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7. Regulatory Consultations

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.

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.

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

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.

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:

• 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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