Health and Safety Executive

Carbon capture and storage - Working with others

Government commitment

The Government's report on the Energy Review: 'The Energy Challenge' [PDF] was released on 11 July 2006". This work aims to put UK in a position to meet two major long-term challenges in UK energy policy:

  • the need to tackle climate change by reducing carbon dioxide emissions; and
  • the need to deliver secure, clean energy at affordable prices, as we move to increasing dependence on imported energy

HSE's expert report [PDF 100KB] on the Governments Energy Review identified a need to review the suitability of some parts of the current legal framework with a view to maintaining a consistent approach to regulating these emerging industries.

On 10 January 2008, the Government published the Energy Bill implementing the legislative aspects of the Government's Energy White Paper, 'Planning for a Sustainable Future', published on 21 May 2007. This includes creating a regulatory framework to enable private sector investment in CCS projects. CCS has the potential to reduce the carbon emissions from fossil fuel power stations by up to 90%.

Most processes can be effectively regulated under existing legislation, but there are gaps that Government and others are currently exploring ways to fill. Licensing arrangements, if introduced will probably incorporate four periods.

  • Preliminary exploration period - ID of sites
  • Time limited exploration period - surveys etc
  • Dormant period - limited period for site preparation
  • Operational period of 2 stages i) injection stage; and ii) post injection stage for period from closure to license surrender
  • The plan foreseen is, after the Operational period, to vest the rights to store carbon dioxide permanently offshore through the Crown Estate

On the 30th June 2008 the Department for Business Enterprise and Regulatory Reform, (BERR) published a public consultation document 'Towards Carbon Capture and Storage'. This consultation seeks views on several aspects of the regulation of Carbon Capture and Storage. Specifically, it consults on aspects of the proposed EU Directive on the Geological Storage of Carbon Dioxide and invites views on the principle of 'carbon capture readiness' for combustion plants and the regulation of Carbon Dioxide storage.

Competition to develop demonstration of carbon capture and storage

On 19 November 2007, BERR launched a competition to develop the UK's first full-scale demonstration of carbon capture and storage, to begin operation within the next decade. Governmental calculations have confirmed that by 2020, 20GW of new power generation plant will be needed to meet UK Energy needs. Meanwhile, for the EU to meet its now binding target of a 20% reduction in greenhouse gases by 2020, it is vital that the first commercial scale EU CCS demonstration plant is built as soon as possible, paving the way for the development of a CCS industry. In addition, HSE are aware of a number of other CCS projects that will be progressed outside the BERR competition.

Health and safety arrangements

HSE is working closely with BERR throughout the competition. Within the competition documents, it is clearly stated that HSE requires developers to give a health and safety compliance demonstration as if CO2 was classified as a dangerous substance or fluid under COMAH and PSR, and (for offshore installations) as if all relevant offshore regulations applied, in order to satisfy the requirements of the Health and Safety at Work etc. Act 1974. In addition, the successful competitor must provide technical information to HSE throughout the project, to inform the development of appropriate health and safety standards.

North Sea Basin Task Force

The UK has a unique opportunity with the convenient location of the North Sea storage capacity to demonstrate the benefits of CCS in helping to mitigate climate change, (possibly utilising existing infrastructure before it is decommissioned) and has set up a Task Force to develop common principles for managing and regulating the transport, injection and permanent storage of CO2 in the North Sea sub-seabed.

North Sea Offshore Authorities Forum (NSOAF)

The NSOAF was formed in 1999; its goal is to ensure continuous improvement in health, safety and environment in the petroleum activities in the North Sea. Active members are Norway, Faroe Islands, Germany, Ireland, The Netherlands, Sweden and UK.

HSE has been asked to chair a NSOF EU Working Group project to explore the potential for developing common principles for managing and regulating the transport, injection and permanent storage of CO2 in the North Sea sub-sea bed. This works follows on from the North Sea Basin Task Force's recommendation for a common regulatory approach.

International CCS Regulators' Forum

International Energy Agency (IEA) launched the International CCS Regulators' Forum on 13-14th May 2008. It's aim is to provide a neutral forum for information exchange, facilitating the development of legal and regulatory frameworks to govern CCS.

HSE gave a presentation on CO2 transport health and safety issues at the two day launch event in Paris. Details of the forum and all the presentations from the two day event are available on the IEA website (CCS Legal and Regulatory Frameworks).

A series of web conferences are planned for 2008 beginning with one on CO2 transport  safety issues on 10th July 2008, chaired  by HSE. This conference provided a forum for experts to provide updates, ask questions and discuss possible solutions to the challenges faced in developing a shared understanding of the health & safety risks and an adequate regulatory framework. It will allow HSE to benchmark our proposals against approaches taken by other countries.


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Updated 21.08.09