Offshore Division (OSD) is responsible for regulating the risks to health and safety arising from work in the offshore oil and gas industry on the UK Continental Shelf (UKCS). Our priority work is the major hazard work for which OSD operates a permissioning regime. Our core activities are:
We also:
The industry set a tough challenge in proposing a target of a 50% reduction on the 2009/10 total of hydrocarbon releases (HCRs), with a target for end year 2012/2013 in the region of ninety four. We will continue to support this industry objective and for our part will investigate all major and significant releases in accordance with our procedures as detailed in SPC/TECH/OSD/48, as we want to encourage a greater focus on identification of root cause for such releases, and ensure industry as a whole shares and learns lessons to help in minimising future similar releases. We will also continue to monitor duty holder performance against their HCR action plans.
OSD’s inspection programme of ageing and life extension, known as KP4, was launched to the offshore industry in July 2010. KP4 will run to December 2013 and involves both onshore and offshore inspection of duty holders’ management systems. The programme will determine the extent to which asset integrity risks associated with ageing and life extension are being managed effectively by duty holders, and will place emphasis on the development and promotion of good practice in the industry to ensure continued safety. There is a challenging programme of duty holder inspections during 2012/13. HSE will issue an interim KP4 progress report during 2012/13.
In responding to the issues arising out of the Macondo and Montara well blow-outs in the USA and Australia respectively in 2009/10, OSD set up its internal Deepwater Horizon Incident Review Group (DHIRG) to provide a forum to assess the implications of those incidents for the UKCS and ourselves as the regulator. DHIRG will continue during 2012/13 as the final reports are received from the US investigations.
In 2010/11 OSD increased its frequency of assessing well control issues by including this aspect at all offshore inspections of mobile drilling rigs. This will continue into 2012/13.
The verification scheme as applied to well control equipment is one of the key aspects of the UKCS regulatory regime that would aid in preventing an incident like Deepwater Horizon. We will continue our focused inspection programme to gauge compliance with the Offshore Installations (Safety Case) Regulations 2005, regulation 19.
During 2012/13, OSD will continue to develop its expectations for an effective blow out prevention (BOP) integrity management system, to be followed by structured inspections to test compliance. This will include the following initiatives.
A key theme of the HSE strategy is to motivate others in the health and safety system to address their responsibilities in a common sense and proportionate manner and contribute to improving health and safety performance. In 2010/11 OSD undertook a pilot exercise on leadership interventions with duty holder managing directors.
OSD will be continuing its leadership interventions with managing directors building on the successful pilot interventions from 2011/12.
During 2010/11 HSE undertook an inspection programme of work to check industry compliance with the provisions of SI971 (Offshore Installations (Safety Representatives and Safety Committees) Regulations 1989). The findings of this project, which highlights best practice findings, were published on the offshore website. The report was also forwarded to the Step Change Workforce Engagement group, and the OIAC Workforce Involvement Group (WIG), to take forward in their respective work.
There are a number of inspection initiatives aimed at creating healthier safer workplaces offshore, these include asbestos, noise and vibration, and food, water and welfare.
Asbestos: operational intelligence gathered through planned inspections, an industry survey (2007/09) and investigations of incidents involving asbestos, has identified serious deficiencies in the management of asbestos. HSE has therefore begun a three year programme to improve duty holder awareness and their effective management of asbestos offshore.
Food, Water and Welfare: following on from the food and water inspection project (2008/2011), HSE will be running another 3 year inspection initiative. This will follow-up on outstanding food and water management issues and also look at welfare standards offshore e.g. accommodation, rest rooms etc.
Noise and Vibration: an inspection initiative on noise and vibration is to run from 2012 to 2015 and will focus on:
OSD works with a wide range of stakeholders as a means of driving forward improvements in health and safety within the UKCS and as a global concern. We participate in various forums and working groups on an international and European front. We are actively involved in various forums such as the International Regulators Forum (IRF), the North Sea Offshore Authorities Forum (NSOAF) and bilateral meetings with our counterparts in major producing neighbours, including the Norwegian Petroleum Safety Authority, the State Supervision of Mines the Netherlands and the Danish energy Agency.
Key partnership working arrangements during 2012/13 include:
Department of Energy & Climate Change (DECC): In addition to working with DECC and the Maritime and Coastguard Agency (MCA) on the formal review of the UK’s offshore oil and gas regulatory approach we are also working more closely with DECC in sharing common regulatory information. We have recently revised the existing memorandum of understanding (MoU) accordingly, and now meet regularly in an HSE/DECC Joint Coordinating Group.
Offshore Industry Advisory Committee (OIAC): OIAC is a tripartite committee and includes members representing employers, employees, unions, trade associations and government departments. The head of OSD, Steve Walker, continues to chair this committee, which meets twice a year. Particularly active is the Workforce Involvement Group (WIG), which OSD chairs. WIG is continuing to work with partners to develop an additional training matrix for safety representatives to include examples of good practice. The intention is to seek the Step Change Leadership Team support in the promotion of use of the training matrix as industry wide best practice. In addition to this, WIG intends to host two further workforce events in 2012/13. Details will be available via the WIG website.
Step Change in Safety: Step Change is a unique industry group established in 1997 with the aim to make the UK the safest place to work in the worldwide oil and gas industry. OSD continues to work with Step Change as a member of the Step Change Leadership Team and on many of the working groups. Step Change Strategic Plan 2010/15 aims to deliver major improvements in the whole industry’s safety performance and is the key way in which the UK offshore industry responded to take the HSE Strategy forward:
Wells Life Cycle Practises Forum (WLCPF): This is the key legacy industry forum for wells issues following the winding up of OSPRAG in 2011. OSD is represented on the main group, and also has representatives of the Wells Group on other working groups when appropriate.
North Sea Offshore Authorities Forum (NSOAF): This forum of offshore regulators working in the North Sea is influential, and provides good opportunities to establish common standards and regulatory approaches across the North Sea offshore industry. The head of OSD has taken over the chair of NSOAF in May, and OSD is also leading on the development of a cross-North Sea NSOAF audit of the human factor related aspects of well control, learning the lessons from Macondo.
Other Offshore Regulators: Our objective is to exchange our intelligence and share approaches to help consistency of regulatory approach and sharing of best practice not only from a European perspective but also on a global front via the International Regulators Forum (IRF). OSD chairs the IRF Sub-Group on standards and the Head of OSD, Steve Walker, attends the main Forum meetings.
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