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Ensuring Compliance: Gas Safety Case Development and Risk Mitigation under GSMR

Ensuring Compliance: Gas Safety Case Development and Risk Mitigation under GSMR

Our client operated a range of commercial and domestic dwellings (both fixed and mobile) had been given a HSE improvement notice in relation to the Gas Safety (Management) Regulations (GSMR), and their safety case.

The client had multiple sites across the UK, which operated with predominantly buried Natural Gas pipework, but also used LPG cylinders.

Challenge:

The challenge was to help the client understand the risks associated with their gas safety systems and to carry out a gap analysis on their current procedures and policies to understand where they required support in the gaps found. This included a review of the gas safety case and provision of advice and authoring on the gas safety case and various policies and procedures.

Solution: Gas Safety Case

To address the challenge, Finch used the existing safety case to act as the basis for a gap analysis against GSMR, before assessing other policies and procedures. Following the desktop audit, a list of recommended changes was discussed in meetings with the responsible person and senior management team. Once the changes had been implemented, each site was audited to assess any gaps in the application of the policies and procedures, as well as any equipment issues.

Steps Taken:

  1. Initial Consultation
    • Gather relevant information and procedures from the client about their gas safety and processes which were on-site with the relevant personnel. This included volumes, network makeup (pipework lengths, locations, construction material), and relevant procedures.
  2. Conduct a gap analysis
    • Carry out a gap analysis on the existing gas safety case, procedures, and policies to determine the key actions required to ensure the HSE improvement notice was closed. One item identified was that the drawings and knowledge of the gas network were questioned, which included gas marker posts.
  3. Identify the gas network on the sites
    • Assisted with a programme of excavations to confirm the location of buried pipework, and identify key gas equipment such as LPG cylinders, tanks, meter housing etc.
  4. Conduct Site Visit for audit purposes
    • Explore each of the sites looking at the physical assets as well as how procedures are followed. This included emergency drills, maintenance and inspection regimes.
  5. HSE Liaison
    • Assisted the client with communicating, presenting and working with the HSE to ensure that the management plan developed was suitably communicated.
  6. Completion of the Gas Safety Case
    • Finch supported the client and developed their Gas Safety Case to present to the HSE to ensure the improvement notice was closed.

Outcome:

The project identified multiple improvements to policies, procedures and physical assets. The HSE closed their improvement notice for the various sites because with Finch’s assistance, they were comfortable that the procedures and policies in place managed the risks associated with the gas network. The Gas Safety Case was instrumental in:

  • Ensuring the client is legally compliant:
    • Gas Safety Case is required to be completed legally, especially when there are multiple gas hazards on site.
    • HSE is always looking for an up-to-date Gas Safety Case where required to ensure sites are legally compliant.
  • The risks are as low as reasonably practicable (ALARP):
    • Carry out all the essential actions/recommendations to ensure all the risks are as low as reasonably practicable (ALARP).

Conclusion:

By employing the Gas Safety Case and gap analysis assessment, Finch Consulting enabled the clients’ facilities to gain a thorough understanding of their risks and establish a strong basis of safety for gas safety. This facilitated safer operations but also ensured they remained legally compliant under the Gas Safety (Management) Regulations (GSMR).

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