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Offshore Safety Directive (OSD) –Operational Implementation Team
Progress Update
6 October 2014
2 EU Directive 2013/30/EU Competent Authority Update 6 October 2014
Introduction
The EU Offshore Safety Directive
• Takes effect 19 July 2015. UK must be up and running by then.
• There will be a Competent Authority• DECC & HSE working in partnership• Name and brand• Website & portal
• Competent Authority the new offshore regulatory body for major hazards
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Competent Authority - Governance
• Governed by DECC Director Energy Development Unit and HSE Director of Hazardous Installations Directorate
• Using an enhanced Memorandum of Understanding
• Operational implementation by HSE Head of Energy Division and DECC Head of OGED
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Competent Authority – Business Processes
• Business processes for:• Safety Case & Oil Pollution Emergency Plan
Assessment• Thorough Reviews• Combined Operations & Wells notifications• Intervention planning• Investigation of major incidents• Complaints• Reporting of incidents and dangerous occurrences
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Major Accident & Major Environmental Incident
• In the OSD there can be no major environmental incident without an associated major accident.
• An environmental incident with no major safety accident potential is simply a pollution incident (and not in scope of the OSD/Competent Authority)
• Outside the scope of the Directive:• DECC deals with pollution and environmental
matters• HSE deals with health and safety matters
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Safety Cases• New regulations SCR2015• All installations need to submit material change• Need to cover:
• SEMS – Safety & Environmental Mgt System• CMAPP – Corporate Major Accident Prevention Policy• IERP – Internal Emergency Response Plan• SECE – Safety & Environmentally Critical Elements
• Transitional arrangements are complex• Taking opportunity to review and revise some aspects
of assessment process
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Safety Cases
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Safety Case Assessment Process Map
Assessment Templates
Timetable & Transitional Provisions
Assessment in Practice
SMS/EMS in Practice
Katie McCabe/Andrew TaylorThe Competent Authority / HSE and DECC
Safety Cases
Safety Case Assessment Framework Diagram• Details the process on one page
• Clearly outlines roles and responsibilities
• Clearly outlines steps and timescales involved
• Links to all relevant documents
• Provides clarity for all partiesFramework - Safety Case Assessment - DRAFT for comment - Sept 2014.DOC
Look at in detail
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Assessment Templates
• Aids consistency and improves transparency• Shares expectation with industry• Improves efficiency
Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 18 September / 6 October 2014EU Directive 2013/30/EU Competent Authority Update 6 October 201411 EU Directive 2013/30/EU Competent Authority Update 6 October 2014
SMS Template• SMS Assessment Template DRAFT for comment Sept 2014.DOC
•Directly references regulatory requirements that are associated with this topic area
•CMAPP // SMS // Verification
•EMS are not included at present
• Recognise that management systems are inter related – Working with DECC to determine how we can manage this
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Timetable & Transitional Provisions
• ~300 Safety cases to bring through 14(2) process in 3 years, by 19 July 2018.
• Slots allocated to manage the workload both for industry and ourselves
• Based on TR dates, then allocated with due regard for DHs and HSE teams
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• Assessment managed within teams by focal point inspectors• DECC and Environment is an additional topic specialism• Clear expectation for depth and timeframe• Dedicated “peak-shaving” support resource?
Assessment in Practice
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SMS/EMS in Practise
• SMS requirements are in Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations - SCR2015
• EMS requirements are in The Offshore Petroleum Activities (Offshore Safety Directive) (Environmental Functions) Regulations 2015 – EF2015
• SCR and OSDEF regulations allow for a joint SEMS description. In response to consultation EMS requirements may move to SCR.
• Conscious of need not to replicate assessment
and avoid differences of opinion
• Working together to have a single output
for assessment of management systems
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Safety Case Summary
• Framework Diagram outlines process
• Assessment Templates guide the assessment
• Timetable and transitional arrangements are based on TR dates
• Timely assessment and communication will be the key to success
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Oil Pollution Emergency Plans
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Oil Pollution Emergency Plans
• OPEP requirements for- Non Production Installation Owners- Well Operators- Production Installation Operators- Pipeline Operators- Decommissioning
• Adequate description expectations• Assessment Templates• Submission timeframes/transitional provisions
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Owners of Non Production Installations
• New requirement from OSD.• OPEP and PFEER plans form IERP arrangements• Owners OPEP only contains the non-location specific
requirements of the OSD:• Training• Persons responsible for response initiation• Reporting requirements• Arrangements for exercises & retention of evidence• Worst case scenario description
• Interface arrangements with subsequent OPEP addendums
• Submitted to CA (DECC) to align with time frame of Safety Case submissions.
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Well Operators
• Appointed by the Licensee(s) and responsible for the submission of an addendum to the NPI OPEP.
• Addendum will contain the location specific requirements of the OSD and extant OPRC regulations.
• New OSD derived requirements:• Inventory of response equipment• Assessment of the effectiveness of oil spill response measures
• Submitted to CA (DECC) 2 months prior to requirement – alignment with Well Notification?
• DECC Examining how any response measures provided by Licensed Operator be included.
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Production Installation Operators
• Appointed by the Licensee(s) and responsible for the submission of the field/installation OPEP.
• New OSD derived requirements:• Inventory of response equipment• Assessment of the effectiveness of oil spill response measures
• Well Operations from Production Installation – may necessitate an addendum from the Well Operator.
• Subsea infrastructure – included in Production Installation plan if in licensed area.
• Well Operator of any tie back infrastructure in other licensed area – looking to retain flexibility
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Pipeline Operators
• Interconnectors – No changes• Trunk pipelines that are connected infrastructure
• Update current OPEPs to reflect new OSD IERP requirements
• Pipelines included in current production OPEPs• Included in scope of OPEP updates for production
installation operators
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Decommissioning
• OSD extends definition of oil and gas activities to include decommissioning activities
• OPRC regulations amended to require a plan during decommissioning phase – not in current regime.
• Decommissioning OPEP will have to meet the requirements of the OSD IERP.
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Oil Pollution Emergency Plans
• Adequate description expectations• Assessment Templates• Submission timeframes/transitional provisions
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Incident Reporting
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Reporting Arrangements
•New offshore incident reporting requirements – Implementation Act (10 Criteria Reporting Criteria.doc )
- Competent Authority
•Reporting of Incidents comes into force July 2015
•Competent Authority reporting - Annual Basis (Jan – Dec)- Commences Yr 2016- Europe- Public
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Website & Offshore Portal
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Competent Authority Website• A CA Website is being prepared,
initially hosted as a micro-site on the HSE website.
• Important to recognise this is a joint CA website, not a HSE website.
• Will be used to publish details on:– CA Governance– Guidance for industry
• As new guidance is prepared, it is the intention to make this available on the website.
• Website URL:– www.hse.gov.uk/OSDR
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Competent Authority IT Portal• An IT Portal will be developed for
Operators and Owners to submit permissioning documents:
– Safety Cases – Well Notifications– Combined Ops Notifications– Design Notifications– Thorough Review Summaries– Oil Pollution Emergency Plans
• Will be based upon existing DECC IT systems.
• Initial scoping of specification for the portal started.
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Further Communication
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• Events – future• Articles in industry publications• Regulator Training
Questions?
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