Notifying and Reporting Incidents - HSE: Information about ...

1 Health and Safety ExecutiveIndustry briefing Event: Notifying and Reporting IncidentsOSDR Industry briefing March 20161 Welcome & Introduction Reporting Law & Overlapping Legal Requirements The EU Implementing Regulation in Detail Relevant Guidance on incident Reporting Events A to J Report of an Oil & Gas incident (ROGI form) Introduction Detail of the form Wells & Pipelines Case Studies, Scenarios Questions & AnswersOSDR Industry briefing March 20162 Health and Safety ExecutiveReporting Law: GB and EUOverlapping RequirementsOSDR Industry briefing March 20163 incident Reporting Relevant Legislation RIDDOR DCR Reg 9 MAR Regs 21A, 21B, 21C and 21H SCR2015 Reg 29 SCR2015 Reg 33 Supplementary Reporting of HCRs Petroleum Operations Notices EU Commission Implementing RegulationOSDR Industry briefing March 20164 incident Reporting Relevant Legislation RIDDOR DCR Reg 9 MAR Regs 21A, 21B, 21C and 21H SCR2015 Reg 29 SCR2015 Reg 33 Supplementary Reporting of HCRs Petroleum Operations Notices EU Commission Implementing RegulationOSDR Industry briefing March 20165 RIDDOR If you are still using the L73 document then get up to date!

2 A revision to RIDDOR came into force in October 2013. RIDDOR was further amended by SCR2015, because of the requirements of the European Offshore Directive Guidance to RIDDOR is available onlineOSDR Industry briefing March 20166 RIDDOR Work Offshore Offshore workers are normally accommodated offshore in between their work shifts. RIDDOR Regulation 2(3) provides that injuries to workers while off-shift when offshore are reportable in the same way as injuries during work shifts. For the purposes of the regulations a person at an offshore workplace is deemed to be at work at all times when the person is there in connection with his/her work Includes being on other installations when travellingOSDR Industry briefing March 20167 RIDDOR Who Reports Reg 3 - Responsible Person must report The Responsible Person (RP) is normally the employer Except at an offshore installation when it is the duty holder for everything other than: Occupational diseases, exposure to carcinogens, mutagens & biological agents.

3 Diseases And except for dangerous occurrences at: a pipeline (the pipeline operator is the RP) a well (the well operator is the RP)OSDR Industry briefing March 20168 RIDDOR - Notifying and Reporting Deadlines RIDDOR (and several other statutory provisions) requires that the responsible person notifiesby the quickest practicable means; for example, in the event of: any major injuries & fatal accidents and; Incidents with the potential to be, or escalate to, a major incident . In practice, the quickest practicable means is to notify by phone(and the legislative guidance says so eg L154 paras 318 and 334)OSDR Industry briefing March 20169 RIDDOR - Notifying and Reporting Deadlines RIDDOR Reg 13 requires that, in the event of a fatal accident, major injury; the place where the incident happened must not be disturbed, or anything tampered with for three days after notification of the incident or the place has been visited by an inspector Reg 13 does not prohibit any person doing things with the consent of an Inspector, and allows for action necessary to secure the safety or integrity of the workplace or of any person, plant, vessel or well.

4 OSDR Industry briefing March 201610 RIDDOR - Notifying and Reporting Deadlines A written report must be made of: Offshore deaths and major injuries within 10 days. Other offshore reportable Incidents within 10 working days. A working day means any day other than a Saturday, Sunday, Christmas Day, Good Friday, or a bank holiday under the Banking and Financial Dealings Act 1971 in any part of Great Britain).OSDR Industry briefing March 201611 RIDDOR Responsible Person Must Report Non fatal injuries to workers (Reg 4) Non fatal injuries to non-workers (Reg 5) Work related fatalities (Reg 6) Dangerous occurrences (Reg 7) Occupational diseases (Reg 8) Diseases offshore (Reg 10) Exposure to carcinogens, mutagens and biological agents (Reg 9)OSDR Industry briefing March 201612 RIDDOR Injuries and IncapacitationNon fatal injuries - Regs 4(1) & 5 Where a person suffers a defined accident at work the responsible person must report it.

5 The regulations define the reportable incapacitated for routine work - Reg4(2) Where person is incapacitated for routine work for more than seven consecutive days, the responsible person must send a report as soon as practicable and in any event within 15 days of the accident. OSDR Industry briefing March 201613 RIDDOR Dangerous Occurrences OffshoreHCRs - Schedule 2 Pt 6 Para unintentional release of petroleum hydrocarbon on or from an offshore installation which (a) results in(i) a fire or explosion; or(ii) the taking of action to prevent or limit the consequences of a potential fire or explosion; or(b)could cause a specified injury to, or the death of, any Industry briefing March 201614 RIDDOR Dangerous Occurrences OffshoreFire or Explosion - Schedule 2 Pt 6 Para fire or explosion at an offshore installation, other than one caused by the release of petroleum hydrocarbon, which results in the stoppage of plant or the suspension of normal workOSDR Industry briefing March 201615 RIDDOR Dangerous Occurrences OffshoreRelease of Dangerous Substance - Schedule 2 Pt 6 Para unintentional or uncontrolled release or escape of any substance (other than petroleum hydrocarbon) on or from an offshore installation which could cause a significant risk of personal injury to any person.

6 OSDR Industry briefing March 201616 RIDDOR Dangerous Occurrences OffshoreSchedule 2 Pt 6 Offshore Dangerous Occurrences Para 78 Unintended collapses that threaten integrity 79 Failure of station keeping equipment 80 Dropped objects that could cause injury 81 Weather damage that could cause injury 82 Vessel or aircraft collisions, or 83 potential collisionsOSDR Industry briefing March 201617 RIDDOR Dangerous Occurrences OffshoreSchedule 2 Pt 6 Offshore Dangerous Occurrences Para 84 Seabed subsidence that threatens integrity 85 Loss of stability or buoyancy, any incident 86 Partial or complete evacuation of installation 87 Person falling into the waterOSDR Industry briefing March 201618 RIDDOR Dangerous OccurrencesWells and Pipelines Para 20 Wells Applies onshore and offshore Reportable by the well operator Some overlap with HCR Reporting Para 21 Pipelines Applies onshore and offshore Reportable by the pipeline operator Again, some overlap with HCR Reporting if in the 500m zoneOSDR Industry briefing March 201619 incident Reporting Relevant Legislation RIDDOR DCR Reg 9 MAR Regs 21A, 21B, 21C and 21H SCR2015 Reg 29 SCR2015 Reg 33 Supplementary Reporting of HCRs Petroleum Operations Notices EU Commission Implementing RegulationOSDR Industry briefing March 201620 DCR Danger to an Installation Reg 9(1)

7 The duty holder shall ensure that, within 10 working days after the appearance of evidence of a significant threat to the integrity of an installation, a report is made to the Executive in writing identifying such threat and specifying any action taken or to be taken to avert it. DCR 9(2) Paragraph (1) shall not apply to anything of which the Reporting of Injuries, Diseases and Dangerous Occurrences regulations 1995(1) require a report to be made. OSDR Industry briefing March 201621 incident Reporting Relevant Legislation RIDDOR DCR Reg 9 MARRegs 21A, 21B, 21C and 21H SCR2015 Reg 29 SCR2015 Reg 33 Supplementary Reporting of HCRs Petroleum Operations Notices EU Commission Implementing RegulationOSDR Industry briefing March 201622 MAR Notifying Death or Loss of a PersonReg 21 - a return of death in the form set out in Schedule 3 must be made when any person: dies on an offshore installation or; is lost from the installation or; dies in or on a lifeboat, life raft or other emergency survival craft belonging to an offshore installation or; is lost from any of those places.

8 Or otherwise dies or is lost in the neighbourhood of an offshore installation while engaged in any operation connected with the installationOSDR Industry briefing March 201623 MAR Notifying Death or Loss of a PersonRegulation 21B The OIM completes Part 1 of the form and sends it to the duty holder as soon as is practicable and in any event within ten days Within 10 days from receipt, the duty holder completes Part 2 of the form and sends it to the Registrar General of Merchant Shipping & Seamen HSE Form OIR8 is the form, but it is planned to integrate this in the ROGI form and withdraw OIR8 OSDR Industry briefing March 201624 Notifying and Reporting Incidents - MARO bligation to notify death or loss of personRegulation 21C Within 48 hours of first becoming aware of the death or loss of the person, the duty holder must Notify the next of kin if the duty holder was the employer or; Notify the person s employer if the duty holder is not the employer.

9 Liaise with the Police over this in Industry briefing March 201625 Notifying and Reporting Incidents - MAR RIDDOR DCR Reg 9 MARRegs 21A, 21B, 21C and 21H SCR2015 Reg 29 SCR2015 Reg 33 Supplementary Reporting of HCRs Petroleum Operations Notices EU Commission Implementing RegulationOSDR Industry briefing March 201626 Notifying and Reporting Incidents - MARR egulation 21H - Safety Zone Infringement Certain types of vessels are prohibited from entering or remaining in a safety zone except with the consent of HSE; or consent given by the duty holder. A contravention of regulations means the vessel owner and master are potentially guilty of an offence and liable on conviction to a fine and/or imprisonment. Safety Zone infringements are reported using HSE form OIR13. Not changed by the ROGI formOSDR Industry briefing March 201627 incident Reporting Relevant Legislation RIDDOR DCR Reg 9 MAR Regs 21A, 21B, 21C and 21H SCR2015 Reg 29 SCR2015 Reg 33 Supplementary Reporting of HCRs Petroleum Operations Notices EU Commission Implementing RegulationOSDR Industry briefing March 201628 Notifying and Reporting Incidents SCR15 SCR 2015 Notification of major accident etc Reg 33 - duty on the operator, well operator or owner (as applicable) to notify the competent authority without delay of a major accident or a situation where there is an immediate risk of a major accident.

10 The notification should provide as much detail as necessary to give a reasonable understanding of the event. Almost inevitably RIDDOR plus other Reporting provisions will require a subsequent Industry briefing March 201629 Notifying and Reporting Incidents SCR15 SCR 2015 Regulation 29 - Duty to Control Risk Reg 29 - The competent authority must be notified without delay where: a dutyholder takes suitable measures to reduce the risk from an activity which significantly increases the risk of a major accident Reg 29 itself requires no written report to be submitted later, but it is possible a written report will be required (eg under RIDDOR)OSDR Industry briefing March 201630 Notifying and Reporting Incidents SCR15 SCR 2015 Reg 29 Potential Examples Cumulative Risk resulting in a decision to shut down production.