19 Through Life Safety Management

Health, Safety and Environment Quality (HSEQ) documentation including a Safety Management System (SMS) will be in place for the Array and will be continually updated throughout the development process. The following subsections provide an overview of this documentation and how it will be maintained and reviewed with reference, where required, to specific marine documentation. For the purposes of the Risk Assessment in Section 16 it has been assumed that these measures will be in place.
Monitoring, reviewing, and auditing will be carried out on all procedures and activities and feedback actively sought. Any designated person (identified in HSEQ documentation), managers, and supervisors are to maintain continuous monitoring of all marine operations and determine if all required procedures and processes are being correctly implemented.

19.1 Incident Reporting

After any incidents, including near misses, an incident report form will be completed in line with the HSEQ documentation. This will then be assessed for relevant outcomes and reviewed for possible changes required to operations.
The Applicant will maintain records of investigation and analyse incidents in order to:

determine underlying deficiencies and other factors that may be causing or contributing to the occurrence of incidents;
identify the need for corrective action;
identify opportunities for preventative action;
identify opportunities for continual improvement; and
communicate the results of such investigations.

All investigations shall be performed in a timely manner.
A database (lessons learnt) of all marine incidents will be developed. It will include the outcomes of investigations and any resulting actions. The Applicant will promote awareness of their potential occurrence and provide information to assist monitoring, inspection and auditing of documentation.
When appropriate, the designated person (noted within the ERCoP should inform the MCA of any exercise or incidents including any implications on emergency response. The MCA will be invited to take part in incident debriefs should they request.

The Applicant will be responsible for reviewing and updating all documentation including the risk assessments, ERCoP, SMS and, if required (i.e. if requested by the MCA), will convene a review panel of stakeholders to quantify risk e.g. via a Hazard Workshop process.
Reviews of the risk register should be made after any of the following occurrences:

A review of potential risks should be carried out annually. A review of the response charts should be undertaken annually to ensure that response procedures are up to date and should include any amendments from audits, incident reports and identified deficiencies.

All vessels, facilities, and equipment necessary for marine operations associated with the Array are to be subject to appropriate inspection and testing to determine fitness for purpose and availability in relation to their performance standards. This will include monitoring and inspection of all aids to navigation to determine compliance with the performance standards specified by NLB.

Auditing and performance review are the final steps in HSEQ management systems. The feedback loop enables an organisation to reinforce, maintain and develop its ability to reduce risks to the fullest extent, and to ensure the continued effectiveness of the system. The Applicant will carry out audits and periodically evaluate the efficiency of the marine safety documentation.
The audits and possible corrective actions should be undertaken in accordance with standard procedures and results of the audits and reviews should be brought to the attention of all personnel having responsibility in the area involved.

The Applicant will manage the risk associated with the activities undertaken at the Array. An integrated SMS, which ensures that the safety and environmental risks of those activities are ALARP, will be established. This includes the use of remote monitoring and switching for aids to navigation to ensure that if a light is faulty then a quick fix can be instigated, which will allow IALA availability requirements to be met.