Cost recovery for the inspection of notifications for onshore 'boreholes'
This guidance provides an example of how cost recovery for the inspection of notifications submitted to HSE for onshore petroleum 'boreholes' will work, as per the requirements of the Health and Safety (Fees) Regulations 2021.
Part 2: Illustrative example of cost recovery activities
A borehole operator plans to drill and/or conduct an operation at a petroleum borehole site. The operator is required to submit a notification to HSE under regulation 6(1) and schedule 1, part 1, of the Borehole Sites and Operations Regulations 1995 (BSOR).
This is the first time this borehole operator has conducted such an operation and therefore contacts HSE for advice. The advice about what should be in a notification given before the notification is sent to HSE is not cost recoverable.
The borehole operator submits the notification, which is inspected by a specialist well engineering and operations inspector. This work is cost recoverable. The actual number of hours spent on the inspection will depend on the complexity of the borehole and the accuracy and completeness of the information contained in the notification.
Time spent on any questions asked by the inspector of the borehole operator and any correspondence between the borehole operator (or its consultants or agents) and the inspector is cost recoverable. The creation of the inspection summary record and review of it by the inspector's line manager is also cost recoverable.
In this instance, a follow-up inspection at the borehole operator's office and borehole site was deemed necessary by the inspector to confirm actions and risk mitigations in the notification are being implemented. Following this, a meeting at HSE offices was held to discuss the findings from the inspection. All of this work is cost recoverable.
General proactive inspections, not linked to the borehole notification, are not cost recoverable. The inspection of weekly operations reports, submitted to HSE under the requirements of regulation 19 of the Offshore Installations and Wells (Design and Construction, etc) Regulations 1996 (DCR), is not cost recoverable. However, if a contravention of the law is found at a borehole site, Fee for Intervention may be payable.