Health and Safety
Executive / Commission
Regulatory Impact Assessments: Offshore
1. The new Health and Safety at Work etc. Act 1974 (Application Outside Great Britain) Order 2001 (The Order) came into force in July. Among other things it extended the definition of 'offshore installation' to include supplementary units which may be wind, wave, tide, current or conventionally powered and provide power, control, communications and chemical injection facilities These supplementary units would provide support services to offshore installations. As a result, the definition of offshore installation contained in MAR needs to be amended to align it with the definition in the Order.
2. There are potential risks associated with the operation of offshore energy structures including supplementary units. There is no accident record for the types of structures affected by this legislation but data on non-catastrophic (ie excluding major fires and explosions) risk in the offshore sector as a whole provides some indication of potential hazards.
3. The overall accident record suggests that risks in the offshore industry tend to be above the average across all industries, notwithstanding the considerable effort devoted to health and safety by the industry. This principally due to the hostile external environment and the relatively large amount of heavy machinery involved in the energy production process. There are particular risks arising from offshore activities relating to personnel travelling from the shore, working at night, moving objects (including machinery), any diving operations that may be required, and risk of fire combined with limited means of escape.
4. The objective of the change is to ensure that offshore health and safety law is appropriately extended to supplementary units.
5. Options relating to application of the Order were considered at the time it was made. The definitional change is consequence of adopting the Order.
6. These are as stated in the text.
7. The extension to MAR will help ensure the same level of safety will apply to workers when dealing with supplementary units as applies when they are working on the `parent' installation. In terms of industry safety and HSE's activity there are benefits for the inspection function from the perspective that it will clarify the application of legislation to supplementary units. Further benefits can be gained by industry from implementing health and safety measures in terms of avoiding lost production costs associated with accidents.
Business sectors affected
8. This definitional change will affect supplementary units which provide power to offshore installations within the existing definition. No such units are in operation, although some are at the design and development stage. If they were ever to come into use, they would almost certainly be operated exclusively by offshore oil and gas production companies.
9. As there are no units in operation, we cannot predict likely total costs. However we are able to cost 'windfarms,' although even a very small scale working wind farm is likely to be on a larger scale than a supplementary unit.
10. Example costs were provided for a small scale developmental two-tower wind farm. Given differences in the operation (specifically less personnel visits required during operation), the costs associated with supplementary units were assumed to be approximately half those for wind powered structures.
11. The initial costs of complying with MAR for the two-tower wind farm was £10,000, comprising of expenditure on safety equipment, training and risk assessment. Recurring costs were estimated at £2,000 every three years. We therefore assume costs of half these totals for a supplementary unit giving a similar power output to the developmental wind farm - which is likely to be the typical case for an operational supplementary unit. This indicates costs of £5,000 initially, and £1,000 every three years. It should be recognised that the offshore industry, which is very safety conscious, would incur many - if not all - of these costs even in the absence of the formal extension of MAR to these structures.
12. The estimated costs above total £8,000 over ten years, or £7,000 discounted to current values at a rate if 6%. This is the cost relating to one unit.
13. As above.
14. None. No SMEs will be affected by these proposals.
15. None.
16. None.
17. This depends on the future use of supplementary units, which we cannot predict at present.
18. Positive. Wave powered energy generation is one of the most environmentally friendly forms of generating electricity.
19. This cannot be quantified, but at current valuations of risk, the MAR related costs relating to a single unit would only have to have a one in one thousand chance of preventing a single fatality over the ten year period, for the safety benefits alone to balance the costs.
20. This is a developing area, and these are as already stated in the text.
21. None proposed until it becomes clear whether or not supplementary units will become widely used.
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