An amended regulatory regime for health, safety and environmental matters will arise from implementation of EU Directive 2013/30/EU on the safety of oil and gas operations (the Directive).
The regulatory changes fundamentally affect all installation Safety Cases and Oil Pollution Emergency Plans (OPEPs). To continue operating installations in the UKCS, Operators and Owners will need to submit a revised Safety Case and have it accepted before the relevant transition date. Existing OPEPs will also require updating and approval, and non-production installations will need an approved OPEP for the first time.
During the transitional phase, revised regulations will take effect, and existing Safety Cases will need to be revised to satisfy the new requirements:
Officials from the DECC Oil & Gas Environment & Decommissioning Unit and the HSE Energy Division are jointly working on practical arrangements to sequence submissions of revised Safety Cases and OPEPs to achieve compliance with the transitional arrangements for all UK Oil and Gas installations in a coherently managed way. Accordingly, Operators and Owners of Offshore Installations are being requested to submit revisions to Safety Cases and OPEPs according to a schedule requested by OSDR.
The scheduled dates take into account that assessment of a material change Safety Case requires a minimum of three months from submission to acceptance. The dates are part of a broader, overall schedule that identifies time-slots for all UK installations and takes into account the needs of owners, operators and regulatory authorities. It also enables synchronisation between Safety Cases and OPEP submissions.
Operators and Owners of existing installations are requested to indicate if it is decided not to revise a Safety Case, so that the time-slot reserved for assessment can be reallocated.
Operators and Owners are not requested to complete any Thorough Review process early. The timing of planned through reviews will remain unchanged, as it affects the overall schedule for assessing revised cases for many installations.
In exceptional circumstances, and where justified, there may be merit in re-considering the timing of submissions, for example in circumstances of an imminent material change to a Safety Case or update to an OPEP for operational reasons. In such situations, there is a potential benefit in combining the changes brought about for operational reasons with the Directive updates to create one single submission. If this is likely, Owners and Operators should contact HSE to discuss the timing of such submissions.
Should companies wish to discuss any of the matters above, they should contact their usual HSE Focal Point Inspector or, in the case of OPEPs, please refer to the usual DECC contact.
Inspectors assessing Safety Cases will be guided by Assessment Templates. This will ensure each Safety Case meets all the regulatory requirements and the assessment process is transparent. For Cases that are being updated to reflect the new requirements, Assessors will only consider information that has changed within the Case, and information that is required to support new regulatory requirements. A full assessment will only be conducted for new cases and this should limit the burden on both industry and the regulator.