Rog's reflections

15 December 2015

Rog Thomson from HSE Energy Division shared with us his reflections on key lessons learned in his role as team lead for the joint HSE-DECC project to deliver the UK Competent Authority and implement the 2015 Safety Case Regulations.

His excellent presentation includes some important lessons learned to assist duty holders transitioning to the new regime (p10), and also summarises how the joint assessment process has been updated.

Rog Thomson 

Probably more relevant, especially for OSH Professionals not directly involved in UK offshore Safety Case submissions, are Rog’s reflections on how to respond to an unexpected request to take on a very challenging project. In this case key factors included:

  • Very challenging timescale, with failure to deliver not an option (either personally, or for the UK regulators – as not meeting the mid-July implementation date would result in infraction proceedings by the European Commission, as some other member states are now finding out (and eventually significant EU non-compliance fines).

  • The project team came from two very different organisations, there was little history of joint working, both were accountable to senior politicians for different aspects of the transposition in to UK law and each was advised by their own lawyers whose views didn’t always align.

Does any of that sound familiar for some oil & gas sector projects? If so, Rog’s reflections may have useful lessons for you – either personally, or to communicate to others.

Karen McDonald

A final point is that most IOSH members are expected to record summaries of our personal professional development plans and experiences. Rog’s reflections are an excellent example both of how this can be done and the benefits that can result – whether it’s new lessons that have been learned or just reinforcement of old ones.

In addition to his presentation Rog responded helpfully to questions raised. Points mentioned, not covered in much detail in his slides, include:

  • The linked guidance to SCR 2015 should be available in January 2016. There will be minimal changes to the current ‘draft guidance’ issued in July 2015. Most relate to clarity of wording, so as to avoid misunderstandings identified by the some submissions and assessments to date.

  • The 2005 SC Regulations will continue in force for ‘internal waters’, e.g. estuaries, because DECC are not the regulator for these. But the Safety Case requirements are essentially the same.

  • The revised incident online reporting portal will be operational from early 2016.

A very stimulating network meeting and, I suggest, well worth your time to review the presentation.

Ian Waldram, CFIOSH