| Description |
You have failed to ensure that installations undergoing decommissioning activities were hydrocarbon free (HCF) as stated in your safety case, PUK-SMS-SC-001 Volume 1, Part 2, Section 8.2 in that on 21 April 2022 at your Inde 49/18A installation there was a release of hydrocarbon and resulting fire from the topsides that involved activities that should not have commenced before HCF status; another similar hydrocarbon release incident also occurred at your Pickerill A installation on 16 October 2019 after the installation had been declared HCF. This indicates that your procedures and arrangements were not suitable and sufficient to ensure hydrocarbon free status and prevention of risks to persons on the installation. |