Professional Documents
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ukcsmal002_iss1
ukcsmal002_iss1
ukcsmal002_iss1
Contents
Paragraph Page
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1 Scope 1
2 Diving Standards 1
3 Responsibilities 2
3.1 Business Units and Project Groups 2
3.2 BP Upstream Technology Group Subsea Team 2
3.3 Third-party Contractors and Other Operators 3
Figure
1 Essential Elements of a Diving and Subsea SMS 4
Addendum 1 References
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Diving and Subsea Operations Practice UKCS-MAL-002
Issue Authority
Name: Jon Turnbull
Signature: ________________________________________________
Date: ________________________________________________
Technical Authority
Name: Norman Taylor
Signature: ________________________________________________
Date: ________________________________________________
Amendment Record
AMOSAF.171
Amendment Summary
Distribution List
Virtual Copyholders
Copy Copyholder
Copy Copyholder
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15 ERC, Dimlington
16 ERC, Theddlethorpe
17 ERC, CATS Terminal, Teesside
18 ERC, Wytch Farm
19 ERC Admin, Dyce Emergency Response Centre
20 Finnart, ADCO, Grangemouth (Eric Brown)
21 Dive Co-ordinator, Grangemouth (Tony Pollock)
22 HSE Team Leader, BBM (Paul Everest)
23 HSE Team Leader, BP Norway (TBA)
24 HSE Team Leader, CNS Gas (Trevor Stapleton)
25 HSE Team Leader, EoS (Brian Stewart)
26 HSE Team Leader, FACTS (Ann Rosbrook)
27 HSE Team Leader, GFU (Allan McCulloch)
28 HSE Team Leader, Grangemouth (TBA)
29 HSE Team Leader, Harding (Gordon MacLeod)
30 HSE Team Leader, Ninian (TBA)
31 HSE Team Leader, Northern Export System
(John Robertson)
32 HSE Team Leader, SNS (Stuart Harrower)
33 HSE Team Leader, UKX and Faroes (Mike George)
34 HSE Team Leader, UTG
35 HSE Team Leader, WoS (Fraser Bell)
36 HSE Co-ordinator, Bacton
Copy Copyholder
Copy Copyholder
63 OIM, Magnus
64 OIM, Miller
65 OIM, Montrose
66 OIM, North Everest
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67 OIM, Ninian Central
68 OIM, Norway Gyda
69 OIM, Norway Ula
70 OIM, North West Hutton
71 OIM, Ravenspurn
72 OIM, Schiehallion
73 OIM, Thistle
74 OIM, West Sole Alpha
75 Onshore Control Centre, GFU Forties Pipeline Control Centre
76 Onshore Control Centre, SNS Great Yarmouth Control Centre
77 Pipeline Consultant (Alastair McLachlan)
78 Principal Subsea Engineer, UTG (Ian Mitchell)
79 SNS Subsea Engineer (John Gilligan)
80 Stolt Offshore Engineer, UTG (Simon Hounsome)
81 Subsea Controls Engineer, UTG (Mike Hillier)
82 Subsea Controls Engineer, UTG (Martin Pritchett)
83 Subsea Controls Engineer, UTG (Keith Williams)
84 Subsea Engineer, BBM Bruce (Katherine Low)
85 Subsea Engineer, UTG (Stuart Brooks)
86 Subsea Engineer, UTG (Terry Hall)
87 Subsea Engineer, UTG (Jonathan Harker)
88 Subsea Engineer, UTG (Colin Ladd)
89 Subsea Engineer, UTG (Les Sutherland)
Copy Copyholder
Preface
Purpose
The purpose of this document is to define the BP standards and expectations regarding the
arrangements which must be in place when a BP UKCS Business Unit or project group
manages a project requiring diving or subsea operations.
This document also describes the key issues that must be considered by personnel involved in
the management and control of a diving or subsea project or operation, and outlines the
essential requirements of a diving and subsea safety management system.
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Responsibility of Copyholders
It is the responsibility of the registered copyholder of controlled hard copy versions to
maintain the accuracy of the document by ensuring that all updates are promptly
incorporated and acknowledged.
Furthermore, the registered copyholder of controlled hard copy versions must at all times
maintain custody of this document unless prior approval is given by the relevant
Technical Authority.
The roles and responsibilities of copyholders and ‘virtual’ copyholders are detailed in Section 1
of the Document Control Procedure (UKCS-DCM-001).
1 Scope
This diving and subsea practice shall be used in conjunction with other BP Health,
Safety and Environment (HSE) policies, practices and procedures and at all BP sites;
inland, inshore and offshore.
This practice may also be used at BP sites worldwide where no other guidance exists.
2 Diving Standards
To assure BP Business Units (BUs) or project groups that any work undertaken by
a contractor supplying diving or subsea services, direct or through third parties,
meets BP expectations, the following must be enforced:
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3 Responsibilities
3.1 Business Units and Project Groups
Business Units and project groups are responsible for the safe management of diving
and subsea projects. Their responsibilities include:
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• Operating in compliance with this practice and ensuring its implementation
• Verifying that third parties operating within a BP sphere of influence accord with
this practice
• Justifying, by a demonstrable risk management process, deviations from this practice
• Participating in all phases and elements of the diving and subsea project
• Providing a safe place of work to support diving and subsea projects by
communicating all relevant information for that site, including the following topics:
- Hazard Identification (HAZID)
- Work control systems
- Simultaneous operations
- Emergency response
- Communications
4.1 Compliance
Any diving or subsea operation undertaken by a contractor, direct or through
third parties, shall meet the standards detailed in Paragraph 2 of this practice.
4.2 Planning
Communicating Expectations
At the start of and throughout a diving or subsea project, it is essential that
BP expectations on policies and practices be communicated to all key personnel.
UKCS-MAL-002
COMPLIANCE PLANNING PERFORMING MEASURING AND IMPROVING
COMMUNICATING
EXPECTATIONS
Figure 1 Essential Elements of a Diving and Subsea SMS
ROLES AND
RESPONSIBILITIES
SITE RULES
COMPETENCY
ASSESSMENT
PROCESS
RISK
HSE OVERVIEW
ASSESSMENT
NATIONAL
AUDIT PLAN
REGULATIONS
PROGRESS
COMMERCIAL
REPORTING
RISK
ASSESSMENT
ACCIDENT
INVESTIGATION AND
REPORTING
EMERGENCY
March 2001 Issue 1
RESPONSE PLAN
MANAGEMENT
OF CHANGE
UKCSMAL002_001.ai
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Diving and Subsea Operations Practice UKCS-MAL-002
Audit Plan
An audit plan for the diving or subsea operation shall be developed. As a minimum the
contractors’ management systems, vessels, plant and equipment shall be audited to
BP and industry standards prior to work commencing.
Information Validation
A system shall be in place to ensure that all information at the worksite is current and
valid. All relevant documents, including their revision status, should be listed in the
bridging document.
Risk Assessment
All activities including workscopes, generic and specific procedures must be subject to a
formal risk assessment process during the planning phase. The process will identify any
requirement to change the workscope and procedures and/or any mitigating measures
to be applied. The process should employ the diving or subsea contractor’s SMS with
active involvement from all parties whose acts or omissions could adversely affect the
health and safety of persons engaged in the project or could affect plant, equipment or
the environment.
Management of Change
The diving and subsea contractor must have a documented system to manage change.
The management of change procedure will define how change is implemented,
who is authorised to approve levels of change and how any appropriate risk reducing
measures are applied.
Bridging Document
No diving or subsea project can commence until an authorised bridging document has
been issued. The bridging document is the interface between BP and other parties
SMSs. It provides a project overview, operational detail for an emergency response and
outlines how the SMS requirements have been met. A separate bridging document will
be required for each phase of a diving or subsea project or major element of work.
Key personnel and response organisations must receive controlled copies.
4.3 Performing
Site Rules
Site rules that define the specific arrangements to manage and control diving and subsea
projects safely shall be developed. This will include HAZID, work control systems,
simultaneous operations review, emergency response and communications.
Risk Assessment
Formal onsite risk assessments must be conducted for all elements of the project
including the review of generic risk assessments, job safety analysis, personnel risk
assessments and routine maintenance activities.
Safety Briefings
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Briefings on BP expectations, policies and practices are to be given to all personnel
involved in the operations, including marine crew and third parties. A system of general
safety briefings, safety meetings and toolbox talks must be carried out and recorded.
Appropriate site orientation, induction and project specific training that includes site rules
and emergency procedures shall be undertaken to clarify roles, responsibilities and
actions. All personnel should attend the briefings and training, and an attendance register
maintained.
Progress Reporting
A process of regular communications between the key parties shall be in place to report
project progress, including safety, operational and technical issues.
HSE Overview
HSE data including a summary of accident, incident and near miss reports from BP and
subsea contractors or other parties associated with the project shall be collated. The
conduct and culture of contractors and other parties should be reviewed and issues
raised in order to improve standards and compliance with requirements.
Operational Issues
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Technical Issues
As-built and closeout documentation will be used to revise BP documentation. Relevant
documentation must be updated immediately if any changes affect diving and subsea
operational safety.
Commercial
An itemised outline breakdown of costs and expenditure should be recorded for
reference and audit purposes.
Addendum 1
References
Paragraph Page
References
March 2001 Issue 1 Add 1-i/ii
Diving and Subsea Operations Practice UKCS-MAL-002
(8) Health and Safety (Display Screen Equipment) Regulations, SI 1992/No 2792.
(9) Manual Handling Operations Regulations, SI 1992/No 2793.
(10) Personal Protective Equipment Regulations, SI 1992/No 2966.
(11) Provision and Use of Work Equipment Regulations, SI 1998/No 2306.
(12) Lifting Operations and Lifting Equipment Regulations, SI 1998/No 2307.
(13) Control of Substances Hazardous to Health Regulations, SI 1999/No 437.
(14) Health and Safety Information for Employees (Modifications and Repeals)
Regulations, SI 1995/No 150.
(15) The Offshore Installations and Pipeline Works (First Aid) Regulations,
SI 1989/No 1671.
(16) Noise at Work Regulations, SI 1989/No 1790.
(17) Electricity at Work Regulations, SI 1989/No 635.
(18) Ionising Radiations Regulations, SI 1999/No 3232.
(19) Health and Safety (Training for Employment) Regulations, SI 1990/No 1380.
(20) Offshore Installations (Safety Case) Regulations, SI 1992/No 2885.
(21) Offshore Installations and Pipeline Works (Management and Administration)
Regulations, SI 1995/No 738.
(22) Offshore Installations (Prevention of Fire and Explosion, and Emergency Response)
Regulations, SI 1995/No 743.
(23) Pipeline Safety Regulations, SI 1996/No 825.
(24) Chemicals (Hazard Information and Packaging for Supply) Regulations, SI 1994/No
3247, and subsequent amendments (SI 1996/No 1092, SI 1997/No 1460).
(25) Construction (Design and Management) Regulations (onshore worksites only),
SI 1994/No 3140.
References
March 2001 Issue 1 Add 1-1
UKCS-MAL-002 Diving and Subsea Operations Practice
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(32) OSD Guidance in the offshore of the Reporting of Injuries, Diseases and
Dangerous Occurrences Regulations 1995, SI 1995/No 3163 (L73).
References
Add 1-2 March 2001 Issue 1
Diving and Subsea Operations Practice UKCS-MAL-002
References
March 2001 Issue 1 Add 1-3/4