1. The Consultative Letter was distributed to organisations and government departments identified in HSC/01/164 and was also available on the Internet. HSE received 16 replies of which 50% of the respondents represented professional associations, 4 represented government, 3 represented industry and 1 represented trade unions. A list of respondents can be found at Annex A.
2. The majority of the responses welcomed the opportunity to consider the proposals, but had few comments to make. A single comment was received on the proposed legislation. One of the professional associations brought to our attention that some of the legislation mentioned in the draft regulations had been amended or revoked since MAR was introduced in 1995 and that this might be confusing. The draft regulations have been amended.
3. Most of the comments on the revised guidance were unfortunately aimed at the unchanged sections rather than the proposed amendments. One respondent, representing one of the professional associations, suggested amending the preface and introduction to explain that the guidance now incorporates clarification regarding the status of specialist support vessels which provide accommodation and the circumstances under which well service vessels are defined as offshore installations. This was incorporated into the guidance.
4. A government department urged the extension of 'supplementary units' to include all units engaged in or contracted for the support of the exploitation of oil and gas on the United Kingdom Continental Shelf, to include specialist vessels such as diving support vessels when carrying out diving operations as well as providing accommodation. It was felt that this would be too much of a burden on the industry if it were taken forward. A further suggestion to highlight the risks to helicopters from installation generated environmental hazards was incorporated into the guidance.
5. The Health and Safety Commission agreed the amended draft regulations and the revised guidance on 28 May 2002. It is hoped the regulations will come into force by the end of July and the revised guidance be available by September 2002.
Association of Wellhead Equipment Manufacturers
Civil Aviation Authority
Department for Education and Skills
Honourable Company of Master Mariners
Independent Pilots Association
Institute of Marine Engineering Science and Technology
International Marine Contractors Association
National Assembly for Wales
National Wind Power
Well Services Contractors Association