Implementing Regulation under the Safety of Offshore Oil and Gas Operations Directive for the standardisation of reporting of incidents in the offshore oil and gas industry enters into force – all change?

On Tuesday 11 November 2014, the Implementing Regulation (No. 1112/2014) entered into force, following its adoption by the European Commission a few weeks ago.

The Regulation implements the requirements under Articles 23(1) and 24(1) of the Offshore Oil and Gas Safety Directive (No. 2013/330) for the sharing of details of major hazard indicators by operators and owners of offshore oil and gas facilities in a common format.

The information to be reported and shared relates to incidents such as unintended release of oil, gas and other hazardous substances; loss of well control; significant loss of structural integrity; failure of a safety and environmental critical element; fatal accidents; helicopter accidents on or near offshore installations; and vessel collisions with an offshore installation and others (Annex IX of the Directive).

Operators in the North Sea will already be very familiar with the reporting requirements and standard forms in the UK, such as the Petroleum Operations Notice (PON1) to be sent to DECC, JNCC and the Coastguard and RIDDOR reports. In fact, section A of Annex 1 to the Regulation, which sets out the format for information for unintended release of hydrocarbons or other hazardous substances, is almost identical to the HSE hydrocarbon release supplementary information report (Form OIR12).

Under the Regulation operators will be obliged to report an incident in the specified format within 10 working days of the event. Currently operators have until 4 weeks following the incident to file the supplementary information form OIR12 to the HSE, if applicable. Operators’ duties of reporting will in certain instances therefore be subject to shorter timescales than before.

Member States will be obliged to share, i.e. publish, all the collated information from its operators no later than 1 June of the following year. The reporting period will be each year from 1 January until 31 December, with 2016 being the first reporting year.

In practice, the effect of this Regulation will be marginal to those operating in the North Sea, given the requirements and high standards to which UK and other offshore facilities there already operate. It will be other European countries and its operators that may consider this a change to their procedures and operations.

Please use the following links to see the text of the Regulation and Directive.