Offshore Safety Directive (OSD) –Operational Implementation Team

Progress Update

6 October 2014

2 EU Directive 2013/30/EU Competent Authority Update 6 October 2014

Introduction

The EU Offshore Safety Directive

• Takes effect 19 July 2015. UK must be up and running by then.

• There will be a Competent Authority• DECC & HSE working in partnership• Name and brand• Website & portal

• Competent Authority the new offshore regulatory body for major hazards

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Competent Authority - Governance

• Governed by DECC Director Energy Development Unit and HSE Director of Hazardous Installations Directorate

• Using an enhanced Memorandum of Understanding

• Operational implementation by HSE Head of Energy Division and DECC Head of OGED

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Competent Authority – Business Processes

• Business processes for:• Safety Case & Oil Pollution Emergency Plan

Assessment• Thorough Reviews• Combined Operations & Wells notifications• Intervention planning• Investigation of major incidents• Complaints• Reporting of incidents and dangerous occurrences

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Major Accident & Major Environmental Incident

• In the OSD there can be no major environmental incident without an associated major accident.

• An environmental incident with no major safety accident potential is simply a pollution incident (and not in scope of the OSD/Competent Authority)

• Outside the scope of the Directive:• DECC deals with pollution and environmental

matters• HSE deals with health and safety matters

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Safety Cases• New regulations SCR2015• All installations need to submit material change• Need to cover:

• SEMS – Safety & Environmental Mgt System• CMAPP – Corporate Major Accident Prevention Policy• IERP – Internal Emergency Response Plan• SECE – Safety & Environmentally Critical Elements

• Transitional arrangements are complex• Taking opportunity to review and revise some aspects

of assessment process

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Safety Cases

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Safety Case Assessment Process Map

Assessment Templates

Timetable & Transitional Provisions

Assessment in Practice

SMS/EMS in Practice

Katie McCabe/Andrew TaylorThe Competent Authority / HSE and DECC

Safety Cases

Safety Case Assessment Framework Diagram• Details the process on one page

• Clearly outlines roles and responsibilities

• Clearly outlines steps and timescales involved

• Links to all relevant documents

• Provides clarity for all partiesFramework - Safety Case Assessment - DRAFT for comment - Sept 2014.DOC

Look at in detail

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Assessment Templates

• Aids consistency and improves transparency• Shares expectation with industry• Improves efficiency

Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 18 September / 6 October 2014EU Directive 2013/30/EU Competent Authority Update 6 October 201411 EU Directive 2013/30/EU Competent Authority Update 6 October 2014

SMS Template• SMS Assessment Template DRAFT for comment Sept 2014.DOC

•Directly references regulatory requirements that are associated with this topic area

•CMAPP // SMS // Verification

•EMS are not included at present

• Recognise that management systems are inter related – Working with DECC to determine how we can manage this

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Timetable & Transitional Provisions

• ~300 Safety cases to bring through 14(2) process in 3 years, by 19 July 2018.

• Slots allocated to manage the workload both for industry and ourselves

• Based on TR dates, then allocated with due regard for DHs and HSE teams

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• Assessment managed within teams by focal point inspectors• DECC and Environment is an additional topic specialism• Clear expectation for depth and timeframe• Dedicated “peak-shaving” support resource?

Assessment in Practice

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SMS/EMS in Practise

• SMS requirements are in Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations - SCR2015

• EMS requirements are in The Offshore Petroleum Activities (Offshore Safety Directive) (Environmental Functions) Regulations 2015 – EF2015

• SCR and OSDEF regulations allow for a joint SEMS description. In response to consultation EMS requirements may move to SCR.

• Conscious of need not to replicate assessment

and avoid differences of opinion

• Working together to have a single output

for assessment of management systems

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Safety Case Summary

• Framework Diagram outlines process

• Assessment Templates guide the assessment

• Timetable and transitional arrangements are based on TR dates

• Timely assessment and communication will be the key to success

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Oil Pollution Emergency Plans

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Oil Pollution Emergency Plans

• OPEP requirements for- Non Production Installation Owners- Well Operators- Production Installation Operators- Pipeline Operators- Decommissioning

• Adequate description expectations• Assessment Templates• Submission timeframes/transitional provisions

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Owners of Non Production Installations

• New requirement from OSD.• OPEP and PFEER plans form IERP arrangements• Owners OPEP only contains the non-location specific

requirements of the OSD:• Training• Persons responsible for response initiation• Reporting requirements• Arrangements for exercises & retention of evidence• Worst case scenario description

• Interface arrangements with subsequent OPEP addendums

• Submitted to CA (DECC) to align with time frame of Safety Case submissions.

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Well Operators

• Appointed by the Licensee(s) and responsible for the submission of an addendum to the NPI OPEP.

• Addendum will contain the location specific requirements of the OSD and extant OPRC regulations.

• New OSD derived requirements:• Inventory of response equipment• Assessment of the effectiveness of oil spill response measures

• Submitted to CA (DECC) 2 months prior to requirement – alignment with Well Notification?

• DECC Examining how any response measures provided by Licensed Operator be included.

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Production Installation Operators

• Appointed by the Licensee(s) and responsible for the submission of the field/installation OPEP.

• New OSD derived requirements:• Inventory of response equipment• Assessment of the effectiveness of oil spill response measures

• Well Operations from Production Installation – may necessitate an addendum from the Well Operator.

• Subsea infrastructure – included in Production Installation plan if in licensed area.

• Well Operator of any tie back infrastructure in other licensed area – looking to retain flexibility

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Pipeline Operators

• Interconnectors – No changes• Trunk pipelines that are connected infrastructure

• Update current OPEPs to reflect new OSD IERP requirements

• Pipelines included in current production OPEPs• Included in scope of OPEP updates for production

installation operators

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Decommissioning

• OSD extends definition of oil and gas activities to include decommissioning activities

• OPRC regulations amended to require a plan during decommissioning phase – not in current regime.

• Decommissioning OPEP will have to meet the requirements of the OSD IERP.

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Oil Pollution Emergency Plans

• Adequate description expectations• Assessment Templates• Submission timeframes/transitional provisions

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Incident Reporting

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Reporting Arrangements

•New offshore incident reporting requirements – Implementation Act (10 Criteria Reporting Criteria.doc )

- Competent Authority

•Reporting of Incidents comes into force July 2015

•Competent Authority reporting - Annual Basis (Jan – Dec)- Commences Yr 2016- Europe- Public

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Website & Offshore Portal

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Competent Authority Website• A CA Website is being prepared,

initially hosted as a micro-site on the HSE website.

• Important to recognise this is a joint CA website, not a HSE website.

• Will be used to publish details on:– CA Governance– Guidance for industry

• As new guidance is prepared, it is the intention to make this available on the website.

• Website URL:– www.hse.gov.uk/OSDR

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Competent Authority IT Portal• An IT Portal will be developed for

Operators and Owners to submit permissioning documents:

– Safety Cases – Well Notifications– Combined Ops Notifications– Design Notifications– Thorough Review Summaries– Oil Pollution Emergency Plans

• Will be based upon existing DECC IT systems.

• Initial scoping of specification for the portal started.

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Further Communication

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• Events – future• Articles in industry publications• Regulator Training

Questions?

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