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Reporting of Pipeline Incidents under RIDDOR - HSE additional guidance

Background

The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR), detail in Schedule 2, Part 1, Paragraph 14, dangerous occurrences that should be reported for pipelines or pipeline works. In some cases it may not be clear immediately whether an incident is a dangerous occurrence. This guidance provides examples to aid reporting decisions for some of the more common occurrences detailed in paragraph 14.

Who should report Pipeline Dangerous Occurrences under RIDDOR

The responsibility for reporting pipeline dangerous occurrences rests with the pipeline operator as defined by the Pipelines Safety Regulations 1996.

Pipeline Release

This is covered by Schedule 2, Part 1, Paragraph 14(a) which states the following is reportable “the uncontrolled or accidental escape of anything from, or inrush of anything into, a pipeline which has the potential to cause the death of, major injury or damage to the health of any person or which results in the pipeline being shut down for more than 24 hours”.

Examples:

  1. A contractor carrying out excavation work damages an onshore gas pipeline, causing an uncontrolled release of gas. The gas cloud could ignite causing overpressure, heat radiation and the potential for death, major injury or damage to health. The matter is reportable.
  2. An offshore pipeline corrodes and results in an uncontrolled release of a small amount of oil remote from an installation. A small release may disperse naturally and is unlikely to cause the death of, major injury or damage to the health of any person. This release is not reportable. The pipeline operator on discovering the leak shuts the pipeline down for repairs, which take longer than 24 hours. The matter is now reportable.
  3. During an ROV inspection a minor leak is discovered at a valve stem. The pipeline operator must assess any potential risks arising from the leak but it is unlikely that any immediate remedial attention or action will be required. The operator may decide to repair or replace the valve at some future date during planned maintenance. As the essential integrity of the pipeline has not been breached and this leak was not an indication of more serious problems the matter is not reportable under RIDDOR. If the operator decides to shut down the line for more than 24 hours the matter is reportable. The matter remains reportable even if the main reason for shutting the line is protection of the environment.

Pipeline Damage

This is covered by Schedule 2, Part 1, Paragraph 14(c) which states the following is reportable “any damage to any part of a pipeline which has the potential to cause the death of, major injury or damage to the health of any person or which results in the pipeline being shut down for more than 24 hours”.

Examples:

  1. An onshore gas pipeline is severely scored by an excavation contractor. The damage has the potential to cause a rupture which could cause death, major injury or damage to health. The matter is reportable.
  2. A pipeline corrodes and results in a much reduced wall thickness. Subsequently the pipeline operator carries out some intelligent pigging, which identifies the pipeline damage. The pipeline operator on discovering the damage causes the pipeline to be shut down as a precautionary measure for repairs or further assessment, which takes longer than 24 hours. The matter is reportable.
  3. An offshore pipeline is damaged when a dropped object from a loading operation strikes the pipeline. It is known that the pipeline is in good condition and the combined operations assessment has identified that objects of the weight of the dropped object will not result in critical damage to the pipeline. On this basis the operator does not shut down the pipeline but arranges for a more detailed assessment with an ROV at the next opportunity. This is not reportable. However, if later the operator decides to shut down the line for repairs for more than 24 hours the matter then becomes reportable.

Pipeline Isolation Failure

This is covered by Schedule 2, Part 1, Paragraph 14(f) which states the following is reportable “any failure of any pipeline isolating device, equipment or system which has the potential to cause the death of, major injury or damage to the health of any person or which results in the pipeline being shut down for more than 24 hours”.

Typical pipeline isolation devices are ESDVs, SSIVs, slam shut valves, stopples, expanding plugs, ice plugs, etc.

Examples:

  1. An offshore ESDV becomes damaged and is inoperable. The failure of this device to correctly operate could place workers at risk of death, major injury or damage to health if an incident occurred. The failure is reportable.
  2. An offshore ESDV fails to operate first time on demand or for an inspection test. The failure of this device to operate correctly could place workers at risk of death, major injury or damage to health if an incident occurred. The failure is reportable.
  3. An onshore slam shut valve fails to operate causing the over pressurisation of the downstream system. This has the potential to cause a rupture which could cause death, major injury or damage to health. The matter is reportable.

Issue Date: 19 February 2008
Gas and Pipelines Unit