Document type

Senior management should ensure the SMS is reviewed at planned intervals to ensure its continuing suitability, adequacy and effectiveness. Reviews should include assessing opportunities for improvement and the need for changes to the SMS, including the safety policy and objectives. Input to reviews (which should be carried out by independent third parties) should include

Results of internal audits and evaluations of compliance with legal and other requirements

The results of worker participation and consultation

Relevant communications from third parties

The safety performance of the petroleum undertaking

The extent to which safety objectives have been met

The status of incident investigations, corrective and preventive actions

Followup actions from previous reviews

Changing circumstances, including developments in legal and other requirements related to safety and

Recommendations for improvement. The outputs from the reviews should be consistent with the petroleum undertaking’s commitment to continual improvement and should include any decisions and actions related to possible improvements. Relevant outputs from the review should be made available for internal and external communication and consultation as appropriate.
4.6.6.1 Incident Investigation
The Petroleum Incident Regulations define those incidents that must be reported to the
CER. This section covers the safety case requirements for the SMS in relation to all incidents. The safety case must demonstrate that procedures are in place to record, investigate and analyse incidents (including near misses and unsafe conditions) in order to

Determine underlying safety deficiencies and other factors that might be causing or contributing to the occurrence of incidents

Identify the need for corrective action

Identify the need for improved risk reduction measures and

Communicate the results of such investigations throughout the organisation as appropriate to enable lessons to be learned. The safety case should demonstrate how investigations are performed in a timely manner and the results documented and maintained. The safety case will describe the system of classifying and categorising incidents that has been adopted so that a suitable response is demonstrated, using persons at the appropriate level of seniority and with the necessary expertise. Investigations need to be thorough enough to establish both the immediate and underlying causes. A phased approach should be adopted with the onsite investigation being carried out to collect evidence, followed by

the collection of offsite evidence and the laboratory analysis of components and materials removed and finally an interpretation of the findings to establish the cause. The safety case must demonstrate that investigations provide an adequate basis for determining the level of risk and are commensurate with the severity of the potential consequences and not just the actual consequences.
4.6.6.2 Non-conformities and Corrective Actions
The safety case will document procedures for dealing with actual and potential non- conformities with the SMS and for taking corrective and preventive actions. The procedures should define requirements for

Evaluating the need for actions to prevent non-conformities and implementing appropriate actions designed to avoid their occurrence

Identifying and correcting non-conformities and taking action to mitigate their safety consequences

Investigating non-conformities, determining their causes and taking action to avoid their recurrence

Recording and communicating the results of corrective actions and preventive actions taken and

Reviewing the effectiveness of corrective actions and preventive actions taken.

Download 0.73 Mb.

Share with your friends: