Offshore Safety Directive (OSD) – DECC Presentation

1 Offshore Safety Directive (OSD) Operational Implementation TeamProgress Update 6 October 20142EU Directive 2013/30/EU Competent Authority Update 6 October 2014 IntroductionThe 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 hazards3EU Directive 2013/30/EU Competent Authority Update 6 October 2014 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 OGED4EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Competent Authority Business Processes

2 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 occurrences5EU Directive 2013/30/EU Competent Authority Update 6 October 2014 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 matters6EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Safety Cases New regulations SCR2015 All installations need to submit material change Need to cover.

3 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 process7EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Safety Cases8EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Safety Case Assessment Process MapAssessment TemplatesTimetable & Transitional ProvisionsAssessment in PracticeSMS/EMS in PracticeKatie McCabe/Andrew TaylorThe Competent Authority / HSE and DECCS afety CasesSafety 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 at in detail10EU Directive 2013/30/EU Competent Authority Update 6 October 201410 EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Assessment Templates Aids consistency and improves transparency Shares expectation with industry Improves efficiencyOffshore Safety Directive DECC/HSE Presentation to

4 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 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 this12EU Directive 2013/30/EU Competent Authority Update 6 October 201412 EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Timetable & Transitional Provisions ~300 Safety cases to bring through 14(2) process in 3 years, by 19 July 2018.

5 Slots allocated to manage the workload both for industry and ourselves Based on TR dates, then allocated with due regard for DHs and HSE teams13024681012 Apr-15 Jul-15 Oct-15 Jan-16 Apr-16 Jul-16 Oct-16 Jan-17 Apr-17 Jul-17 Oct-17 Jan-18 Apr-18 Jul-18 MonthNumber of CasesEU Directive 2013/30/EU Competent Authority Update 6 October 201413 EU Directive 2013/30/EU Competent Authority Update 6 October 2014 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 Practice14EU Directive 2013/30/EU Competent Authority Update 6 October 201414 EU Directive 2013/30/EU Competent Authority Update 6 October 2014 SMS/EMS in Practise SMS requirements are in Offshore Installations ( Offshore Safety Directive ) ( Safety Case etc.)

6 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 systems15EU Directive 2013/30/EU Competent Authority Update 6 October 201415 EU Directive 2013/30/EU Competent Authority Update 6 October 2014 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 success16EU Directive 2013/30/EU Competent Authority Update 6 October 201416 EU Directive 2013/30/EU Competent Authority Update

7 6 October 2014 Oil Pollution Emergency Plans17EU Directive 2013/30/EU Competent Authority Update 6 October 201417 EU Directive 2013/30/EU Competent Authority Update 6 October 2014 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 provisions18EU Directive 2013/30/EU Competent Authority Update 6 October 2014 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.

8 19EU Directive 2013/30/EU Competent Authority Update 6 October 2014 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. 20EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Production Installation Operators Appointed by the Licensee(s) and responsible for the submission of the field/installation OPEP.

9 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 21EU Directive 2013/30/EU Competent Authority Update 6 October 2014 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 22EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Decommissioning OSD extends definition of oil and gas activities to include decommissioning activities OPRC

10 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. 23EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Oil Pollution Emergency Plans Adequate description expectations Assessment Templates Submission timeframes/transitional provisions24EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Incident Reporting25EU Directive 2013/30/EU Competent Authority Update 6 October 201425 EU Directive 2013/30/EU Competent Authority Update 6 October 2014 Reporting Arrangements New Offshore incident reporting requirements Implementation Act (10 Criteria Reporting )