1. Offshore Safety Directive (OSD)
Update on the Merchant Shipping (OPRC) Regulations 2015
Nicholas Woollacott
DECC EDU OGED
18th December 2014

2. Introduction
Highlight post-consultation updates to the draft OPRC regulations
Confirm how proposals have been refined to implement the Directive
Detail the remaining challenges still to be resolved
Update on OPEP guidance project
Offshore Safety Directive – OPRC Update 18 December 2014

3. Changes Since Consultation
Changes: Definitions, Provision for Joint Plans and proposed UK Limitation on Approvals
Clarifications: Internal waters (via definitions), Material Changes and Well Operation updates
No changes since consultation in relation to required content of OPEPs:
Schedule 2 and Regulation 4(9) which detail what must be included in an OPEP remain unchanged
Offshore Safety Directive – OPRC Update 18 December 2014

4. Changes – Definitions 1
“Connected Infrastructure” - aligned with HSE requirements to include wells and supplementary units connected to an installation, and not as detailed in Article 2(21)
“Licence” - defined as per the new Licensing Regulations
“Offshore installation” - amended to distinguish between facilities in internal waters and facilities in the territorial sea or on the continental shelf
“Operator” - in relation to a production installation,
for matters relating to a well, means the well operator, and
in relation to all other matters means the “installation operator” (as per the new Licensing Regulations)
Offshore Safety Directive – OPRC Update 18 December 2014

5. Changes – Definitions 2
“Well operation” - definition now fully specified:
the drilling of a well, including the recommencement of drilling after a well has been completed, suspended or abandoned by plugging at the sea-bed; and
any operation in relation to a well during which there may be an accidental release of fluids from that well which could give rise to the risk of a major accident
“Well operator” - defined as per the new Licensing Regulations
Offshore Safety Directive – OPRC Update 18 December 2014

6. Changes – Application
To achieve a distinction in the regime for internal waters the wording has been clarified such that:
The OSD amendments to the regulations require that every responsible person in respect of an ‘Offshore Installation’ must have an OPEP
Any operations from a ‘facility’ that would be an Offshore Installation but for the geographic limitation in the amended definition are covered by an unchanged OPRC regime, in common with ‘Oil Handling Facilities’.
Offshore Safety Directive – OPRC Update 18 December 2014

7. Changes – Joint Plans
Ability to hold joint plans expanded such that there may be joint plans between:
Offshore installations, related facilities that would be installations but for the geographic limitation in the amended definition and related oil handling facilities which are pipelines
Offshore Safety Directive – OPRC Update 18 December 2014

8. Changes – UK Limitation
New limitation proposed:
Any OPEP approved by the Secretary of State is valid only when the offshore installation is located in UK waters or on the UKCS
Offshore Safety Directive – OPRC Update 18 December 2014

9. Changes – Material Changes and Well Operations
OPEP guidance will clarify that:
A ‘material change’ to a Safety Case will only require the OPEP to be updated if the change affects the approved oil spill response arrangements
Initial draft has been corrected to confirm that the OPEP update for well operations is the responsibility of the well operator
Offshore Safety Directive – OPRC Update 18 December 2014

10. Remaining Challenges Inspectorate powers and enforcement
Introduction of a mechanism whereby the current powers as derived from Part X of the Merchant Shipping Act 1995 are available for all OPEPs approved by the Secretary of State
Offshore Safety Directive – OPRC Update 18 December 2014

11. OPEP Guidance
OPEP guidance and assessment templates will be shared with industry in early January 2015
Meeting on 4th February 2015 of DECC / OGUK OPEP work group, to discuss feedback on new OPEP guidance
Post-publication of guidance, DECC will offer to meet companies with early OPEP submissions to clarify expectations based on specific circumstances
OSDR / Industry event 23 February 2015
Offshore Safety Directive – OPRC Update 18 December 2014