SARS-CoV-2 is now an offshore health hazard, no different from legionella, NORM or asbestos. While the offshore sector is better-prepared for infectious incidents than most industries, there will be challenges managing a phased post-pandemic return to work over the coming months.

COSHH does not specifically apply to COVID19. But operators must undertake and document a formal review of risk assessments as required under Regulation 3(3) Management (Health and Safety at Work) Regulations on the basis that it’s reasonable to consider that there has been a “significant change in the matters to which it relates”.

It should be noted that review of existing risk assessments alone is unlikely to be sufficient given the highly transmissible nature of the virus: you will usually require to extend the scope or extent of your existing risk assessments to cover additional work activities and locations previously considered to present negligible risk and not warranting risk assessment.   

To add insult to injury, with challenges to PPE supply chains continuing, there is every chance that operators and contractors may need to get used to working without the same level of reliance on PPE as before.

For the offshore sector the main pressure relates to availability of disposable or half-mask respirators. But the HSE has given a strong signal1 that the strain on the PPE supply chain must not be allowed to impact on worker health. Instead HSE recommends that employers identify what other control measures could be implemented:

  • Urgently review existing COSHH risk assessments
  • Start at the top of the hierarchy of control and look at process/product changes
  • Can you really argue that your working practices cannot be improved as regards releases to air?
  • Are you making best use of local exhaust ventilation to reduce reliance on RPE?

Occupational hygiene is the applied science of assessing and controlling workplace health hazards, whether chemical, physical (or viral). DNS member Ethos Environmental has more offshore-certified hygienists than any other company and has been serving the North Sea sector – exploration, production and decommissioning - since 1996.  We provide the following third-party services relevant to the post-pandemic challenges offshore: 

  • Desk-top or on-site review of your risk assessments (COSHH Reg 6/MHSWR Reg 3)
  • Audit your working practices and PPE management policy
  • Test your air management/ventilation system (ATTMA-certified)
  • Monitor the workplace air to verify exposure controls are adequate (COSHH Reg 10)
  • Test and inspect local exhaust ventilation systems (COSHH Reg 9)

Senior Occupational Hygienist, Dr Brian Gardner comments: “You must expect that your performance in managing risk during this period will be subject to close scrutiny; in our experience few offshore activities actually survive challenge to their COSHH or hygiene risk management standards. For example, having just completed a major 12-month review for one North Sea operator it is clear that the box-ticking and database-led COSHH management approach (so common throughout this sector) is simply not fit-for-purpose” 

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