Guidance on the provision of accommodation on offshore installations

Guidance on the provision of accommodation on offshore installations Document Identification: Operations Notice 82 (Rev 3) Publication Date: August 2022 Review Due: August 2025 Target Audience: All stakeholders Internal Reference: 2019/55626 Document Owner: HSE ED5 IH

Introduction

1. This Notice provides guidance on the provision of accommodation on offshore installations to comply with the requirements of Regulation 12 and Schedule 1 of the Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996 (DCR)1.

2. It clarifies the terms “bed design”, “sufficient beds”, “overcrowded”, “adequate space”, “reasonable privacy and comfort”, “continuous improvement”, “temporary use” and “welfare impact assessment”.

3. ON82 (Issued May 2019) is now withdrawn.

Background

4. DCR Regulation 12 and Schedule 1 paragraphs 59-66 contain requirements for accommodation standards offshore. These specify that sleeping accommodation must contain sufficient beds; must not be overcrowded; must contain adequate storage space and allow reasonable privacy and comfort.

5.. When making any changes to accommodation, especially if this increases the number of persons on board (POB), operators must continue to comply with all relevant legal requirements. In particular:

• Offshore Installations (Safety Case) Regulations 2005 or Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015, as appropriate2, Duty holders will need to keep the safety case up to date to reflect the change in persons on board (POB). Where the changes make a material change to the safety case, then the safety case with the proposed revisions must be sent to HSE for assessment and the safety case must be accepted by HSE before the changes are brought into effect.

• The Offshore Installations (Prevention of Fire and Explosions, and Emergency Response) Regulations 1995 (PFEER)3 Duty holders should ensure appropriate arrangements are in place for evacuation, escape and rescue e.g., that there are sufficient lifeboats, life rafts and survival personal protective equipment (PPE) sets, that muster points and temporary refuges are large enough and that there is sufficient emergency helicopter capacity.

• The Offshore Installations and Wells (Design and Construction, etc)1 Regulations (DCR)1996 and the Offshore Installations (also L85 Guidance for DCR) 10 and Pipeline Works (Management and Administration) 4 Regulations (MAR) 1995 Duty holders should ensure adequate welfare arrangements including the provision of adequate galley facilities, access to drinking water, sufficient lockers, rest rooms and recreational facilities for everyone.

• Offshore Installations (Safety Representatives and Safety Committee’s) Regulations 19895 Duty holders should consult with their workforce and safety representatives and take account of the results before implementing any changes to accommodation.

Provision of accommodation offshore

6. Any room designated as sleeping accommodation - (a) must not be overcrowded; (b) must contain adequate space for the occupants to store their clothes; and (c) shall, so far as is reasonably practicable, be occupied only by such number of persons as is consistent with reasonable privacy and comfort, having regard to the features of the room.

Continuous Improvement

7. The DCR requirements allow for continuous improvement in accommodation standards on offshore installations, the HSE expectation is for operators to align to this philosophy. In the interests of health and welfare, the provision of sleeping accommodation should be consistent with the goal of continuous improvement and should be based on the principles of adequate space, quality and privacy.

Bed design

8. Sleeping cabins should be provided with a platform bed (a mattress resting on a solid, flat raised surface, either free-standing or part of the structure of the sleeping cabin). Beds can be arranged side by side or tiered with the lower bed in a tier at least 300 mm above the deck. Head clearance above each bed should be at least 610 mm and preferably, 810 mm. Beds should be provided with individually operated privacy curtains. Bed mattress sizes

should be at least 1900 mm by 900 mm. These dimensions are consistent with established standards such as the ABS - 105 Guide for Crew Habitability on Offshore Installations 20166 and Norwegian NORSOK Standard C-0017.

Sufficient beds

9. There should be sufficient beds or bunks for the number of people expected to sleep on the installation. No person should be required to share a bed (hot bunking). Changing the mattress and/or bedding to allow two people to share a bed or bunk is considered as 'hot bunking'.

Overcrowded

10. Overcrowding can mean restricted access to facilities, lack of privacy, difficultly in maintaining hygiene, disturbance of rest and sleep, which could increase fatigue and poor mental health. Overcrowding can also restrict the ability of the occupants to respond properly in the event of an alarm or emergency.

11. The minimum floor area in a sleeping cabin (exclusive of bathroom unit) should be 4.5 square metres for a single occupant and 9.0 square metres for two/three occupants. The height of a cabin should be at least 2.3 metres. Sleeping cabins with a floor area less than 9.0 square metres will normally not allow reasonable access, for two occupants, to the facilities within the room at the same time. However, these rooms may be occupied by one person on day shift and a second person on night shift provided the layout and features of the room allow for reasonable access to the facilities within the room during single occupancy.

12. Minimum area per occupant is derived from the established standard in the 4th Edition Guidance Note8 and is consistent with other established standards such as the Norwegian NORSOK Standard C-001 (single cabin, inclusive bathroom unit: 6 m², double cabin, inclusive bathroom unit: 12 m²) and the ABS Guide for Crew Habitability on Offshore Installations 2016 (single cabin: 7.0 – 8.5 m², double cabin: 8.0 – 10.0 m²).

13. Each person should have adequate lockable storage space.

Privacy and comfort

14. On exploration and production installations, single or double occupancy cabins are good practice in terms of a 21st Century approach, although, where cabin design permits (dimensions and layout), reasonable privacy and comfort, could be provided when a cabin

is allocated to a maximum of three people, based on two people working days, with the third person working nights, nominally known within the offshore industry as “2+1”.

15. HSE will not accept safety case submissions for new installations requesting the use of 2+1.

16. Any proposed use of 2+1 cabins can only be used on a defined temporary basis. Duty Holders should provide justification for any critical/exceptional circumstances to move to 2+1 cabins as part of a safety case material change. If the use of 2+1 is already in an accepted safety case, then DH should produce a welfare impact assessment (WIA) for each temporary use in consultation with the elected safety reps (ESR), the workforce and shared with the designated HSE IMT/Focal point inspector prior to each use. This would include an assessment of what other options have been considered and why they are not deemed feasible. HSE will inspect 2+1 arrangements as defined in the WIA and investigate any concerns raised by the workforce and take appropriate enforcement action where required.

Temporary Use

17. This would detail specific start and finish dates for the use of 2+1 cabins, ensuring they are not used for normal operating parameters (as stated in the duty holder’s safety case), and be in line with any identified critical or exceptional circumstances, for example: short duration projects, Shutdowns, turnarounds (TARs) etc. Companies should strive towards minimising these cabin arrangements as much as possible.

Welfare Impact Assessment

18. The requirement that any room designated as accommodation should not be overcrowded covers more than just the number of people who use the room and the level of occupancy. As well as providing adequate space for the occupants to store their clothes, it may be helpful to consider the following: there needs to be sufficient space to allow for reasonable access to the facilities within the room; disturbance to sleeping occupants by others using the facilities within the room, or using the adjacent corridors and rooms, needs to be avoided so far is as reasonably practicable; and allowance needs to be given for the room to be cleaned at suitable intervals without disturbance to sleeping occupants.

19. The WIA should be carried out by identifying and evaluating the potential long-term hazards and risks by assessing against the regulations noted above. This would include the following topics (not exhaustive). Identify the justification for any critical/exceptional circumstances to move to 2+1 cabins as part of a material change. What other options have

been considered and why they are not deemed feasible? What are the impacts for proposed changes to the offshore workforce in terms of welfare, mental health, team working, morale and fatigue? Assess the adequacy of sleeping accommodation, privacy & comfort, cabin design, proposed space and facilities including personal lockers. Assess the adequacy of washing facilities, showers, toilets, washbasins, basic utilities, sewage, water, ventilation, laundry, cleaning etc. Review the adequacy of any recreation space on-board for relaxation etc. Finally ensure there is meaningful workforce involvement and consultation in any decision making.

20. On Flotels and other accommodation support vessels, reasonable privacy and comfort will be provided when a cabin is allocated to a maximum of two persons during a 24-hour work/rest period, as is standard in the marine industry. Hence the “2+1” arrangement is not acceptable in these circumstances.

Sleeping cabins for men and women

21. Operations Notice 779 explains HSE’s policy and role in the inspection and enforcement of the requirement for separate cabins for men and women on offshore installations.

Provision of accommodation on normally unattended installations (NUI) or not permanently attended installation (NPAI)

22. For NUI/NPAIs where no overnight stays are planned, there should be adequate welfare facilities for the number of workers likely to be present. Sufficient emergency accommodation should also be provided to account for the rare occasion when planned departure from the installation cannot be achieved. Temporary beds are acceptable for unplanned stays on NUI/NPAIs.

23. Where planned overnight stays are required; accommodation arrangements in line with those required for permanently attended installations should be provided.

Enforcement approach

24. In applying DCR, complaints or matters of evident concern relating to accommodation will be investigated in accordance with HSE procedures.

References

1. Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996 SI 1996/913 2. Offshore Installations (Safety Case) Regulations 2005 SI 2005/3117 and Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015 SI 2015/398 3. Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995 SI 1995/743 4. Offshore Installation and Pipeline Works (Management and Administration) Regulations 1995 SI 1995/738 5. Offshore Installations (Safety Representatives and Safety Committee’s) Regulations 1989 SI 1989/971 6. American Bureau of Shipping: 105 Crew Habitability on Offshore Installations 2016 7. NORSOK Standard C-001 Living Quarters Area (3 May 2006) 8. Offshore installations: guidance on design, construction and certification (fourth edition) HMSO 1990 (withdrawn) 9. HSE Operations Notice 77 Offshore accommodation standards - men and women sharing cabins. Revised and reissued August 2017 Open Government Status: Open (hse.gov.uk) 10. A guide to the integrity, workplace environment and miscellaneous aspects of the Offshore Installations and Wells (Design and Construction etc) Regulations 1996. Guidance on Regulations L85 (hse.gov.uk)

This guidance is issued by the Offshore Major Accident Regulator (OMAR). Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance, you will normally be doing enough to comply with the law. Inspectors seek to secure compliance with the law and may refer to this guidance as illustrating good practice.