2009 – 2010 Workplan narrative

Introduction

1 The Gas and Pipelines Unit is responsible for the enforcement of health and safety law in relation to upstream natural gas transmission and distribution networks; gas reception and import terminals; gas storage facilities; onshore and offshore major hazard pipelines; Oil and Pipeline Agency COMAH sites; and associated high hazard sites.

2 The Unit’s work includes the assessment of safety cases under the Gas Safety (Management) Regulations 1996 (GSMR); pipeline aspects of safety cases under the Offshore Safety Case Regulations 2005; safety reports under the Control of Major Accident Hazard Regulations 1999 (COMAH); and pipeline notifications under the Pipelines Safety Regulations 1996 (PSR). 

3 Inspection issues will be identified during the assessment process, and intervention plans prepared to maximise the effectiveness of the unit’s inspection programme. Staff will conduct inspections and other interventions to ensure that safety issues have been properly addressed and that the duty holder is complying with relevant legislation.

Delivering health and safety outcomes

4 Our work will help HSE to meet its strategic objectives of: Avoiding Catastrophe; Leadership and Securing Justice and deliver improved health and safety outcomes for those in or otherwise affected by work. This will primarily be through our contribution to the health and safety outcome targets which form part of the DWP Departmental Strategic Objectives. We will investigate significant incidents in the gas and pipelines sector, determine the causes, make recommendations, and take enforcement action where necessary.

Unit priorities

Avoiding Catastrophe

5 Gas safety:  Assess safety cases (and revisions); review and revise intervention plans; inspect against plans. 

6 Offshore Safety Cases: Assess pipeline related aspects in support of OSD assessment teams; review and revise intervention plans; inspect against plans.

7 Pipelines Notifications: Assess notifications which have been submitted.  Identify inspection issues; review and revise operator intervention plans; inspect against plans. 

8 COMAH: Assess safety reports (and revisions); review and revise intervention plans in accordance with regulation 19; inspect against plans.

Leadership

9 We recognise the importance of effective leadership in managing and controlling risks in the major hazard industries in our sector and will be working with industry and stakeholders secure and promote improvements.  

Securing Justice

10 We will investigate significant incidents in the gas networks, at COMAH establishments and involving major accident hazard pipelines.

Priority work

Deliver the Unit’s contribution to HID’s key deliverables for 2009 – 10 on the strategic themes of avoiding catastrophe (which includes targeting of poor performers, increased adoption of key performance indicators and competence in major hazards) and leadership. 

Review implementation and use of process safety performance indicators (PSPIs) by major operators; PSPIs to be reviewed with key industry stakeholders including the Gas Transporters Operational Safety Group & United Kingdom Onshore Pipelines Association. Publish an Annual report on safety in the gas industry 

Approve iron mains replacement programmes and audit progress against the iron gas mains replacement programme in accordance with HSE audit programme.

Inspect distribution networks’ response to publicly reported gas escapes and compliance with GSMR regulation 7(4)

Inspect operations and maintenance on the high pressure gas transmission and distribution network

Assess PE integrity issues across the independent gas transporter (iGT) networks and deliver a industry seminar on PE integrity

Continue to inspect gas networks emergency exercises and support the wider industry and government agenda concerning risk of gas supply emergencies

Inspect operations at new LNG import facilities

Develop arrangements for assessing COMAH safety reports for storage of gas in depleted reservoirs; develop and implement COMAH intervention plans

Assess new gas storage COMAH safety reports

Review and inspect the integrity of cup & grip seal arrangements at higher risk gas holders. Support industry revision of guidance on safe operation of low-pressure gasholders

Support HSE COMAH remodelling project

Develop intervention plans to support Offshore Divisions’ priority areas on asset integrity, leadership, competence and safety culture

Inspect arrangements for the integrity management of offshore flexible risers following on from the 2008 industry seminar

Inspect arrangements for offshore riser-in-caisson integrity management

Contribute to HSE’s Emerging Energies Technologies programme on gas storage, biogas and carbon capture and storage. 

Support proposed revision of the Pipelines Safety Regulations 1996

Improve business efficiency:

Continue to develop the use of HSE’s gas & pipelines website to provide health and safety information to the public

Comment

12 The unit plan is based on staffing levels set out in the document ‘Gas & Pipelines Plan of Work 2009-2010’.    

13 Activities which are likely to have the least immediate effect on the health and safety of workers or the public will be dropped if necessary. These include:

• Internal HSE consultation on non-safety issues
• Inspection of lower risk activities
• Responding to repetitive complaints and requests for information where there is no demonstrated H&S benefit
• Assessment/inspection of subsea pipelines which do not (i) affect the safety of an installation or (ii) have the potential to create on-shore risks

Head of Gas and Pipelines Unit
June 2009