Offshore Safety Directive (OSD)
Update on the Merchant Shipping
(OPRC) Regulations 2015
Nicholas Woollacott
DECC EDU OGED
18th December 2014
Introduction
• Highlight post-consultation updates
to the draft OPRC regulations
• Confirm how proposals have been
refined to implement the Directive
• Detail the remaining challenges still
to be resolved
• Update on OPEP guidance project
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Offshore Safety Directive – OPRC Update 18 December 2014
Changes Since Consultation
3
•
Changes: Definitions, Provision for Joint Plans
and proposed UK Limitation on Approvals
•
Clarifications: Internal waters (via definitions),
Material Changes and Well Operation updates
•
No changes since consultation in relation to
required content of OPEPs:
o Schedule 2 and Regulation 4(9) which
detail what must be included in an OPEP
remain unchanged
Offshore Safety Directive – OPRC Update 18 December 2014
Changes – Definitions 1
•
“Connected Infrastructure” - aligned with HSE requirements to
include wells and supplementary units connected to an
installation, and not as detailed in Article 2(21)
•
“Licence” - defined as per the new Licensing Regulations
•
“Offshore installation” - amended to distinguish between
facilities in internal waters and facilities in the territorial sea or
on the continental shelf
•
“Operator” - in relation to a production installation,
– for matters relating to a well, means the well operator, and
– in relation to all other matters means the “installation
operator” (as per the new Licensing Regulations)
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Offshore Safety Directive – OPRC Update 18 December 2014
Changes – Definitions 2
•
“Well operation” - definition now fully specified:
o the drilling of a well, including the
recommencement of drilling after a well has been
completed, suspended or abandoned by plugging
at the sea-bed; and
o any operation in relation to a well during which
there may be an accidental release of fluids from
that well which could give rise to the risk of a major
accident
•
“Well operator” - defined as per the new Licensing
Regulations
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Offshore Safety Directive – OPRC Update 18 December 2014
Changes – Application
•
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To achieve a distinction in the regime for internal waters
the wording has been clarified such that:
o The OSD amendments to the regulations require
that every responsible person in respect of an
‘Offshore Installation’ must have an OPEP
o Any operations from a ‘facility’ that would be an
Offshore Installation but for the geographic
limitation in the amended definition are covered
by an unchanged OPRC regime, in common with
‘Oil Handling Facilities’.
Offshore Safety Directive – OPRC Update 18 December 2014
Changes – Joint Plans
•
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Ability to hold joint plans expanded such that
there may be joint plans between:
o Offshore installations, related facilities
that would be installations but for the
geographic limitation in the amended
definition and related oil handling
facilities which are pipelines
Offshore Safety Directive – OPRC Update 18 December 2014
Changes – UK Limitation
•
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New limitation proposed:
o Any OPEP approved by the Secretary of
State is valid only when the offshore
installation is located in UK waters or on
the UKCS
Offshore Safety Directive – OPRC Update 18 December 2014
Changes – Material Changes
and Well Operations
•
OPEP guidance will clarify that:
o A ‘material change’ to a Safety Case will only
require the OPEP to be updated if the change
affects the approved oil spill response
arrangements
•
Initial draft has been corrected to confirm that the
OPEP update for well operations is the responsibility
of the well operator
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Offshore Safety Directive – OPRC Update 18 December 2014
Remaining Challenges
•
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Inspectorate powers and enforcement
o Introduction of a mechanism whereby the
current powers as derived from Part X of
the Merchant Shipping Act 1995 are
available for all OPEPs approved by the
Secretary of State
Offshore Safety Directive – OPRC Update 18 December 2014
OPEP Guidance
•
OPEP guidance and assessment templates will be
shared with industry in early January 2015
•
Meeting on 4th February 2015 of DECC / OGUK OPEP
work group, to discuss feedback on new OPEP
guidance
•
Post-publication of guidance, DECC will offer to
meet companies with early OPEP submissions to
clarify expectations based on specific circumstances
•
OSDR / Industry event 23 February 2015
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Offshore Safety Directive – OPRC Update 18 December 2014