OSDR 3 Industry Event 28th September 2015

OSDR
rd
3 Industry Event
28th September 2015
2015/364527
Aims
2
•
The purpose of the briefing is to update you about developments in the operational
implementation of the OSDR partnership, including:
•
Safety Case Assessment & Transition
•
OPEP approval and guidance
•
Updates to the Safety Case Regulations and related guidance
•
Reporting of Oil and Gas Incidents
•
To OSDR
•
To the European Commission and the public
•
The ROGI interim and final arrangements
•
OSDR Intervention Planning & Joint DECC\HSE Inspections
•
Well Notifications
•
Appointment of Licensees & Operators
•
An opportunity to ask questions, receive answers and exchange feedback
Offshore Safety Directive – Industry Briefing – 28th September 2015
The Government’s Commitments
The OSDR Partnership
“…the Government proposes that DECC and HSE work in a partnership CA to deliver the functions
specified in the Directive…This CA would be governed via an enhanced MoU between DECC and
HSE…”
3
•
The partnership is established. The MoU is in place. OSDR will cover Northern Ireland
territorial waters too.
•
The CA has an identity and brand.
•
Regular OSDR Operational Management Team meetings are happening. Many more
DECC\HSE links and interfaces are established, and are growing.
•
DECC inspectors now trained in safety case assessment
•
All inspectors have access to a shared online area for documents, which will be enhanced.
•
DECC staff to have access to HSE’s COIN system
•
Monthly joint operational implementation team meetings driving the project.
Offshore Safety Directive – Industry Briefing – 28th September 2015
The Government’s Commitments
Creating a Single Regulatory Face
“From a stakeholder perspective, this would manifest itself as a single regulatory face from the CA,
including:
4
•
DECC and HSE staff working seamlessly under a set of common CA systems and processes”
•
All OSDR business framework processes are now designed & implemented; available online.
•
“A CA online portal for all notifications and submissions to the CA, regardless of whether they
relate to safety or environmental issues”
•
Portal designed specification is agreed. Now with developers for pricing. On schedule for
implementation Q3 2016
•
A single, coherent set of CA assessment/acceptance procedures for safety cases, notifications
etc.;
•
OSDR assessment and acceptance procedures drafted and available online, including topic
assessment templates shared with industry
Offshore Safety Directive – Industry Briefing - 28th September 2015
The Government’s Commitments
5
•
A single CA intervention plan for each operator and owner, covering all planned CA inspection
activities;
•
Joint DECC\HSE intervention targeting, prioritisation and planning system created. Planning
now in progress for commencement in January 2016. Duty holder intervention plans to be
issued Q4 2015 describing all DECC and HSE planned interventions.
•
Proactive CA interventions fully coordinated and planned, with the presumption of joint
DECC/HSE visits wherever appropriate;
•
Joint intervention planning has identified installations for separate HSE and DECC proactive
inspections, and installations for joint HSE and DECC inspections. Intervention plans will show
these. Approx 30 joint inspections in 2016.
•
Coordinated CA investigations, with decisions made at an early stage as to which regulatory
partner should lead;
•
OSDR investigation process framework established. Lead agency identified at early stage after
incident. Other agency assists.
Offshore Safety Directive – Industry Briefing - 28th September 2015
The Government’s Commitments
•
A single enforcement policy covering all CA enforcement;
•
DECC and HSE enforcement policies have been examined and are aligned.
and
•
A CA website for all information relating to the CA.
•
OSDR website established as mini-site on HSE website. Lots of information available to assist
industry. A new GOV.UK site will be created and introduced around the time the OSDR portal
comes online.
Also
DECC and HSE has recommend and implemented a new approach for reporting incidents.
6
•
An online tool giving a single way to report according to requirements of the EU Implementing
Regulation, RIDDOR, MAR, DCR etc
•
The tool will replace OIR8, OIR9B, OIR12
Offshore Safety Directive – Industry Briefing - 28th September 2015
OSDR Website and
DECC\HSE Community
•
All the Competent Authority business process frameworks and supporting templates
are publically available on the OSDR website www.hse.gov.uk/osdr
•
Industry and Inspectors use them
•
The processes include specific time-frames for key stages of work.
•
OSDR can be measured by:
•
How well we stick to our processes
•
How well we stick to the time-frames
Non-industry facing documents are available to DECC and HSE staff via a shared
web community.
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Offshore Safety Directive – Industry Briefing - 28th September 2015
OSDR Safety Case Assessment
Update
Feedback & Experiences so far…
Katie McCabe
OSDR Partnership HSE/DECC
General Update
• HSE & DECC are working together effectively
• More than 10 safety cases have been accepted
• Some internal problems with resourcing are being addressed
• No fundamental changes to the process
• Some modifications to framework & templates to take account
of early lessons
• Mainly clarity to wording / additional instructions / removing
duplication
- No assessment of concurrent safety cases
- Closing COIN files for returned cases
• Website was updated in July, further update in September
• Use the most up-to-date templates
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Offshore Safety Directive – Staff Briefing - 28th September 2015
Experience to date
• Submissions
•
Safety Cases only to HSE address – OPEPs still go to DECC
•
Use online storage sites (eg Dropbox) carefully – do not send us numerous large files
• Initial Reviews
•
Use the form as a quality check and submit with your safety case
•
Ensure it’s accurate – is it based on the final submission or an earlier draft?
• NAIs
•
Some bedding in of new arrangements for raising issues
•
If you are not clear what is being asked of you then go back to your IMT
•
Do not send in too much information
•
Safety case must stand alone therefore it is likely you will need to update your case
as a result of an NAI
Working group is considering further improvements in these areas
10
Offshore Safety Directive – Industry Briefing - 28th September 2015
Assessment
• Transitional case assessment:
•
‘Management Systems & Verification’ – updated template
- re-evaluated the content of the system / scheme versus the description in the safety case
•
‘Environmental Operational Control’ – updated template
•
‘Environmental Information’ – production cases only - required to consider location
•
‘Emergency Response’ – updated template
•
‘Fire Explosion & Risk Assessment’ – updated template
- screening template to minimise assessment where no change
- management and control of major accident hazards & duty to control risk
•
‘Electrical Control & Instrumentation’ – updated template
- collection & recording of relevant data (production and non-production)
- maintaining control systems on evacuation (production only)
•
‘Wells’ – Production cases only - description of well examination scheme
• New cases & material changes
•
11
All disciplines now have templates for use with new & materially changed cases
Offshore Safety Directive – Industry Briefing - 28th September 2015
Lessons
Fundamental learning points:
• Mark your changes (regulation 24(2))
• Clearly identify the legal entity
•
Operator / owner of the installation - as approved by DECC/OGA
•
Is this an employer? If not, identify who is (enforcement purposes).
• Use the templates
•
Initial Review Template should be submitted with the safety case,
•
Specific discipline templates are available for information, experience is showing that
when submitted with the case they speed up assessment
• Ensure the information in the Safety Case is consistent throughout, and with
other regulatory submissions
• Environmental consequence must be considered when reviewing MAHs &
SECEs
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Lessons
Fundamental learning points continued:
• Safety cases should adequately demonstrate that the extent of each
regulatory requirement is understood and met. Reading and
understanding the regulations is important.
•
Use the terms SEMS / SECEs / etc
• Material changes under the 2005 Safety Case Regulations still acceptable
until the installation transition date.
13
•
Safety case assessment periods cannot overlap.
•
Any SCR05 material change must be completed before a SCR15 transitional safety
case can be assessed.
Offshore Safety Directive – Industry Briefing - 28th September 2015
Management Systems & Verification
•
CMAPP – MUST cover the points in the Schedules - refer to L154 and assessment templates for guidance
•
SEMS
•
•
regulation 8 (& associated Schedules) state what should be in the SEMS BUT regulations 17/18
(& associated Schedules) state that an ‘adequate description’ should be included in the safety
case.
Verification
•
regulations 9 & 10 state what should be in the VS BUT regulations 13 & 17/18 (and the
associated Schedules) state what should be in the description contained in the safety case.
•
SCEs no longer exist – SECEs are the way forward
•
Suitability of SECEs
•
Statement that SECEs will be suitable needs to be included in safety cases:
•
Survivability criteria due to environmental consequences may vary due to location.
•
NPI cases need to describe the methodology that will be used to determine that SECEs and
performance standards will be suitable for work such as well operations, combined operations etc.
FOCUSED ASSESSMENT HAS LED TO CONCERNS ABOUT THE QUALITY OF EXISTING
INFORMATION - CONSIDERING HOW BEST TO ADDRESS THIS
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Emergency Response
Duty holder’s are missing the changes:
• SCR15 Schedule 13 – Amendments and revocations
includes changes to the PFEER Regs:
•
Reg 6 - preparation for emergencies
6(1)(e) & 6(2) – coordinating emergency response & the IERP
•
Reg 22A - inventory of equipment
•
Reg 22B - initiation & direction of emergency response and liaison with
external response authority (MCA)
•
Reg 22C - arrangements for early warning of major accidents
Further guidance can be found in L154
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Fire Explosion & Risk Assessment
SCR15 Regulations 16(1) and 29:
Management and control of major accident hazards
Duty to control risk
• Enhancement of SCR05 Reg 12 to include environment;
• Duty holder must demonstrate that they have discharged these duties;
• Potentially all encompassing including ORAs, HAZOPs, ENVIDs etc. etc.;
• Wording of the regulations and guidance is not particularly helpful;
• NAIs have been raised;
• Being discussed with Oil & Gas UK with respect to further guidance.
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Electrical, Control & Instrumentation
Transitional cases - 2 common NAI’s
•
SCR15 Schedule 2 (3) – collection and recording of relevant data
•
•
The need to adopt suitable measures to use suitable technical means or procedures
in order to promote the reliability of the collection and recording of relevant data and
to prevent possible manipulation of that data.
SCR15 Schedule 6 (20) – control systems on evacuation (production only)
•
Arrangements for the maintenance of control systems to prevent damage to the
installation and the environment in the event that all personnel are evacuated
Walk-to-work material changes - 24(2)
17
•
Increasing common issue that EC&I are looking to address
•
EC&I will use the requirements for SEMS to ensure duty holder’s have appropriate systems
in place to manage these operations and they remain fit for purpose
•
SCR15 Schedule 3(8) monitoring of performance & 3(9) audit and review of arrangements
Offshore Safety Directive – Industry Briefing - 28th September 2015
Main Message
Use the templates and make
sure you have the current
version
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Offshore Safety Directive – Industry Briefing - 28th September 2015
OSDR Safety Case Assessment
Update
Feedback & Experiences so far…
Andy Taylor / Fiona Brett
OSDR Partnership HSE/DECC
Environmental Operational Control
• General
•
Dutyholders doing a find and replace to insert word ‘Environment’
• CMAPP
•
Expecting to see a brief description within the CMAPP of how the requirements of the
particulars are to be delivered or reference where further detail can be found in the
SEMS
• SEMS
•
Do not describe the process / arrangements for including environment in the
MAHRAs or the arrangements for ensuring how damage to the environment will be
limited (enhancing performance of SECE to further reduce risk, etc).
•
Some NPI SC do not contain MAHRA that include environmental impacts as location
unknown. Must detail how they will fill this gap in the SEMS description and risk
assessment sections of the SC. Some stating that this will be covered in TO OPEP.
• IERP
•
20
Cross references between SCR & OPRC Regs Schedule 2 incorrect. References to
oil spill effectiveness register should be to assessment of environmental effects and
arrangements for early warning of MEI.
Offshore Safety Directive – Industry Briefing - 28th September 2015
Environmental Operational Control
• Internal Emergency Response Arrangements
21
•
Cross references between SCR & OPRC Regs Schedule 2 incorrect.
•
Para. 22 Schedule 6 references paragraph 2(8) of Schedule 2 to the OPRC. Should
reference paragraph 2(j) of Schedule 2 to the OPPRC (rather than paragraph 2(h)).
•
Para. 18 of Schedule 7 of the SCR 2015, in relation to NPIs. This likewise should be
to paragraph 2(j).
•
Para. 23 of Schedule 13 of the SCR 2015. Where it refers to ‘paragraph 11 of
Schedule 2’ it should now refer to paragraph 2(k) of OPRC Schedule 2.
Offshore Safety Directive – Industry Briefing - 28h September 2015
Environmental Information
The Competent Authority has received 14 Production Installation Safety Cases of
which 7 have been fully assessed resulting in 5 Non Acceptance Issues (NAIs)
A MEI is only likely to occur where the following takes place:
• A major accident has taken place
• There are significant effects on species or habitats listed in the EU Directives, or in
coastal waters, or on human health
EIA / OPEP worst-case assessment and modelling will evaluate whether an MEI
could occur, and potential impacts should then be summarised (refer to EIA/
OPEP)
22 Offshore Safety Directive – Industry Briefing - 28th September 2015
MEI - Definition
Article 2(37) ‘Major Environmental Incident’ means:
‘an incident which results, or is likely to result, in significant adverse effects on
the environment in accordance with Directive 2004/35/EC’ [the Directive of the
European Parliament and of the Council on environmental liability with regard to the
prevention and remedying of environmental damage – the Environmental Liability
Directive]
23 Offshore Safety Directive – Industry Briefing - 28th September 2015
MEI Identification – Schedule 6
Likelihood
• Historical spill frequency information etc. already provided in EIA (justification)
documents, and just need a high level summary in the Safety Case
• Provide linkages to hazard management / mitigation measures, e.g. well / pipeline
design, pressure control, corrosion management / protection, loss of containment
etc.
Offshore Safety Directive – Industry Briefing - 28th September 2015
MEI – Consequence Assessment
• The full impact assessment identifying the consequences
should be included in the Environmental Statement (ES) for
new installations and the Production (PRA) MAT EIA
(justification) document for existing installations
• The Design / Relocation Notification stage is likely to be the
only submission where environmental information is required
‘up front’, but the information provided can then be fed into the
Environmental Statement when it is submitted to support the
Field Development Plan
• The Safety Case should incorporate a high level summary of
the assessment and reference the ES or the Production MAT
25 Offshore Safety Directive – Industry Briefing - 28th September 2015
Lessons learnt so far (1)
Quality Control Issues:
• The Safety Case must contain current information pertaining to the
installation, and all changes to a submitted document must be highlighted
(Regulation 24 (2))
• The consequence of an oil spill is not limited to whether the oil beaches or
not, or how long it takes to beach, the consequence assessment is an
additional requirement and is not normally covered in the OPEP, but should
be covered in the EIA
• If it is concluded that a major accident relating to an installation or
connected infrastructure could result in a MEI, a summary of the potential
consequences (the impact assessment) will need to be provided
• Several Safety Cases have presented conclusions or statements referring
to the potential for a MEI, but no explanation is provided to confirm the
rationale for arriving at that conclusion
26 Offshore Safety Directive – Industry Briefing - 28th September 2015
Lessons learnt so far (2)
Specific cases:
• Breach of export pipeline containment near shore is assessed to have MEI potential
in more than one Safety Case, this is not relevant to installation(s) or connected
infrastructure
• Some OPEPs cover a number of fields and the worst-case scenario identified in the
OPEP has been used for determining the MEI potential, but this approach is only
relevant if the worst-case scenario relates to the installation and connected
infrastructure covered by the Safety Case.
26 Offshore Safety Directive – Industry Briefing - 28th September 2015
Offshore Safety Directive Regulator
OPEP UPDATE
28 September 2015
Nicholas Woollacott
Offshore Environmental Inspectorate – OSDR
OPEP update
Agenda
• Summary of main changes in August 2015 OPEP guidance notes
• Lessons learned from initial NPI and Production Installation OPEP submissions
• Review of OPEP transitional arrangements
Since the entry into force of the amended Merhchant OPRC regulations on 19 July
2015 OSDR has approved 57 OPEPs.
DECC OPEP guidance notes fully updated and initially issued January 2015. First
update published May 2015. Second updated made available on OSDR website
August 2015.
Potential for next revision of DECC OPEP guidance notes to occur in December 2015
or January 2016.
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Changes to Guidance (1)
Changes to DECC OPEP guidance notes since previous revision (May 2015):
30
•
Updated process for making changes to approved OPEPs. All changes are either major or
minor. Major changes relating to proposed well/combined operations will be approved. Other
changes will be assessed for appropriateness.
•
Any material change to a Safety Case only requires the OPEP to be amended if the material
change impacts on the oil spill response arrangements as detailed in the OPEP.
•
A CIP may be appropriate if a NPI intends to undertake non-combined operations in a location
within the scope of an existing Production Installation/Field OPEP and the primacy for the oil
spill response remains with the production installation – Not necessarily a TOOPEP.
•
Oil and gas operations undertaken from vessels must be included in the scope of an OPEP if
there is a risk of oil pollution from any subsurface infrastructure as a result of the oil and gas
operations or the oil and gas operations necessitate the vessel obtaining a Consent to Locate.
Offshore Safety Directive – Industry Briefing - 28th September 2015
Changes to Guidance (2)
31
•
The OPEP must confirm that adequate arrangements are in place to limit environmental risks;
•
Modelling results should be displayed pictorially to a visible an oil thickness of 0.3µm not
0.04µm. The tabulated information in the modelling section must still include the probability of
any oil beaching / crossing median line to 1%;
•
Worst case well flow rate text amended. The word “unconstrained” is removed as industry
feedback identified that the worst case well flow rate could be constrained;
•
Dispersant efficacy. Requirement for the dispersant selection to be undertaken in accordance
with MMO protocol for efficacy testing (LR448) removed. Requirement is to now confirm that
chosen dispersant(s) are suitable for application.
•
Training Requirements. On Scene Commander - DECC Level 1. EOM, Ops Rep & Technical
Rep in the OCU - at least DECC Level 2. Emergency Room Manager & Environmental Advisor
in the ERC - at least DECC Level 3. Duty Managers - at least DECC Level 2. The
Responsible Person must have also have access to personnel trained to DECC Level 4.
Offshore Safety Directive – Industry Briefing - 28th September 2015
Lessons Learned (1)
32
•
The NPI OPEP template as prepared by IADC has facilitated the NPI OPEP review process;
•
Completed assessment templates expedite the review process;
•
All OPEPs should be sent directly to DECC (electronic & hard copy);
•
Full OPEPs do not need to be included as an appendix to the Safety Case;
•
Some NPI owners have expanded on the IADC template to include material from the SOPEP
– Resulting in conflicting information (incident reporting etc);
•
NPI owners should sense check the IADC template to ensure third party equipment listed on
the template is actually present on the NPI – Cement Units on Floatels etc;
•
Some NPI owners have deviated from the IADC template in their explanation of how the
location specific oil spill response arrangements will be provided by the well/installation
operator – Information provided is not consistent with the OPEP regime;
Offshore Safety Directive – Industry Briefing - 28th September 2015
Lessons Learned (2)
33
•
Shoreline protection – If an OPEP identifies potential for oil to beach Responsible Persons
must confirm in the OPEP that appropriate at sea and shoreline response resources can be
available on scene in sufficient time to allow response measures to be implemented to
minimise the impact of any oil pollution;
•
Offshore OPEP exercises - Every OIM on a production installation undertaking the role of
OSC must complete one OPEP exercise per calendar year. If the production installation is
under the operatorship of one company with subsea tieback(s) under different operatorship
with separate approved OPEPs the OIMs annual OPEP exercise can utilise any one of these
OPEPs (i.e. an exercise for each offshore OPEP is not required);
•
The EPC Regulations 2002 do not regulate the preparation/implementation of OPEPs.
Reference to these regulations should be removed (clarification matter); and
•
The terms addendum/appendix as used in some field OPEPs to explain how the document will
be updated in the event of NPI operations should be replaced with CIP/TOOPEP (clarification
matter);
OSDR OPEP Update – OGUK – 28 September 2015
Lessons Learned (3)
34
•
Communication is key - NPI Owners and Operators who have discussed their proposed
OPEP arrangements with DECC have demonstrated a good understanding of the regime in
their submissions;
•
The current DECC Inspector/Environmental manager Operator split for production installations
is available on the website:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/421537/Operato
r_split.pdf
•
The review of the OPEP for each NPI with a UK safety case is allocated to a DECC inspector:
[email protected]
OSDR OPEP Update – OGUK – 28 September 2015
Transitional Arrangements
Impact of NPI OPEPs:
Once a NPI holds an approved NPI OPEP any Well/Installation Operator contracting the NPI
must take account of the NPI OPEP in their own OPEP arrangements.
Impact of Production Installation OPEP transitions:
Once a production installation holds an OPEP approved under the amended OPRC regulations
any NPI or subsea tieback that interfaces with the transitioned field / installation OPEP must hold
an OPEP to the standard of amended OPRC regulations.
New OPEP submissions and major changes to approved OPEPs:
Must meet the requirements of the amended OPRC regulations.
Minor changes to approved OPEPs:
Do not necessitate transitioning the OPEP to meet the requirements of the amended OPRC
regulations.
Early transitions of Subsea Tieback OPEPs:
Do not necessitate the transition of the host installation OPEP.
35
OSDR OPEP Update – OGUK – 28 September 2015
Directive on the safety of offshore
oil and gas operations
Legislative Update
Jim Neilson
Head of Offshore, Diving and Pipeline Policy
HSE
Legislative Update
SCR 2015
• A correction note will be used to amend editorial errors
identified (e.g. in numbering or referencing), including:
- Some links to DECC’s OPPRC Regulations
- Regulation 26(3) , which should refer to the competent
authority not competent person
- References to the external emergency response plan in
the explanatory note
• In the final version of the SCR 2015 guidance, the
legislative text will be updated to reflect the above changes
37
Offshore Safety Directive – Industry Briefing - 28th September 2015
Legislative Update
SCR 2015 Guidance
• Meetings took place with well examiners and well
operators in July to clarify notification expectations
• Guidance has been on line in draft form for over 2
months to bed in
• We will amend the editing error in paragraph 235
• Paragraph 169 on material changes will be updated
to clarify the verifiers role is to consider that any new
or existing SECEs or specified plant are suitable
and that the verification scheme is revised as is
necessary
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Legislative Update
PFEER ACoP
• In July meetings took place between HSE and the
Industry on Regulation 16 on escape
• A way forward was has been agreed, based on the
current interpretation
• Some other industry comments being considered
(e.g. need for guidance on review/repeat
assessments and emergency response training on
coordination with persons not on installation)
• Revised draft will be circulate in October
39
Offshore Safety Directive – Industry Briefing - 28th September 2015
Legislative Update
First Aid ACoP
• Two issues have been raised by industry (e.g. the need for
competence in endotracheal intubation and the need to refer
to baths and/or treatment on an installation if rescued from a
vessel)
• HSE’s Corporate Medical Group are considering and will
respond to Oil & Gas UK on these issues and update the
ACoP as appropriate
• Both the First Aid and PFEER ACoPs are not expected to be
M
published
in final glossy form until March 2016
40
Offshore Safety Directive – Industry Briefing - 28th September 2015
Legislative Update
Further information
The Offshore Directive website:
http://www.hse.gov.uk/offshore/directive.htm
SCR 2015 draft guide:
http://www.hse.gov.uk/offshore/index.htm
OSDR website:
www.hse.gov.uk/osdr
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Reporting Incidents to OSDR,
Europe and the Public
Rog Thomson
OSDR Partnership – HSE & DECC
Reporting Incidents to OSDR
•
A new direct acting EU Regulation (Implementation Regulation) for the
reporting of incidents offshore came into effect 19th July 2015.
•
EU Regulation requires reporting of events in a number of categories:
A. Unintended release of gas, oil or dangerous substance.
B. Loss of well control.
C. Failure of a SECE.
D. Loss of structural integrity / loss of station keeping.
E. Vessel collision / potential collision.
F. Helicopter collision / potential collision.
G. Fatal accidents.
H. Serious injuries to 5 or more persons.
I. Evacuation of personnel.
J. Major environmental incident.
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Reporting Incidents to OSDR
•
Ministers approved a policy decision not to alter our domestic
legislation to take account of the new notification obligations.
•
We will therefore have overlapping health, safety and environmental
reporting regimes.
RIDDOR
MAR
44
EU
Regulation
OIR
12
PON
1
PON
10
PON
2
DCR
Offshore Safety Directive – Industry Briefing - 28th September 2015
Reporting Incidents to OSDR
• Legally an installation needs to report incidents under the EU
Regulation after a safety case has been accepted under the
SCR2015
• This may lead to situation where a Duty Holder has different
reporting regimes for different installations.
• Confirmation has been given by the O&GUK Board that it is content
for the whole industry to start reporting using the new tool from
January 2016
• Transitioned installations will still need to report before this date.
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Reporting Incidents to OSDR
46
•
PON 1 notification will still be undertaken via the normal route (EU
Reporting Form Sections A and/or J -‘major environmental incident’)
•
All other reporting (with the exception of safety zone infringement) will be
through one single reporting tool as a means of minimising the reporting
burden on industry.
•
We previously advised that we would report via the RIDDOR database this
is no longer the case
•
There will now be a separate online system which is to be made available
from Jan. 2016. HSE is contracting the work out for build of this system .
•
For installations that have transitioned and require to comply with the
changes there is a Word Format reporting form (ROGI) available via the
OSDR website at www.hse.gov.uk/osdr
•
The form has been designed to deal with both internal and external waters
Offshore Safety Directive – Industry Briefing - 28th September 2015
Reporting Incidents to OSDR
• As with Safety Case Assessment there is a framework diagram which takes
you through the various stages of the process
• Currently the reporting form is in word format until an online system is made
available. (link to form)
• The online system is scheduled to be complete by January 2016
• http://www.hse.gov.uk/osdr/reporting/incidents-to-osdr.htm
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Reporting Incidents to OSDR
• There will be additional entries onto COIN by IMT administrators (training
session will be set up for this)
• The form also requires details of the inspector judgement and justification on
whether or not the event should be regarded as a major incident
48
•
EU Guidance has now been finalised and is on the OSDR Website
•
Revised guidance on how to use the tool to report HCRs is also now
available on the site this replaces the old HSE OTO 96 956 guidance for
reporting of offshore hydrocarbon releases.
•
O&GUK supplementary guidance for reporting hydrocarbon releases is also
being revised
Offshore Safety Directive – Industry Briefing - 28th September 2015
Reporting to Europe & the Public
Member States must report incident information to the
EU Commission and share it publically:
• Annual data
•
gathered using the ROGI database / HCR database etc.
• Major accident investigations
•
OSDR will make summary information available at the conclusion of the investigation
/ legal proceedings. Sent to Commission and made public on OSDR website.
• Respond to requests for information
•
Member States may request information from any other member state
• Trans-boundary effects
•
Europe to be informed if potential is identified during safety case assessment or
during an incident
Framework Diagram outlines the process for complying with these requirements
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Reporting to Europe & the Public
• Annual reporting to the EC is by calendar year
• Commences 2016 with the first return to EU in June of following
year, and annually thereafter.
• Annex 11 of the Implementation Regulation details the common
format all EU Member States are required to use. Information will be
extracted from
• COIN (including work recording)
• DECC work recording
• Online system
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Intervention Planning
Marc Nunn
OSDR Partnership / HSE and DECC
OSDR Intervention Planning
• EU Directive requires the CA to produce annual inspection
plans.
• HSE and DECC, working in partnership as the Competent
Authority, will produce joint intervention plans for duty holders
of offshore installations, and well operators.
• Plans shall include all HSE and DECC inspection activities in
one plan (including pipelines, diving and environmental
regulations).
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Offshore Safety Directive – Industry Briefing - 28th September 2015
OSDR Intervention Planning
• Plans will be based upon a calendar year, starting January
2016, and will be revised and re-issued December each year.
• Plans will include 15 months of activities for HSE (i.e. covering
the period January 2016 to March 2017).
• First 3 months of the plan for HSE activities (January to March
2016) will be taken from existing HSE 2015-16 plans.
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Offshore Safety Directive – Industry Briefing - 28th September 2015
OSDR Intervention Planning
Inherent Hazard /
Risk Assessment
Duty holder or
well operator
performance
Intervention Plan
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Offshore Safety Directive – Industry Briefing - 28th September 2015
Other
Intelligence
OSDR Intervention Planning
HSE
Produce list of
prioritised PIs
Produce list of
prioritised PIs
Produce list of
prioritised NPIs
known at beginning
of work year
Identify planned
inspections of NPIs
known at start of
planning cycle
Produce combined
IP for installations
Operational
Intelligence
e.g. WN,
CON, diving
55
Revise IP in
response to in-year
operational
intelligence
Offshore Safety Directive – Industry Event – 28th September 2015
DECC
OSDR Intervention Planning
• Prioritisation process mostly unchanged.
• DECC processes for prioritising inspections for PIs and NPIs
remains unchanged.
• HSE process for prioritising PIs remains unchanged.
• HSE process for NPIs has been modified:
• Inherent hazard currently uses PLL for an installation.
• New process places NPI installations into inherent hazard
‘bands’ based upon the type of installation:
> High : None
> Medium : MODUs / accommodation units
> Low : well intervention vessels / construction vessels
(including HLV)
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Offshore Safety Directive – Industry Event – 28th September 2015
OSDR Intervention Planning : Next Steps
• Prioritisation process has just been completed.
• Focal point inspectors should be able to give duty holders an
indication of which installations are likely to be targeted for
inspection in 2016.
• Inspectors are now developing the detailed intervention plans,
which will be shared with duty holders and well operators by
end of December 2015.
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Offshore Safety Directive – Industry Event – 28th September 2015
Well Notifications
Marc Nunn
OSDR Partnership / HSE and DECC
Well Notifications
• Processes and transitional arrangements for well notifications are
detailed on the OSDR website.
• A flow diagram is available to assist interpreting the regulations
on when the 2015 regulations apply, and what documents need
to be submitted.
• In certain circumstances, a CMAPP and SEMS description may
need to be submitted along with the well notification, if they have
not already been sent to OSDR.
• If such a situation is likely, it would help to speak to your focal
point inspector to assist in workload scheduling:
• CMAPP and SEMS can be sent before the well notification, to ease
the inspection process.
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Offshore Safety Directive – Industry Event – 28th September 2015
Well Notifications : Wireline Operations
• Latest legal advice is that a well notification is required for
wireline operations on a production installation.
• Including a section in a safety case would not be compliant with
the Directive.
• Pragmatic approach to well notifications for wireline operations
shall be taken.
• A generic well notification covering such operations, spanning
a longer time period, will be acceptable.
• A 5 year period, coinciding with the safety case thorough review
period, could be a convenient time period.
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Offshore Safety Directive – Industry Event – 28th September 2015
Appointment of Licensees
and Operators
Fiona Brett
OSDR Partnership / HSE and DECC
OSD Licensing Regulations
• Licensing Authority (LA) is now the Oil and
Gas Authority (OGA)
• Establishment of OGA, driven by the Wood
Review, ensures functional separation between the
LA and the Competent Authority (DECC and the
HSE)
• Licences are still granted under the Petroleum Act
1998, but the Regulations introduce new
environmental and safety requirements
• Environmental and safety requirements will apply
to licensees and operators, and the Competent
Authority (CA) must be consulted
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Offshore Safety Directive – Industry Event – 28th September 2015
OSD Licensing Regulations
• Revised definitions of terms including licensee, operator, installations, offshore
operations, etc. to align with Directive
• Several operators are possible under a single licence, e.g. installation operators and
well operators, for all or different phases of the operations
• Grant and transfer of licenses
• Appointment of operators by licensees or the licensing authority
• Capacity of operators and termination of operator appointments
• Licensees’ obligations and liability for environmental damage
• Provision of information
• Revocation of licences
• Offences
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Offshore Safety Directive – Industry Event – 28th September 2015
New OGA Licensing Regulations –
Appointment of Operators
• Licensing Authority is required to consult the Competent Authority who will comment
on:
– Safety and environmental performance of applicant
– Safety and environmental management systems and structure
– Sensitivity of local and adjacent environment, and potential cost of its degradation
– Capacity to comply with relevant statutory provisions
• OSDR has a business process framework with supporting templates and guidance
for handling with OGA consultation requests
• Where details can’t be provided at application stage, commitments will be checked
before commencement of operations, including financial responsibility relating to
well operations
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Offshore Safety Directive – Industry Event – 28th September 2015
OSD Licensing Regulations –
Capacity of Operators
• OSDR must inform OGA if it determines an operator no longer has the
capacity to comply with relevant statutory provisions.
• OGA must notify licensees of the CA’s determination
• Where licensees are informed of a determination, the operator’s
appointment must be terminated.
• Where an operator’s appointment is terminated, the licensee becomes
responsible for carrying out the operator’s functions
• Where an operator’s appointment is terminated, the licensee must propose
a new operator
• Guidance on the safety and environmental requirements for licence
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Offshore Safety Directive – Industry Event – 28th September 2015
applications
and the appointment of operators is available
Licensing contact details
• OSD notifications/submissions (inc for well and installation operatorship): to
[email protected] (marked ‘XXX: OSD Submission’ where XXX is the
case it’s associated with)
• Licensing casework submissions: to the Licensing Portal (PEARS)
• Licensing casework/processing queries to: [email protected] cc:
[email protected]
• Exploration (subarea) operatorship queries to:
[email protected]
• Production (field) operatorship and FDP queries to: the relevant OGA team
leader ([email protected]; [email protected] or
[email protected])
• Licensing policy queries to: [email protected]
• PWA, DepCon, Prod and flare consent casework queries to:
[email protected]
• OSD requirements and policy queries to: [email protected]
Offshore Safety Directive – Industry Event – 28th September 2015
Questions and Answers Session
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Offshore Safety Directive – Industry Event – 28th September 2015