The Offshore Health Risk Management Inspection Guide

OFFSHORE MAJOR ACCIDENT REGULATOR

Offshore Petroleum Regulator for Environment & Decommissioning

The Offshore Health Risk Management Inspection Guide Open Government Status

Fully Open

Publication Date

December 2025

Review Date

December 2028

Review History

Date Changes

November 3 Yearly review, format changes only. 2025

Target Audience

OMAR Inspectors / ED Offshore Inspectors / ED Specialist Inspectors

Contents Summary......................................................................................................................................... 2 Introduction .................................................................................................................................... 2 Relevant Legislation ...................................................................................................................... 2 Action .............................................................................................................................................. 3 Background .................................................................................................................................... 4 Other relevant Inspection Guides ................................................................................................. 5 Organisation ................................................................................................................................... 6 Targeting ..................................................................................................................................... 6 Timing.......................................................................................................................................... 6 Resources ................................................................................................................................... 6 CM9: 2022/108051 Owner: ED5 Industrial Hygiene Page 1 of 12

Recording and Reporting .......................................................................................................... 7 Health and Safety ........................................................................................................................... 7 Appendix 1 Plan, Do, Check, Act for COSHH Management ........... Error! Bookmark not defined. Appendix 2 Application of EMM and Dutyholder Performance Assessment ......................... 11

Summary

This inspection guide (IG) outlines an approach to the inspection of dutyholder’s arrangements with respect to health risk management (HRM) and acts as an umbrella document above all the other health risk topics. This guide is to be used during pre-inspection planning, offshore inspections, and annual reviews and in conjunction with the other industrial hygiene (IH) inspection guides to determine the adequacy of the dutyholder management systems and their implementation/ongoing management of these management systems. The document highlights the key areas that inspectors should consider when inspecting this topic and sets out the criteria for satisfactory and unsatisfactory performance factors against which dutyholder performance will be rated. References are made to technical standards and guidance that inspectors will use to form an opinion of legal compliance.

The HRM IG requires dutyholders to demonstrate that their management systems are adequate to ensure compliance with the relevant statutory provisions. A safety management system which does not include industrial hygiene and health elements is unlikely to demonstrate that the management system is adequate. Assessment of the health components is therefore an important part in that it requires the offshore operator to demonstrate to the regulator that their safety management system (SMS) includes arrangements for complying with the statutory requirements of the regulations covering health risks.

Introduction The purpose of this IG is to provide information and guidance to OMAR inspectors to support the delivery of consistent and effective health risk management.

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

Relevant Legislation

• Health and Safety at Work etc Act 1974 • Management of Health and Safety at Work Regulations 1999

• The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015 (SCR2015) • Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995 (specifically Regulations 17 and 18), including associated guidance (L70 www.hse.gov/uk/pubns/books/l70.htm) • Control of Noise at Work Regulations 2005, including associated guidance (L108 www.hse.gov.uk/pubns/books/l70.htm) • Control of Vibration at work Regulations 2005, including associated guidance (L140 www.hse.gov.uk/pubns/books/l140.htm) • Control of Ionising Radiations 2017, including associated guidance (L121 www.hse.gov.uk/pubns/books/l121) • Control of Asbestos Regulations 2012, including associated guidance (L143 www.hse.gov.uk/pubns/booksl143) • Control of Substances Hazardous to Health Regulations 2002 (as amended), including associated guidance (L5 www.hse.gov.uk/pubns/books/l5.htm and L8 www.hse.gov.uk/pubns/books/l8.htm) • Control of Lead at Work Regulations, including associated guidance (L132 www.hse.gov.uk/pubns/books/l132.htm) • Manual Handling Operations Regulations 1992 (as amended), including associated guidance (L23 www.hse.gov.uk/pubns/books/l23.htm) • Offshore Installations and Pipeline Works (First-Aid) Regulations 1989, including associated guidance (L123 www.hse.gov.uk/pubns/books/l123) • Offshore Installations and Wells (Design and Construction etc) Regulations 1996, including associated guidance (L85 www.hse.gov.uk/pubns/books/l85.htm) • Health and Safety (Display Screen Equipment) Regulations 1992

Action

Inspection of this topic area will include the overall policy, procedures and organisation for managing occupational health risks to establish a consistent and complete coverage. 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 inspection management team (IMT) inspector.

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.

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

• have undertaken a targeted proactive inspection of the HRM systems • investigate concerns associated with a relevant HRM system • 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 duty holder responses against the success criteria in Appendix 1 • use the performance descriptors in Appendix 2 to o determine the appropriate performance rating o the initial enforcement expectation o consider how and when the issues raised during an inspection are to be closed out

Inspectors should review relevant documentation such as a dutyholder IH management strategy document and any associated health risk assessments (HRAs) and improvement plans prior to the installation visit and test compliance during the installation visit against the “Success Criteria “given in Appendix 1.

Background The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations requires a safety case to demonstrate that the dutyholder’s management systems are adequate to ensure compliance with the relevant statutory provisions. A safety case which does not include occupational health elements in the descriptions of the management system is therefore unlikely to demonstrate that the management system is adequate.

The aim of industrial hygiene is to prevent or control exposure to health risks by recognising health hazards (physical, chemical, biological and ergonomic), evaluating the risk and establishing appropriate control measures.

The ED IH team developed guidance to offshore operators in preparing safety cases with respect to occupational health risk assessment. These safety cases are reviewed by the IH team to ensure that operators have arrangements in place for the management of health risks.

Offshore workers are exposed to a range of health hazards. The health risks are difficult to quantify owing to the long latency of some of the occupational diseases however, operational intelligence indicates significant numbers of workers being exposed to health risks including noise induced hearing loss, vibration white finger and occupational lung disease. In addition, the ageing infrastructure offshore has resulted in deterioration of accommodation/welfare facilities, which can impact on the ability of workers to rest and recover.

Increased fabric maintenance and the beginning of decommissioning will expose the offshore workforce to a broad range of occupational health risks including the potential for inadvertent exposure to asbestos.

The recent downturn in the offshore industry has resulted in a loss of industrial hygiene expertise from the industry, and operational intelligence indicates a potential deterioration in the arrangements for managing health risks offshore. Therefore, this inspection guide on the management of health risks offshore will act like the over-arching umbrella document, being used to verify onshore industrial health and hygiene policies, strategy, organisation, procedures, competence and health improvement plan. This will be followed up by an offshore inspection, looking at 2-3 specific health risk areas, to check effectiveness of offshore implementation and compliance with relevant legislation. This inspection guide will form the basis for all planned offshore inspection visits from 2022 and beyond. The aim is to reduce work related illness by improving the arrangements and thereby control of health risks by offshore operators.

The aim of industrial hygiene is to prevent or control exposure to health risks by recognising health hazards, evaluating the risk and establishing appropriate control measures. The health hazards may include biological agents (eg Legionella).

The essential requirements for managing health are the same as those for any management system. Any sub-system for managing health risks should therefore have the key features of any good management system ie 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 industrial hygiene management system.

Other relevant Inspection Guides

• The Offshore Health Risk Management Inspection Guide • The Offshore Potable Water Management Inspection Guide • The Offshore Noise and Vibration Inspection Guide • The Offshore Control of Substances Hazardous to Health (COSHH) Inspection Guide • The Offshore Asbestos Inspection Guide • The Offshore Radiation Inspection Guide • The Offshore Food Hygiene Inspection Guide

Specialist Advice Specialist advice should be sought from the ED Industrial Hygiene Team in circumstances when considering enforcement / debate over relevant standards on any aspects of health risk management.

Organisation

Targeting

Inspections should be planned to ensure that the necessary site personnel are available, and arrangements can be made to facilitate physical inspection of the system(s).

Timing

Inspectors should undertake Inspections as part of the agreed Intervention Plan or as determined by the EDSLT.

Resources

Further guidance can be sought from

HSE website Occupational health risks offshore https://www.hse.gov.uk/offshore/occupationalhealth.htm

HSE Asbestos Essentials www.hse.gov.uk/asbestos/essentials/index.htm

HSE Offshore COSHH Essentials www.hse.gov.uk/coshh/industry/offshore.htm

OEUK: Guidelines for Environmental Health for Offshore Installations: Potable Water Management

Energy Institute: Decommissioning within the offshore UK oil and gas industry A practical guide to worker health protection https://publishing.energyinst.org/topics/health/medical/decommissioning- within-the-offshore-uk-oil-and-gas-industry-a-practical-guide-to-worker-health-protection

Health risk management: A practical guide for managers in small and medium-sized enterprises, HSG137 www.hse.gov.uk/pubns/books/hsg137.htm

British Occupational Hygiene Society www.bohs.org

The HI Standard – Health in Industry Management Standard – Breathe Freely https://breathefreely.org.uk/standards/

Recording and Reporting

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

Health and Safety When conducting an inspection, the principles for mitigating the risk to staff are as follows • sound training for the recognition and identification of risks • understanding of roles and responsibilities • planning and conducting site visits in accordance with HSE procedures

Inspectors undertaking inspections must be suitably trained and competent. The aim is to avoid the risk of exposure by carrying out your duties without entering areas where exposure to physical and chemical hazards may occur. If you are in any doubt about the hazards you face or whether control measures are adequate to safeguard your own health and safety, you should withdraw from the area and seek advice from your line manager or an experienced colleague.

Appendix 1 – Plan, Do Check Act for Health Risk Management 1. To comply with SCR2015 has the dutyholder provided information within the safety case to manage industrial hygiene – recognition, PLAN evaluation and control of hazards and risks to health?

2. Is there an IH strategy in place as part of the health risk management system? How is this implemented and communicated?

3. Is there an IH improvement plan? Is it integrated within the HSE plan or stand alone?

4. Are IH KPIs in place to monitor performance, and are these tracked/reported back to director level? The commitment of senior management is essential to this process and the safety case and policy should demonstrate support of senior management, provision of adequate resource and input from technical specialists as appropriate.

5. Is there an organogram in place identifying the required resource for managing health? Confirm that appropriate health specialists are involved in developing and managing the health management system. Identify what current external specialist health and hygiene support is in place, and if in-house expertise and/or resources are insufficient to meet the organisation’s needs. (Occupational/industrial hygienists use science and engineering to control risks to health, by designing out hazards and applying engineering controls to reduce exposures to a minimum).

6. Is there a company IH focal point (FP) role onshore? Is there a process in place for IH FP/specialist involvement for high-risk work ie TARs, CSE, welding?

7. Who are the offshore IH focal points? is there a process in place for regular engagement on IH matters with onshore IH FP/specialists?

8. Does the safety management system reference and recognise health hazards, evaluating the risk and establishing appropriate control measures?

9. Does the safety management system (SMS) health document reference the following, physical agents (eg noise, vibration, radiation), hazardous substances (eg chemicals, asbestos), biological agents (eg legionella, food hygiene), manual handling and ergonomics?

10. How does the permit to work system identify and manage the health risks above?

11. Do these arrangements align with the strategy to ensure the effective control of health risks are credible and effective?

12. Are there suitable arrangements for the health management of contractors/visitors ie health surveillance, communications of monitoring carried out, records etc?

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DO 1. Is there a health risk assessment (HRA) process in place? Were IH FP/specialists and relevant offshore personnel involved with the process?

2. Are HRA/improvement plan actions being tracked/actioned accordingly to ensure they are effectively implemented?

3. Have all persons who are responsible for the management of health received adequate information, instruction and training? Confirm there is a competence process in place for roles and responsibilities including a matrix, supporting the dutyholder to manage their activities safely and keep up to date with developments in occupational health and industrial hygiene.

4. Are control measures being suitably managed/inspected and maintained at suitable frequencies? Are these requirements managed via planned maintenance routines and do appropriate management records exist?

CHECK 1. Verify whether the health arrangements are physically capable of delivering the claimed performance is a matter for post acceptance inspection.

2. Confirm there are internal and external management audit processes as part of the safety and environmental management system (SEMS) which would include occupational health & hygiene.

3. Verify auditing and control verification has been undertaken

4. Do records illustrate that the control measures are being managed accordingly and are effective?

5. Confirm there are monitoring systems for inspection, maintenance and testing of the facilities and equipment

6. Confirm there is a system in place to review the HRA/IH plan at appropriate intervals? How does this tie into the KPI monitoring/review and engagement sessions between specialists/FPs mentioned above?

7. Are periodic arrangements in place to assess whether the HRA remains suitable and sufficient? Are periodic audit arrangements in place to assess the effectiveness of the IH plan and HRAs?

8. Have any ill health concerns been reported? If so, have the ill health concerns been effectively investigated and has any relevant remedial action been taken to prevent re-occurrence?

9. Has any data from exposure monitoring of employees and contracting staff been managed/reported and effectively communicated amongst relevant parties?

ACT 1. Are there effective arrangements for auditing and monitoring performance?

2. Is any health improvement plan up to date and being managed accordingly? Has any remedial action taken addressed the deficiencies identified?

3. Are IH procedures undergoing regular review, and have they been amended because of accident/incident outcomes? Are they suitable/sufficient and understood by relevant personnel?

Appendix 2 Application of EMM and Dutyholder Performance Assessment When inspecting the health risk management dutyholder compliance is to be assessed against the relevant success criteria. The success criteria have been determined from specific regulatory requirements, defined standards, established standards or interpretative standards.

This assessment will determine the: EMM Risk Gap, the associated topic performance score together with the Initial Enforcement Expectation as shown in the table below.

The actual enforcement may differ from that consistent with the recorded topic score depending on dutyholder and strategic factors. However, should this occur then the relevant dutyholder and strategic factors should be identified in the inspection report. The Topic Score recorded on COIN must be consistent with the Initial Enforcement Expectation

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

EMM RISK GAP EXTREME SUBSTANTIAL MODERATE NOMINAL NONE NONE TOPIC PERFORMANCE SCORE 60 50 40 30 20 10 Broadly Unacceptable Very Poor Poor Fully Compliant Exemplary Compliant Significantly below Meets most of the Unacceptably far the relevant relevant minimum Exceeds the below relevant Meets the relevant minimum legal legal relevant minimal minimum legal minimum legal Substantially below requirements. requirements. legal requirements. requirements. the relevant requirements. minimum legal Several success Most success Most success All success criteria requirements. criteria are not criteria are fully All success criteria criteria are not are fully met. fully met. met. are fully met. met. Many success Management criteria are not fully Degree of non- Degree of non- Management Degree of non- competent and met. compliance compliance minor competent, compliance able to significant. and easily enthusiastic, and extreme and demonstrate Degree of non- remedied. proactive in widespread. adequate compliance Limited devising and identification of the substantial. recognition of the Management implementing Failure to principal risks, Failures not essential relevant recognise effective safety recognise issues, implementation of recognised, with components of essential relevant management their significance, the necessary limited commitment effective health components of system to ‘good and to control measures, to take remedial and safety effective health practice’ or above demonstrate confirmation that action. management, but and safety standard. Actively adequate these are used demonstrate management, and seek to further commitment to effectively; and commitment to commitment to improve take remedial subject to review. take remedial improve standards. action. action standards. EMM INITIAL ENFORCEMENT EXPECTATION Prosecution / Enforcement Notice Enforcement Letter / Verbal None. None. Enforcement / Letter. Notice / Letter. warning. Notice.

It should be noted that:

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

• the IG and hence the allocated scores may not cover all the matters that were considered during the intervention.

• the intervention may not necessarily have used every part of the IG – consequently the score only reflects what was inspected. The inspection report should make it clear what aspects of the IG the dutyholder has been scored against (or it is clearly identifiable by a letter item).

• where the score only relates to limited aspect of the IG then consideration should be given to consulting the IG owner before finalising the score.

• proposed inspection scores should be reviewed/discussed by the full inspection team before finalising.

• the allocated performance score only reflects regulatory judgements about a duty holder’s degree of compliance at a particular point in time.