergency contact details, any interface arrangements with medical supervision/Topside support and other agencies for example the Coastguard/SAR, specific training requirements, and defined audit/review arrangements.

Again, it is expected that a MERP is site specific, representative and requires to undergo regular audit and review.

Medical supervision OFAR requires the person in control to