Shale gas health and safety regulations
The well operator is responsible for ensuring the safety of the well and the site. HSE inspectors scrutinise the working practices adopted by operators to ensure operators manage and control safety risks, conforming to the requirements of the Health and Safety at Work etc. Act 1974, and the following regulations made under the Act:
- The Borehole Site and Operations Regulations 1995 (BSOR) apply to all oil and gas well operations onshore, including shale gas operations. These regulations are primarily concerned with the health and safety management of the site and set out requirements for a notification to be sent to HSE prior to the start of well construction, if there is a material change in the operation and prior to abandonment. A safety document must be produced by the well operator and communicated to everyone on the well site.
- The Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996 (DCR) apply to all wells drilled with a view to the extraction of petroleum (including shale gas) regardless of whether they are onshore or offshore. These regulations are primarily concerned with well integrity. They also set out requirements for a weekly report to be sent to HSE so that there is continued scrutiny of the drilling and abandonment operations and for an independent well examiner to be appointed by the well operator.
- The Reporting of Injuries Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) establish a specific set of Wells Dangerous Occurrences in Schedule 2, Part I, that the well operator has to report to HSE. Reporting of well incidents enables the HSE Energy Division (ED) to investigate those that would have an effect on well integrity and ensures the well operator secures improvements to his operations. These are:
- A blowout (i.e. an uncontrolled flow of well fluids);
- The use of blow out prevention equipment to control an unplanned flow;
- The unexpected detection of H2S (hydrogen sulphide);
- Failure to maintain minimum separation distance between wells;
- Mechanical failure of any safety critical element of a well.
Health and Safety Regulatory Regime
For the drilling process, HSE initially scrutinises the well design to ensure that health and safety risks are properly identified and systems are in place to properly manage them. Specialist inspectors then monitor progress on the well to determine if the operator is conducting operations as planned.
An oil and gas well is a complex engineered construction and the key to well integrity inspection is to ensure that the operator is managing risks effectively throughout the life cycle of the well. To ensure this, HSE uses an inspection and assessment process consisting of the following main elements, all of which utilise HSE’s experienced specialist wells inspectors:
- meetings with new or first time well operators prior to the operational phase will be undertaken (including joint meetings with the EA;
- assessment of well notifications submitted to HSE. This assesses well design prior to construction, a key phase of work where the vast majority of issues likely to have an impact on well integrity will be identified and addressed by the well operator;
- monitoring of well operations during construction based on weekly operations reports submitted to HSE by the well operators. This ensures the construction phase matches the design intent;
- there will also be a joint site inspection with the EA to assess well integrity during the construction phase. Unannounced site inspections may also be conducted at any time as deemed appropriate. Any such meetings and visits could include other interested parties e.g. The Minerals Planning Authority or DECC.
Ensuring public safety in the vicinity of fracking sites
The well operator is responsible for ensuring public safety within, and in the direct vicinity of, the work activities, following the industry model code of safe practice. HSE is responsible for regulating this requirement.