Lesson Details
Many useful learning points came out of the technical exchange meetings. Not all of these are directly related to the
offshore safety cases, but may be useful for decommissioning so are included here:
a. Be pro-active in communicating with the regulator, i.e. engage early on with the regulator, sharing plans for
decommissioning to get feedback
b. Ideally plan for decommissioning early, developing a baseline plan; to try and reduce wasted effort and costly
mandatory revisions to OSC and supporting studies
c. The high level ‘decommissioning programme’ plan should be supplemented by individual topic plans e.g. safety
case plan. The rate of change of drawings and documents (safety case, risk assessments, emergency route
drawings etc.), which can be rapid, should be planned for
d. Align decommissioning phases with the project gates / work breakdown structure
e. Decommissioning should be viewed as part of the operational life cycle of the asset, not as a separate project in
isolation
f. Engage contractors early to avoid last minute changes in how activities involved in decommissioning are carried
out (e.g. number of vessels) as these might require a safety case rewrite. (The challenge is to freeze the
engineering scope)
g. Prioritise communication internally between relevant parties to ensure awareness of each team’s activities
which may impact on the decommissioning process
h. Try and alter corporate procedures to include decommissioning aspects rather than creating project-specific
procedures for decommissioning which may be in conflict with the corporate operational procedures
i. It is important to maintain the correct safety culture and awareness of process safety risks during
decommissioning when there may be significant changes in POB and crews. (Weekly sessions can provide a
mechanism for engagement and communication, particularly about process safety hazards)
j. Duty holder-ship may be transferred to contracted parties during decommissioning, but a high level of due
diligence is required to ensure that the contractor is fulfilling the duty holder’s obligations. The duty holder
remains legally responsible
k. Ensure there is interaction between the different verifiers (ICP, marine warranty surveyor etc.) so that all
equipment is covered by verification and there are no gaps
l. It can be advantageous to have fully autonomous platform Technical Authorities (TAs) who are dedicated to
(and therefore focused on) the asset / decommissioning
m. Avoid adopting a lesser standard for different phases in the lifecycle, (e.g. helicopter flights in later phases may
be from a different regulatory sector – there are different standards for emergency breathing systems for
offshore helicopter occupants in different sectors. They must comply with the UK regulations regardless of
where they are flying from)
n. A report listing obsolescent equipment and what is available for re-sale can be useful if an operator wishes to
reuse equipment on one of its other assets
o. Rigorously test emergency response arrangements ahead of offshore campaigns, recognizing that for the
operators ERP the arrangements during dismantling may be quite different from the producing installations
they support