Health & Safety Report 2015

7. Regulatory Consultations

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Oil & Gas UK continues to serve as a focal point for industry response to regulatory consultations managed by HSE. The following consultations were completed in 2014.

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7.1 European Union Offshore Safety Directive As outlined in Section 5.1 of this report, DECC, HSE and industry, through Oil & Gas UK, have engaged extensively over the last two years to transpose the EU Offshore Safety Directive requirements into UK law by July 2015. As part of this process, a formal consultative document was published on both HSE and DECC websites on 28 July 2014 andwas open for comments for eight weeks. Oil &Gas UK’s Health& Safety and Environment Directorates consolidated industry views from members in response to the regulators. In addition, the majority of operator and duty holder companies made their own submissions, bringing the total number of responses to HSE/DECC to 65. The consultation concerned a number of key areas, including establishment of the CA, as mentioned in Section 5.1.

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One of the questions concerned the proposed approach to setting up the new CA. Five options were considered in the Regulatory Impact Assessment:

1. Do nothing 2. A DECC/HSE partnership CA to deliver the Directive requirements (that is major accidents only) 3. A DECC/HSE partnership CA covering all offshore safety and environmental regulation 4. HSE becomes the offshore safety and environmental CA 5. An independent ‘stand-alone’ offshore safety and environmental CA

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The consultation document identified option 2 as DECC and HSE’s preferred option.

The Oil & Gas UK consultation with members showed a strong preference for the creation of a single integrated safety and environment regulator. Following the consultation, the UK Government announced that it was to proceed with its preferred option of a DECC/HSE partnership to deliver regulatory oversight for major accident hazards only.

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7.2 Approved Codes of Practice

The Lὄfsted report on health and safety legislation published in November 2011 recommended that HSE reviews all approved codes of practices (ACoPs). The review was delayed for offshore specific ACoPs to account for changes arising from the EU Offshore Safety Directive and was completed as part of the Directive’s transposition process. The HSE sought industry views on proposed revisions to two established ACoPs, namely:

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• Prevention of Fire and Explosion, and Emergency Response (PFEER) • Health Care and First Aid on Offshore Installations and Pipeline Works

In line with the government’s drive to reduce the legislative burden on industry, while maintaining suitable standards of health and safety, the proposed revisions were geared towards clarifying and simplifying the ACoPs. As part of the response to the EU Offshore Safety Directive consultation (see above), Oil & Gas UK submitted industry responses that broadly supported the proposed revisions and offered only minor suggestions for improvement to the above ACoPs.

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