Spcenf 45

HEALTH AND SAFETY EXECUTIVE HID SEMI PERMANENT CIRCULAR
Hazardous Installations Directorate SPC/Enforcement/45

Review Date: November 2008 Subject File: 261
Author Section: OSD 5.3 OG Status: Fully Open
Issue Date: November 2006 Version No: 1
STATUS: For Action
To:
All OSD Inspectors (Bands 0-3)
SAFETY CRITICAL ELEMENTS GOOD REPAIR AND CONDITION
PURPOSE
To remind inspectors of the legal framework and provide advice on the sort of
information that they should seek when examining a duty holder’s approach to
ensuring Safety-Critical Elements (SCEs) remain in good repair and condition.
ACTION
1. Inspectors should look for the existence of a well-defined management

system whereby the duty holder can assure himself that each SCE remains in
good repair and condition and that periodic reviews of SCE performance
against clear criteria are undertaken. Sufficient information should be
recorded for the duty holder to ensure that the objectives of the Safety Case
Regulations (SCR) will be met. In addition, verification arrangements should
be in place to regularly test and review this process for each element; those
verification arrangements must themselves be kept under review.
BACKGROUND
2. Health & Safety at Work Act (HSWA) s.2 requires employers to ensure that
any plant which they provide is, and is maintained, in a condition that is so far
as reasonably practicable safe and without risks to health. Provision & Use of
Work Equipment Regulations (PUWER) makes more detailed provision in
respect of work equipment and requires employers to ensure that work
equipment is suitable for the purpose for which it is provided (r.4) and that it is
maintained in an efficient state, efficient working order and good repair (r.5)
[maintenance is defined by the result rather than the means]. Work equipment
will include some, but not all parts of an offshore installation which have been
identified as safety-critical under SCR.
3. HSWA and PUWER require employers to ensure the safety of work

equipment through periodic inspection. Inspections are also required where
work equipment is of a type where safe operation is dependent on its
condition in use or where work equipment is exposed to conditions causing
deterioration which may lead to significant risk to persons (r.6). It is up to the
employer to determine the nature and, often, the frequency of the inspections
required and ensure that those who carry out the inspections are competent
to do so and have the necessary knowledge and experience.
4. Inspectors should note that there is no legal requirement for a maintenance

log, though where there is a maintenance log, the employer has a duty to
keep it up to date (r.5(2)). However, employers have to ensure that the results
of any inspections carried out further to regulation 6 are recorded (r.6(3)) -
these records have to be kept until the results of the next such inspection are
recorded. PUWER guide para 163 indicates what inspection records should
normally include [note that physical evidence is required under r.6(4)].
5. Prevention of Fire Explosion & Emergency Response Regulations (PFEER)

r.19 places similar duties on installation operators and owners in respect of
the construction, suitability and maintenance of certain plant on the installation
provided for the purposes of PFEER. This provision is supplemented by a
requirement to prepare and operate a written scheme for the systematic
examination of such plant by a competent and independent person, and for
recording of the results of that examination. The written scheme is not a
substitute for routine maintenance and test programmes, but provides an
independent check that certain plant complies with relevant PFEER
requirements. PFEER also contains a specific requirement for the
establishment of appropriate standards of performance for certain measures.
6. SCR r.15A requires the duty holder to have a written scheme of verification to
ensure the safety critical elements are suitable and remain in good repair and
condition. A record of the SCEs identified and the proposed verification
scheme are then reviewed by an independent and competent person as a
check on the duty holder’s compliance with legal requirements described
above.
7. Compliance with the Regulatory framework described necessitates that the

duty holder should have criteria against which it is possible for him to evaluate
continuing suitability, good repair and condition. To show compliance, the duty
holder should hold appropriate records relating to the equipment. Some duty
holders claim that their Planned Maintenance System (PMS) stores the
information to show the requirements of the regulations are met. HSE’s
experience is that this is often not the case. Maintenance routines often do not
ask the “right questions” to support equipment condition or availability status,
or the answers are not properly recorded. Below is an outline of the
information which inspectors should seek to show that SCEs are suitable and
remain in good repair and condition. Where enforcement action is thought
appropriate, compliance with PUWER, PFEER, DCR and/or HSWA should be
considered before the duties arising further to the verification requirements of
SCR.
8. Performance standards are often used to define suitability and serve as a test
for whether SCEs remain in good repair and condition. Standards of
performance are used to measure the verification procedures put in place to
comply with PFEER. The PFEER ACoP (para 57) indicates that performance
standards should be measurable and auditable and may be described in
terms of functionality, survivability, reliability and availability. Some of the
PFEER compliance measures will also be SCEs.
9. SCEs will require a formal system of maintenance. It is considered that the

following information is the minimum required to show SCEs remain in good
repair and condition:
Maintenance schedule to describe:
• What components (location, identification)?
• How often?
• What tests, examinations etc.?
Results of the work, in particular:
• Its state (working/any faults/within calibration etc.)
• Down time/repair time (where required to demonstrate availability etc.)
• What action is required to bring into specification
• What action has been taken (i.e. to whom the faults have been reported,
status of remedial work)
SCE specific information:
• What SCE does the routine affect?
• Is the SCE degraded during the maintenance?
• What additional safeguards are taken if a SCE is degraded (e.g. prearranged

precautionary action for foreseeable fire pump outage, gas head outage etc.)
FURTHER INFORMATION
Further information can be obtained from OSD5.3 (VPN 522 6945 or 522 6849)
Further information and guidance can be found in the OSD Enforcement Manual Vol.
2 Chapter 1.

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HEALTH AND SAFETY EXECUTIVE HID SEMI PERMANENT CIRCULAR

Hazardous Installations Directorate SPC/Enforcement/45

All OSD Inspectors (Bands 0-3)

SAFETY CRITICAL ELEMENTS GOOD REPAIR AND CONDITION

1. Inspectors should look for the existence of a well-defined management

3. HSWA and PUWER require employers to ensure the safety of work

4. Inspectors should note that there is no legal requirement for a maintenance

5. Prevention of Fire Explosion & Emergency Response Regulations (PFEER)

7. Compliance with the Regulatory framework described necessitates that the

9. SCEs will require a formal system of maintenance. It is considered that the

Maintenance schedule to describe:

• What components (location, identification)?

• What tests, examinations etc.?

Results of the work, in particular:

• Its state (working/any faults/within calibration etc.)

• Down time/repair time (where required to demonstrate availability etc.)

• What action is required to bring into specification

SCE specific information:

• What SCE does the routine affect?

• Is the SCE degraded during the maintenance?

• What additional safeguards are taken if a SCE is degraded (e.g. prearranged

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