Download - Eu Offshore Safety Directive
-
7/23/2019 Eu Offshore Safety Directive
1/16
EU Offshore Safety DirectiveImplementation and Implications
for Environmental Regulation
Derek Saward
Head, Environmental anagement !eam
DE"" Energy Development Unit #e$ruary %&'(
-
7/23/2019 Eu Offshore Safety Directive
2/16
EU "onclusions )fter acondo
Industry highly capa$le $ut* Strong safety culture insufficiently em$edded throughout the
industry
+ack of transparency and sharing of information
Some EU regulators -orth Sea. $est/in/class $ut*
#ragmentation of regulatory systems "ooperation is inconsistent
Safety and related environment issues are not coordinated
-eed consistent $est practice for safety and environment via formalrisk assessment and goal setting system involving*
Industry Regulators
"oordination and cooperation amongst regulators, and with non/EU countries
Source* EU Directorate General for Energy
2EU Offshore Safety Directive
Implementation and Implications for Environmental Regulation
-
7/23/2019 Eu Offshore Safety Directive
3/16
Directive O$0ectives
3EU Offshore Safety Directive
Implementation and Implications for Environmental Regulation
-
7/23/2019 Eu Offshore Safety Directive
4/16
Implementation easures
4EU Offshore Safety Directive
Implementation and Implications for Environmental Regulation
-
7/23/2019 Eu Offshore Safety Directive
5/16
em$er State Re1uirements
5EU Offshore Safety Directive
Implementation and Implications for Environmental Regulation
"ompetent )uthority "). to $e formed, integrating relevant safety andenvironmental issues
") to $e provided with ade1uate e2pert resources
") to assess and accept relevant su$missions from licensees,
operators and owners
") to $e provided with powers of enforcement to oversee complianceand prevent and investigate ma0or accidents and ma0or environmental
incidents
")s must cooperate in relation to notifying activities, ma0or accidents
and ma0or environmental incidents and emergency response
")s must cooperate through EUO)3 to raise standards and encourage$est practice
")s must report ma0or accidents and incidents and overall annual
performance to the "ommission
-
7/23/2019 Eu Offshore Safety Directive
6/16
!he U4 Implementation 5lan
DE"" and HSE, with support from Defra, the Devolved )uthorities, Df!, ")
etc6, are working together to deliver the U4 implementation plan
Regular meetings with HSE to consider how to meet the "ompetent )uthority
re1uirements
Regular meetings with HSE, Defra, Df! and ") to identify lead authorities
for specific articles and to discuss legislative changes
DE"" +ED +icensing will $e responsi$le for the licensing and operatorship
changes, and DE"" O3ED will $e responsi$le for the environmental changes
3ap analysis to assess impact on the DE"" licensing and environmental
regimes completed, and proposals to fill the gaps are currently $eing drafted
HSE will $e responsi$le for implementing the safety re1uirements
Defra and the Devolved )uthorities will $e responsi$le for amending
legislation to implement the changes to the Environmental +ia$ility Directive
Df! and ") will $e responsi$le for implementing re1uirements relating to
the E2ternal Emergency Response 5lan
6EU Offshore Safety Directive
Implementation and Implications for Environmental Regulation
-
7/23/2019 Eu Offshore Safety Directive
7/16
ain DE"" "hanges 7 +icensing
Directive re1uires functional separation of DE"" +ED +icensing and the
"ompetent )uthority 7 and therefore separation from DE"" O3ED
DE"" +ED, including +icensing, is likely to $e transferred to a new arms/
length $ody 8 agency to implement the recommendations of 9ood Review
DE"" +ED +icensing will have to amend licensing and operatorship
processes to meet Directive re1uirements
+icence and operatorship applications will have to include safety information,
in addition to current re1uirements relating to technical, financial, and
environmental capacity and environmental lia$ility
!he "ompetent )uthority will $e a formal consultee in the licence and
operatorship application processes
Operators must $e competent to undertake the proposed operations or the
"ompetent )uthority will $e a$le to re1uest that they are replaced
DE"" +ED +icensing amendments could involve changes to legislation,
model clauses or regulatory guidance
7EU Offshore Safety Directive
Implementation and Implications for Environmental Regulation
-
7/23/2019 Eu Offshore Safety Directive
8/16
ain DE"" "hanges /
Environment
8EU Offshore Safety Directive
Implementation and Implications for Environmental Regulation
Design and a0or Ha:ards Reports will include environmental components,
similar to some of the information included in EI)s
Safety and Environmental anagement Systems and Safety and
Environmentally "ritical Elements will $e su$0ect to environmental review
Independently verified well notifications and weekly well operations reports
will $e su$0ect to environmental review
Oil 5ollution Emergency 5lan re1uirements e2tended and merged with otheraspects of emergency response Internal Emergency Response 5lan.
Environmental o$ligations on licensees, operators and owners, and all could
$e lia$le for environmental damage
Improving environmental standards and formulating $est practice to $e
included in work of EU regulators group EUO)3.
!ransparency and sharing of information via EU/wide reporting system
covering environmental incidents and near/misses
Environmental issues to $e included in formal "ompetent )uthority 8
Industry 8 !rade Union tripartite consultation
-
7/23/2019 Eu Offshore Safety Directive
9/16
Regulatory "hanges 7 "urrent
!houghts
9EU Offshore Safety Directive
Implementation and Implications for Environmental Regulation
ost of the changes will affect the HSE legislative regime, and offshore safety
legislation will $e replaced or updated to incorporate Directive re1uirements
Defra and the Devolved )uthorities will $e amending the Environmental Damage
Regulations to incorporate the changes detailed in )rticle ;t
$e included in the new regulations as it would $e =gold plating>.
-ew regulations will amend the O5R" Regulations to e2tend the O5E5
re1uirements to the owners of non/production installations
#or drilling operations involving a oDU, the owner of the oDU would
prepare an O5E5 for the non/production installation essentially the same as
the current SO5E5., and the operator would prepare an addendum to that
plan to cover the drilling operation
-ew regulations will amend the O5R" Regulations to re1uire an approved
O5E5 to $e in place prior to commencing the proposed activities
-ew regulations will introduce a charging scheme for the O5R" Regulations
this may follow later if it could delay new regulations.
!he e2isting O5E5 guidance will $e updated to reflect the changes relating
to transposition of the Directive
-
7/23/2019 Eu Offshore Safety Directive
14/16
Environmental Regulatory "hanges
14EU Offshore Safety DirectiveImplementation and Implications for Environmental Regulation
!here will $e a new re1uirement to descri$e the IER5 $ased on summaries
of the O5E5 and the 5#EER. in the a0or Ha:ards Report
-ew regulations may re1uire the use of suita$le technical measures in order
to promote the relia$ility of the collection and recording of relevant data and
to prevent its manipulation
-ew regulations will fill any gaps in the environmental notification and
reporting re1uirements no gaps are currently anticipated, $ut we have still
to receive EUO)3 conclusions relating to data collection and sharing.
If necessary, new regulations will specify information sharing re1uirements
for DE"" 8 HSE
) "ompetent )uthority 5ortal is considered to $e the $est way to manage
the su$mission, sharing, review and acceptance 8 approval of the Directive
su$missions and any related su$missions e6g6 the O5E5.
)mendments to the Environmental Damage Regulations will e2tend the
Environmental +ia$ility Directive provisions to all activities, not 0ust oil and
gas, anywhere on the U4"S, and licensees, operators and owners could all
$e lia$le for environmental damage
-
7/23/2019 Eu Offshore Safety Directive
15/16
!imeta$le
15EU Offshore Safety DirectiveImplementation and Implications for Environmental Regulation
Directive came into force on '< @uly %&';
Interim we$site launched A @anuary %&'(
http*88www6hse6gov6uk8offshore8directive6htm
9orkshops and Industry #ocus 3roups in arch and )pril %&'(
#ormal consultation on implementation proposals scheduled for @une 7
Septem$er %&'( -ew guidance to $e pu$lished in B'8B% %&'?
-ew legislation must come into force to meet implementation deadline of
'C @uly %&'?
-ew production installations and all non/production installations and well
operations must comply $y 'C @uly %&'A
!ransitional arrangements for e2isting production installations will
commence in %&'? and all must comply $y 'C @uly %&'