First let’s start by clarifying our terms. The definition of Combined Operations (COMOPS) is when at least two installations with distinct and approved safety cases enter a joint operation. Before that operation can begin a COMOPS Notification or CON must be submitted to the Offshore Safety Directives Regulator (OSDR) at least 21 days in advance. The CON doesn’t need to be accepted by the OSDR (hope you’re keeping up!), but they can – and they often do – raise concerns.
Figuring out whether any individual operation even qualifies as a COMOPS is not always as straightforward as you might think.
So, when is a COMOP not a COMOPS? Look at the following situations and decide if they qualify as COMOPS. You can find the answers at the end of this post.
- Normally unmanned installation and a heavy lift vessel?
- Normally unmanned installation and an accommodation vessel?
- Manned installation and a jackup drill rig?
- Manned installation and a DSV conducting diving operations?
Having prepared many CONs there are some key learnings I’ve discovered (mostly the hard way) that I’d like to share:
- Collaboration. The regulations require a joint effort between all duty holders. This includes the preparation of the CON itself but they also expect evidence of attendance at and contribution to key risk assessments and table top reviews. It’s often appropriate for one duty holder to take the lead on such matters – but all parties need to demonstrate involvement. To set yourself up for success, construct up a RACI table for the primary activities and identify the right personnel and timings for review of key documentation.
- Actions. If you intend to submit a CON whilst you have safety actions still outstanding, be very clear about when these will be closed and how they will be verified. The regulator can, and does, request safety action responses if they aren’t satisfied.
- HSE Website. Regulation guidance, a CON framework, inspection templates and assessment principles can all be downloaded from the HSE’s website. These resources are invaluable and worth using as they outline the criteria upon which you will be assessed.
- New SECEs. Some of the new equipment on the combined installation that is considered safety critical may be considered as Safety and Environmentally Critical Elements (SECE). These require clear performance standards and for a verification scheme to be developed. The duration of the campaign may be short enough that only initial suitability is required. Specific COMOPS SECEs may include the gangway and its connection, personnel on board (POB) tracking and links between emergency shutdown (ESD) systems.
- Personnel on Board (POB). The CON should clearly outline the intended POB during normal operations as well as the maximum allowable POB. The POB on each of the installations involved must be clearly defined. This is particularly important where there is a single gangway that connects installations and the basis of this POB limit, for example a PFEER Reg 5 assessment, should be made clear. Be aware these numbers may change throughout the operation as the risk profile changes. The gangway may be a common point of failure across both means of evacuation so make it clear how you intend to protect it.
If you’ve got an experience you’d like to share on CONs – or have more to add to this list of factors to be aware of -I’d like to hear from you. Please add your comment below. You can find more information in Regulation 3 of MAR as well as Reg 22 of SCR2015.
Oh, and the answers to the quiz are here: 1 – No; 2 – Yes; 3 – Yes; 4 – No.
Please visit www.salus-technical.com to find out how we can help you to better understand your risks from dropped objects during COMOPS.