Oil and gas companies will need to ensure that their existing contractual arrangements relating to information sharing and reporting enable them to comply with the enhanced reporting requirements of the Offshore Safety Directive (“OSD”). We take a quick look below at the new reporting requirements that will be introduced into UK law by the transposition of the OSD.
Reporting accidents outside the EU
UK registered companies conducting offshore oil and gas operations outside the EU as licence holders or operators will be required to submit reports, on request, to the UK Government in respect of any major accident in which they have been involved outside the EU. These reports will then be exchanged with competent authorities of other Member States. Wide ranging and onerous information requests may follow. Companies will also need to be mindful of the potential liability implications of disclosing such information.
Corporate major accident prevention policy
Operators of EU production installations and owners of EU non-production installations will have to produce corporate major accident prevention policies covering their installations within the EU. This is a new requirement. The policies will need to specify the extent to which equivalent policies are in place for operations outside the EU.
Operators and owners will need to prepare major hazard reports for their installations. These will need to be approved by the competent authority before any operations can start or be continued. These reports will be similar to the current UK safety case but will need to consider environmental as well as safety matters.