Offshore Safety Directive (OSD) – Operational ...

1 Offshore Safety Directive (OSD) Operational implementation TeamProgress update February 2015 Rog ThomsonOSDR Partnership/ HSE and DECC2 Offshore Safety Directive DECC/HSE Presentation to Colleagues / Industry 29 January / 23 February 2015 IntroductionThe 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 planning3 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 20151.

2 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 occurrences5 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 matters6 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 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

3 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 RSPsOSDR Involvement in LicencingOSDR Partnership Processesincluding: Safety Cases & Transitional ArrangementsDesign/Relocation Notifications Thorough ReviewsKatie McCabeOSDR Partnership / HSE and DECCOSDR 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.

4 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 shared12 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 regulations13 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.

5 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 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 etcBUT 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

6 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 MattersIndustry s To ensure the Case meets the legislative requirements in full16 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.)

7 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 requirements17 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 considered18 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.

8 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 acceptance19 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 concluded20 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

9 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 priorities21 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 2015 Nick WoollacottOSDR Partnership / HSE and DECCI ntroduction Draft amendments to the OPRC Regulations and next steps Overview of draft OPEP Guidance not a detailed review23 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.

10 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 201525 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