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Offshore Safety Directive (OSD) – Operational Implementation Team Progress Update February 2015 Rog Thomson OSDR Partnership/ HSE and DECC

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Offshore Safety Directive (OSD) –Operational Implementation Team

Progress Update

February 2015

Rog Thomson

OSDR Partnership/ HSE and DECC

2 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Introduction

The EU Offshore Safety Directive

• Takes effect 19th July 2015. UK must be up and

running by then.

• New Competent Authority required

• DECC & HSE working in partnership

• Referred to as ‘the OSDR partnership’

• Single regulatory face for major hazard regulation

• Website & portal

• Joint strategy and intervention planning

3 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Competent Authority - Governance

• Enhanced Memorandum of Understanding

• Articles of Governance

• Senior Oversight Board

• DECC Director Energy Development Unit and HSE

Director of Hazardous Installations Directorate

• Heads of HSE’s Energy Division & DECC’s OGED

• Operational Management Group

• Joint HSE & DECC planning

• Other Workgroups4 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

1. 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

5 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

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

6 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Safety Cases

• New regulations SCR2015

• All installations need to submit material change covering

• SEMS – Safety & Environmental Mgt System

• CMAPP – Corporate Major Accident Prevention Policy

• IERP – Internal Emergency Response Plan

• SECE – Safety & Environmentally Critical Elements

• Environmental information

• Transitional arrangements programme in place

• OSDR safety case assessment system refines existing

HSE one – consistent auditable trail.

7 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Reporting Requirements

• New requirements for what industry reports to

regulators and regulators report to European

Commission

• HSE and DECC working to integrate all offshore

reporting into one tool

• European Offshore Authorities Forum drafting

guidance

• Transitional arrangements - all installations together

or per installation transition?

8 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

• Licencee must not appoint operator without notifying

Licencing Authority 3 months beforehand, and Authority has

not objected

• Licencing Authority consults Competent Authority (OSDR)

• OSDR will have system for determining capacity of

proposed operator to comply with relevant statutory

provisions (RSPs)

• Licencee must ensure operator is capable and carries out

functions to comply with RSPs

• OSDR must immediately inform Licencing Authority if it

determines an operator no longer has the capacity to meet

requirements of RSPs

OSDR Involvement in Licencing

OSDR Partnership Processesincluding:

Safety Cases & Transitional Arrangements

Design/Relocation Notifications

Thorough Reviews

Katie McCabe

OSDR Partnership / HSE and DECC

OSDR Partnership Processes• Framework Diagrams proposed to describe all processes

• Agreed in principle by OSDR Implementation Teams and by HSE ED Management

• 22 Processes defined

• Series of workshops progressing development

• Safety Case related frameworks complete in draft form

– Safety Case Assessment

– Design / Relocation Notifications

– Thorough Review

– Well Notification

– Combined Operations

– Directed Revision

• Remaining 16 relate to managing incidents, inspections, reporting appeals and are progressing based on priority

•11 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Safety Case AssessmentNew - Material Change - Transitional

• Framework Diagram re-defines safety case assessment as an OSDR process

• Clarifies expectations and builds on existing good practise

• Supporting internal documents have been drafted:

– Assessment Instruction / Assessment Recommendation etc.

•Assessment templates for each Topic are being progressed and shared:

– Management System & Verification

– Environmental Information

– Environmental Operational Control

– Emergency Response (separate templates for production & non production)

– Fire Explosion & Risk Assessment

– Others in due course

• Initial Review Template being trialled and shared

12 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Safety Case Assessment & Templates

• Directly references regulatory requirements that are associated with each topic area

• Used to demonstrate that a Safety Case has been assessed against the specific requirements laid down in the regulations

13 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Safety Case Assessment & Templates• Regulations specifically state that certain things must be

included – much more prescriptive than we may be used to:

– CMAPP – requirements in Regulation 29, Schedules 2/3, 10 & 11

– SEMS – requirements in Regulations 12, 30, Schedules 2/3, 11 & 12

– Verification - Regulations 19, 20, 31 Schedules 2/3 & 7

– Keeping of documents – requirements in Regulation 18

• Where evidence is not found within the Safety Case that a specific legal requirement has been demonstrated OSDR will raise a ‘Non Acceptance Issue’

• ‘Clarification’ may be sought but informally and only to allow an inspector to be confident of their interpretation of the demonstration provided within the safety case.

14 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Safety Case Assessment & Templates• To avoid multiple ‘Non Acceptance Issues’ you must ensure

that all the requirements are demonstrated within the Case

• Some of these matters may already be present because you have drafted your cases in accordance with good practise -APOSC / GASCET etc

BUT

• Although you may have covered the issues in principle you may not have covered them in enough detail to demonstrate the exact requirements of the revised legislation have been met

• OSDR assessment will necessarily cover all the new and revised requirements of SCR2015

15 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Safety Case Assessment & TemplatesOSDR commitment to you

• We will focus on assessment of the Safety Case against the legislative requirements

• All Non Acceptance Issues raised will relate directly to a legislative requirement

• No more Level 3’s / Other Matters

Industry’s challenge…

• To ensure the Case meets the legislative requirements in full

16 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Transitional Case Trial• BP provided a case mid February

• Trial involving Admin, IMT and relevant topic specialist teams including Environmental disciplines:

– Test the process and understand the resource implications

– Aim to have a standard Assessment Instructions for all transitional cases

– Relevant topic specialists (inc. IMT) will trial their Topic Assessment Templates

– Understand the specific scope and requirements of a transitional assessment for each relevant discipline

– understand how to identify and manage Non Acceptance Issues

• Feedback to BP & industry on any differences in interpretation of the legislative requirements

17 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Transitional Arrangements• Slots have been allocated and communicated

• Good industry co-operation

• Some amendments to the timetable, all agreed and manageable

• Trial arranged for February will feed into final staff briefing –18/19 March

• Transitional cases expected to start arriving 1st April –

– Potential for Duty Holders to include partially completed ‘Initial Review Template’

• Admin developing the system to monitor receipts and track progress

• Management of workload and available resources being considered

18 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

New Safety Cases• All new Safety Cases to be assessed to new regulations from

19 July 2015

• From 1 April, for efficiency, encourage all new Cases to be drafted to and assessed in accordance with the new regulations

• Trialling the principle of the Topic Assessment Template on a number of new cases that are currently in the system

• Aim to have Topic Assessment Templates for all disciplines by 19 July 2015

• All new Cases will be subject to an ‘Initial Review’ against the requirements of Schedule 2/3 to ensure it has a ‘good prospect’ of acceptance

19 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Design & Relocation Notifications• All new Design & Relocation Notifications to be submitted to

new regulatory requirements from 19 July 2015

• Framework Diagram completed

• Changes to existing HSE process:

– ‘Inspection’ undertaken by all topic disciplines, now includes Environmental disciplines

– Inspection Instructions issued by IMT Focal Point Inspector will include an ‘Initial Review’ against the requirements of Schedule 1

– Topic Specialists to prepare Topic Inspection Report identifying Potential Non Acceptance Issues - topic disciplines to consider use of their Topic Assessment Templates

– IMT to collate and produce Inspection Conclusions Report and letter communicating Potential Non Acceptance Issues to the duty holder

– Dialogue may continue after the ‘inspection’ has been concluded

20 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Thorough Reviews• Thorough Review Summaries will continue to be submitted in

line with the existing schedule

– Those due in the transitional period should identify actions taken to meet new regulatory requirements of SCR2015

– We do not require Thorough Reviews to be completed early

• Framework Diagram drafted

• Minor changes to existing HSE process:

– Initial Review to determine topic disciplines to be involved

– Environmental disciplines included

– Inspection Conclusions Report produced by IMT which informs subsequent inspection priorities

21 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Offshore Safety Directive (OSD)

Update on the Merchant Shipping

(OPPRC) (Amendment) Regulations 2015Nick Woollacott

OSDR Partnership / HSE and DECC

Introduction

• Draft amendments to the OPRC Regulations and next steps

• Overview of draft OPEP Guidance – not a detailed review

23 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Draft OPRC Amendments

• Tracked change version of draft amendments circulated to industry on 26 January 2015

• All changes and clarifications presented to industry on 18 December 2014 carried forward as amendments to the regulations.

• New Changes: Concept of ‘Offshore Waters’ introduced.

• Further clarity provided as to the definition and application of ‘Connected infrastructure’

24 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

OPRC Regulations - next steps

• Detailed legal cross check between the draft SCR 2015 and the draft OPRC amendments

• OPRC regulations now in Ministerial write around

• Due to be laid before Parliament on 9 March 2015

25 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

OPEP Guidance

• Draft OPEP guidance and assessment templates shared on 26 January 2015

• Meeting on 4 February 2015 of DECC/OGUK OPEP work group to discuss draft OPEP guidance

• Comments being received and guidance will be amended as needed

• Open offer – DECC will meet companies with early OPEP submissions to clarify expectations based on specific circumstances

26 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

OPEP Guidance - Preparation

• In preparing the draft Guidance Industry comments relating to previous OPEP guidance were considered as were comments and recommendations from the groups established as part of the OSRF

• Wherever possible these comments and recommendations have been incorporated

27 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

OPEP Guidance - submissions

• OPEP submissions made in accordance with the timetable for the transitions of Safety Cases/OPEPs must follow the draft Guidance

• Any other OPEP submissions made before the amended OPRC regulations enter into force may be prepared in accordance with the current Guidance

• Operators may consider using the draft Guidance with immediate effect

28 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

OPEP Guidance – new content

• The required content of OPEPs remains predominantly consistent with previous Guidance. Certain changes have however been made and these include:

� The requirement for Non-Production Installations to hold an approved OPEP;

� References to the inventory of response equipment and an assessment of the effectiveness of oil spill response measures.

29 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

OPEP Guidance – next steps

• The Department will periodically amend the draft Guidance in the coming months as OPRC amendments become established.

• Feedback and comments welcome to assist this process. Comments should be sent to [email protected]

• Comments should be attributed to specific sections of the draft Guidance and submitted as a Word document (not tracked changes).

30 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

OPEP Assessment

• Assessment templates drafted

• Similar process and format to SC assessment templates

• Any NAI will prevent an OPEP being approved

• Clarifications will not stop approval of an OPEP but should be addressed in final controlled copies.

31 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Well NotificationsCombined Operations Notifications

Intervention Planning

Marc Nunn

OSDR Partnership / HSE and DECC

33

Well Notifications (WN)

• Well notifications still submitted to

[email protected]

by the Well Operator until OSDR Portal launched.

• A Temporary Operations OPEP may also need to be

submitted to DECC separately, via

[email protected]

for approval at the same time.

• HSE and DECC will be inspecting Well Notifications

jointly.

• Copies of the framework process and inspection

templates will be available on the OSDR website.

Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Well Notifications – Transitional Arrangements• Well Notifications for new operations starting after

19th July 2015 shall be prepared to the

requirements of SCR15:

• After an installation has transitioned to SCR15

• For well operations on a Production Installation

after 19th July 2016

• SCR05 will continue to apply until these dates.

34 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

• If a Well Operator has not already sent a copy of their Corporate Major

Accident Prevention Policy (CMAPP), and an adequate description of

their Safety and Environmental Management System, this will also be

required to be submitted with the WN.

• SEMS description is limited to the SEMS for the well operation.

Well Notifications (WN) Transitional ArrangementsNon-Production Installation (NPI)

NPI Safety

Case

Revised for

SCR15?

Well

Operator

already sent

its CMAPP /

SEMS

Submit WN to

SCR2005 via HSE

Submit:

• WN, & well operator

CMAPP and SEMS to

SCR2015 via HSE

• Temp. ops. OPEP via

DECC

Well Ops

Started

Before 19th

July 2015

Existing WN

acceptable – no

further action

required

YES

YES

YES

NO

NO

NO

Submit:

• WN to SCR2015 via

HSE

• Temp. ops. OPEP via

DECC

Well Notifications (WN) Transitional ArrangementsProduction Installation (PI)

PI Safety

Case

Revised for

SCR15?

Well

Operator

already sent

its CMAPP /

SEMS

Submit WN to

SCR2005 via HSE

Submit:

• WN, and well operator

CMAPP and SEMS to

SCR2015 via HSE

• Temp. ops. OPEP via

DECC

Well Ops

Started

Before 19th

July 2015

Existing WN

acceptable – no

further action

required.

YES

YES

YES

NONO

NO

Well Ops

After 19th

July 2016

NO

Submit:

• WN to SCR2015 via

HSE

• Temp. ops. OPEP via

DECC

YES

Combined Operations Notifications (CON)

• Combined Operations (COMOPS) Notifications

still submitted to [email protected] until OSDR

Portal is launched

• A copy of the Combined Operation bridging

document should also be submitted, which will

provide the additional information not already

covered by existing installations OPEPs

• HSE and DECC will be inspecting COMOPS

notifications jointly

• Copies of the framework process and assessment

templates will be available on the OSDR website

37 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

COMOPS Notifications - Timescales

• A CON to the requirements of SCR15 will be

required once the duty holder submitting the CON

has transitioned to SCR15

• Until such time, CONs shall continue to be

submitted under SCR05

• No requirement to submit a material change of a

CON for COMOPS started before 19th July 2015

• Expected that dutyholders will review the content of

internal bridging documents to ensure it covers the

additional requirements of SCR15

38 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Inspection Planning

• The Directive requires the Competent Authority to

produce annual inspection plans

• HSE and DECC, working together as the OSDR

Partnership, will have a joint intervention strategy,

and will develop joint intervention plans for the

regulation of major accident hazards

• Current thinking is that plans will run on a

calendar year basis, starting in January 2016

• Plans will include 15 months of activities, and will

be reviewed and re-issued every January

39 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Inspections

• HSE and DECC’s current strategies for the

inspection of Production Installations are similar

enough to be combined into the current HSE

intervention planning process.

• The approaches for MODU’s are different, and

this area will be developed further.

• There will be some joint HSE/DECC inspections

under the OSDR Partnership.

• The majority of DECC inspection activities will still

fall outside the remit of the Competent Authority.

40 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Reporting Arrangements

The Offshore Safety Directive (OSD) introduces :

• New offshore incident reporting requirements Directive/

Implementation Act • Report without delay when Major Accident occurs or may about to occur and

provide details of suitable measure

• Report on Major Accidents which occur outwith UKCS

• Accident Fatal/5 or more people injured

• Dangerous occurrence Unintended Release/Loss of Well Control/

Failure of SECE/Loss of Structural Integrity/

Vessel collisions/Helicopter Accidents/

Evacuation personnel/Environmental

•Reporting to EU/Public (Competent Authority - OSDR)

OSDR Partnership/HSE and DECC

Reporting Arrangements

Competent Authority reporting to EU

• Annual reporting is by calendar year

• Commences Jan 2016

• Work is underway to make changes to our existing

systems and processes in order to meet requirements

42 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Reporting Arrangements

Incident reporting to OSDR

• Duplicates many of the existing UK reporting arrangements

• Introduces some additional reporting requirements

• Seek to retain existing legislation via Ministerial Write Round

• Reporting comes into effect July 2015 (transitional)

• Reporting required when SC accepted against SCR2015

43 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Reporting Arrangements

Proposed way forward

• Retain the existing PON1 reporting arrangement

• All other reporting via one single reporting tool

- RIDDOR Webpage (access via RIDDOR/CA

Website/online Portal)

44 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015

Reporting Arrangements

•Framework Diagram

•Gap analysis undertaken against the respective legislation

•HSE/Industry discussions regarding the HCR reporting

•RIDDOR Team/Form Design/IT Solutions - changes to reporting

form/guidance

• James Munro, Jim Neilson and Kevin O’Carroll are assisting

the EU in the preparation of EU Guidance …

45 Offshore Safety Directive – DECC/HSE Presentation to Colleagues / Industry – 29 January / 23 February 2015