The Health and Safety Executive (HSE) recently published their latest annual Offshore Statistics & Regulatory Activity Report 2015 (the “Report”). The data is a validated snapshot of operation information from HSE systems, and is published as Official Statistics.  2015 is the first year that the Report has been based on a calendar year from 1 January 2015 to 31 December 2015, instead of the prior-used fiscal year statistics. The Report indicates that it has, where possible, used calendar year statistics from previous years.  For some statistics from previous years this has not been possible, which could have a minor yet unidentifiable impact on the results. When compared directly to previous years, 2015 shows overall positive results.

The Report includes:

  1. Statistical data of offshore injuries, dangerous occurrences, and ill health reported to HSE under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (“RIDDOR”); and   
  2. The HSE’s regulatory activity relating to the offshore industry during 2015.

The Report includes data from incidents occurring on offshore installations, wells, pipelines, windfarms, and diving operations. Additionally, the information relating to HSE regulatory activity includes safety case assessments, complaints, inspections, investigations, and enforcement.

RIDDOR Statistics

Overall, injury rates (including fatalities) sit at 352 per 100,000 full-time equivalent workers for 2015.  The Report goes into detail on the following topics:

  • There were no fatal injuries in 2015. In the last 5 years, there have been 3 fatalities, and in the last 10 years there have been 7;  
  • There were 33 specified injuries, which form a rate of 103 per 100,000 full-time equivalent workers - this has increased from 28 reported in 2014 and a rate of 83 per 100,000. Fractures accounted for the vast majority of these at 91%, which is similar to previous years;  
  • There were 80 over-7-day injuries, compared to 145 in 2014, and 106 in 2013;  
  • There were 15 occurrences of occupational disease – a slight decrease from 18 in the previous year. Between 2012 and 2015, viral and bacterial conditions had the highest reports, followed by musculoskeletal and skin conditions; and   
  • There were 299 dangerous occurrences – a decrease of over a quarter compared to last year. 94, almost a third, resulted from hydrocarbon releases, the same number as 2014.  Releases are classified on the basis of their severity, and the release rate is based on the level of production in million barrels of oil equivalent per day. As a result of the new EU Commission Implementing Regulation No. 1112/2014, some of HSE’s voluntary notification schemes became mandatory, some classifications changed and so potentially more hydrocarbon release incidents are now being included in the scope.

For RIDDOR, a number of changes to the reporting system and legal requirements have occurred in recent years to simplify the process and ensure collected data portrays a more accurate and useful picture of workplace incidents. Changes have included the ‘major’ injury to workers definition being changed to a list of ‘specified’ injuries, the reporting threshold is now over-7-days off work rather than over-3-days, and the way in which employers report incidents is now predominantly online. This does mean that comparisons can be more difficult to make and care must be taken.

Regulatory activity

During 2015, the HSE:

  • Implemented arrangements for prioritising major hazard inspections offshore, with a focus on high hazard and poor performing installations.  In 2015, 135 planned inspections were undertaken at 104 offshore installations, operated by 47 operators;  
  • Assessed 97 safety cases; an increase of 39% from last year which reflects the flurry of activity following changes arising from the Offshore Safety Directive;  
  • Inspected 92 installations; completed by HSE’s Energy Division (“ED Offshore”), an increase from 58 in 2014;  
  • Investigated 63 workplace health and safety concerns raised by employees, compared to 56 in 2014. Any employee can raise a health and safety concern with HSE if they believe that health and safety law is being broken or minimum standards are being ignored; and  
  • Raised 752 non-compliance issues with operators. These are identified at or during inspections.

ED Offshore applies the principles detailed in HSE’s Enforcement Policy Statement when enforcing health and safety legislation. For more serious offences, inspectors may serve notices or prosecute if the incident is serious enough or notices are not complied with. In 2015:

  • 34 improvement notices were issued, and 1 prohibition notice was issued; and  
  • There were 2 prosecution cases instituted and heard, both resulting in convictions. One related to an injury to an employee, and the other related to a large-scale gas release.

Comment

Although some figures have remained largely the same or only shown marginal fluctuation, the Report generally seems to show improvements in health and safety in the offshore industry: there were no fatal injuries in 2015, and decreases can be seen in both over-7-day injuries and dangerous occurrences.

In terms of regulatory activity, the HSE are making progress with the assessment of revised safety cases as a result of recent legislative changes brought in to implement the Offshore Safety Directive.  As for the number of inspections, this is still lower than in years 2011 – 2013, however the explanation provided by the HSE is that the focus on high hazard, poor performing installations is the cause of lower numbers of in-depth and targeted inspections.  This sends a clear message to dutyholders, regarding the importance of maintaining a good health and safety record, as poor performance will be targeted.  In addition, the highest number of employee raised concerns since the earliest record in the report (2011) was recorded, further emphasising the high standards required of dutyholders.

Finally, the number of investigations completed by the HSE – 92, compared to the low level of prosecutions – two, potentially highlights the continuing delay in the overall regulatory process.

The Report can be downloaded from the HSE website.

For further information on health and safety offshore, Oil & Gas UK also produce an annual health and safety report, which can be found here.