Page 441 - Offshore Electrical Engineering Manual

428 CHAPTER 1 Introduction to UK DCR Regulations and the Duties

PUWER – demonstrating that equipment meets the requirements of PUWER
may be used as evidence to demonstrate compliance with a particular performance
standard. Conversely, examination of equipment as required by SCR and/or PFEER
in no way confirms it is compliant with PUWER.
PSR – there is an interface between PSR and SCR/DCR. It is likely that some parts of
the pipeline covered by the MAPD under PSR will need to be verified (e.g., risers, pipeline
to 500 m limit, subsea isolation valves, etc.) as they are likely to be identified as SECEs.
Prior to undertaking any tasks contained within the Scheme – the ICP engineer
involved should formally agree, or comment on, the content of the Verification
Scheme. This should be issued whether or not the ICP’s organisation has prepared
the complete Verification Scheme on behalf of the duty holder.
This review should include performance standards, or other acceptance criteria.
When engineers are selected (or proposed in tenders) as ICP or ICP project man-
ager for an installation, they should not have previously worked for the duty holder
or any of his subcontractors on that particular installation.
However, engineers may undertake verification in instances where they have pre-
viously worked for the duty holder (either directly or through a contracting company)
on that particular installation, provided their verification activities do not include the
areas in which they were previously involved.
In general it is important that those carrying out verification work have appropri-
ate levels of impartiality and take cognisance that:

• judgements regarding safety are not compromised,
• they do not verify their own work,
• management lines should be separate from those people whose work they are
checking,
• judgements are not subject to financial or operational incentives

Should this screening process indicate uncertainties regarding independence, this
should be discussed with the duty holder.

MULTIPLE ICPS/INTERFACE WITH OTHER ICPS
When a duty holder, and/or their contractors, appoints more than one ICP organisa-
tion (ICB) for a given installation, duties and scope of the respective ICPs should be
clearly established and agreed before undertaking any verification. It is important
to establish which ICP is responsible for making comment(s) on the duty holder’s
record of SECEs and verification scheme (could be different ICPs, although the pre-
ferred position is that only one ICP should make comment).
When ‘inheriting’ the role of ICP from another organisation(s), consideration
should be given to ensuring that the following documents are made available by the
duty holder prior to handover and acceptance of responsibilities:

• A copy of the Verification Scheme,
• Review comment(s) made by the outgoing ICP on the record of SECEs,
• Any comments in respect of the Verification Scheme made by the outgoing ICP
including any reservations.