1. Oil & Gas UK Supplementary Guidance On The RIDDOR Reporting Of Hydrocarbon Releases
Mid 2011 discussions were held around the reporting criteria for small releases. It was agreed that there was a need to update the existing guidance, focussing on the limit for releases which are RIDDOR reportable.
A workgroup was set up in March to develop new Supplementary Guidance for HCR Reporting to ensure accurate and reliable approaches to HCR reporting.
New draft guidance was issued for review end Nov 2013 and presentations made to:
Major Hazards Management Forum
Health & Safety Forum
Step Change’s Asset Integrity Steering Group
IADC
HSE
All comments have now been received and incorporated into the guidance. All comments have been addressed.
Comments were mostly requests for clarification and suggestions for improvements.

2. Deliverables Guidance Assessment Tool Presentation + Notes
Assessment tool (excel spreadsheet) which contains the calculations supporting the guidance, ensures consistent understanding of the methodologies used to calculate the reportable limits, all references are in the public domain.
This presentation – for presenting to your teams and management. Ensures a consistent roll out of the guidance.
If a more technical presentation is planned then the basis for that can be taken from the Major Hazard Management Forum presentation which was presented in Oil & Gas UK Members can download this from the MHMF extranet.

3. Objectives of Workgroup
Produce supplementary guidance that is
Fully aligned with RIDDOR 2013 requirements
Well-understood by the industry
Consistently applied by the industry
Primarily focussed on petroleum hydrocarbon releases
Also includes assessment on non-petroleum hydrocarbon releases
Workgroup kick off March 2012
Objectives defined and communicated to Major Hazards Management Forum
Objectives are…
Main focus…
Main body of guidance 15 pages
Rest of document is examples and appendices to support the guidance
Key requirement was transparency of work, hence the detail in the appendices
Important requirement as previous guidance does not provide justification for the suggested reportable limits

4. Petroleum Hydrocarbon Releases
Reportable Limit
Major
Previous Guidance
Significant
2014 Guidance
Minor
Reportable Limit
This guidance is focussed on the reportability limit threshold – it will not affect the reportability of anything that is obviously a dangerous occurrence.
Existing guidance and RIDDOR text is not sufficiently clear – the grey area
Some operators reported lots of very small releases and others would only report the most significant releases
The new guidance draws a line to eliminate the grey area, and backs this up with documented references and calculations
The location of the line answers the question “which releases could cause a specified injury to, or the death of, any person?”
Not Reportable
Number of releases

5. Structure of Guidance Regulatory Requirements
Review of DO relating to Hydrocarbon Releases (HCR)
Methodology for Assessing RIDDOR Reporting of Petroleum Hydrocarbon Releases
Define key words and phrases
Reporting flow chart
Technical Assessment
Defines Reportable Limits
Case Studies
Worked Examples
Appendices
Consequence Analysis
Application of Methodology to Non-Petroleum Hydrocarbon Fluids
High Water Content Liquids
The guidance focuses primarily on the assessment of reportability for Petroleum Hydrocarbon Releases under RIDDOR DO 75. Section 2 of this document provides the relevant excerpt from RIDDOR for DO 75.
Additionally, Section 2 provides an overview of where other types of hydrocarbon releases are reportable under other sections of RIDDOR, including Wells Releases, Subsea Releases and Non Petroleum Hydrocarbon releases. This is summarised at the end of Section 2 in a table. (This table is also included in this presentation)
Section 3 of the guidance provides definitions of the key components of DO 75 and explains how each of these components is then used in determining the reportability of a petroleum hydrocarbon release.
A flowchart is provided in Appendix A to summarise the decision process for assessing reportability.
The final stage of the decision process for assessing reportability is the “potential for the release to cause death or a specified injury”. Section 4 provides the detail on the technical assessment of the potential consequences of a petroleum hydrocarbon release (i.e. jet fire, pool fire, fireball, etc.) and defines reportable limits based on the potential for these consequences to cause “death or a specified injury.”
The final section in the main body of the report provides a number of worked examples, covering a variety of different types of petroleum hydrocarbon release. This section is intended to show application of the guidance and reportable limits in practice. Users of the guidance are encouraged to provide additional examples to OGUK over time for inclusion in future revisions of the guidance.
The remainder of the document is appendices and back-up technical analysis to support the main body of the document. These sections provide further information on the consequence analysis methodology, how the methodology for petroleum HCRs can be applied to non-petroleum HCRs (DO 77) and how high water content liquids should be treated. The reportability flowcharts are also included in Appendices A and B.

6. Regulatory Requirements – RIDDOR 2013
Release of petroleum hydrocarbon
75 The unintentional release of petroleum hydrocarbon on or from an offshore installation which –
(a) results in –
(i) a fire or explosion; or
(ii) the taking of action to prevent or limit the consequences of a potential fire or explosion; or
(b) could cause a specified injury to, or the death of, any person.
Within DO 75 there are key word and phrases that are critical in determining whether a release is reportable. Each of these has been defined in the guidance.
For example:
Unintentional
Petroleum Hydrocarbon
Fire or explosion
Taking of action..
Consequences
Specified injury
(a)(i) deals with an ignited event and is always reportable. There is no reportable limit associated with this event.
(a)(ii) deals with the unignited event and therefore needs detailed assessment. There is a clear link between taking of action and consequence however consequence in (ii) is not explicitly defined in RIDDOR but it is defined in (b) therefore consequence is taken to mean “death or a specified injury”. Taking of action on its own does not mean the release is automatically reportable. The release must be of a certain size (rate or quantity released) before potential fire or explosion can cause death or a specified injury i.e. must exceed a reportable limit. Injury comes before death therefore the development of a reportable limit must be based on injury.
Not reportable - Intervention actions taken solely for the purpose of carrying out a repair PROVIDED the release rate or quantity released is below the reportable limit.
(b) Deals with other attributes of the release such as HC/H2S mixture (toxicity), narcosis of C5+, asphyxia, etc.
Specified Injury – Defined in RIDDOR
- A “specified injury” is defined in RIDDOR regulation 4(1)(a) to (h). For a potential fire or explosion this means:
4(i)(e) Any burn injury (including scalding) which—
covers more than 10% of the whole body’s total surface area; or
causes significant damage to the eyes, respiratory system or other vital organs;
All other specified injuries defined in regulation 4 consider equivalent to regulation 4(1)(e).
Also note that the consequence is dealing with a single person and is therefore not a MAH. MAH for fire and explosion is death or major injuries to persons (plural). RIDDOR is a higher standard than MAH regulations.
In all cases it is important to consider the potential consequence of a release rather the probable consequence of a release e.g. probability of ignition.

7. Technical Assessment – Potential for Death or a Specified Injury
Petroleum Hydrocarbons
Well Fluids, Natural Gas, Natural Gas Liquids, Condensate, Crude Oil
Continuous & Discrete Releases
Gas, Vapour, Mist, Liquid
Consequence Analysis
Continuous Release - Jet Fire
Continuous Release - Pool Fire
Discrete Release - Fireball
Discrete Release - Pool Fire
Flash fire, Explosion, Toxic Cloud, Asphyxia, Narcosis - See Guidance
Petroleum Hydrocarbons
Emphasise definition of Petroleum Hydrocarbon – fluids that come from reservoir and are processed.
Excludes fluids such as diesel, lube oil, helifuel, methanol, etc.
“Petroleum hydrocarbon” - In relation to DO 75, petroleum hydrocarbons are deemed to be reservoir fluids processed by, or conveyed to or from an offshore installation, namely;
well fluids;
natural gas;
condensate;
natural gas liquids (NGLs);
crude oil
Releases of liquefied natural gas (LNG) on an offshore facility, with the potential to cause death or a specified injury will be reportable under DO75 as the composition will be mainly natural gas.
Release or escape of substances other than petroleum hydrocarbons may also be RIDDOR reportable under DO 77.
Continuous & Discrete
Read definition from Guidance
Emphasise difference in duration of release: Discrete – Seconds, Continuous – minutes
No specific time defined for transition from discrete to continuous, this will be based on potential consequence of release and based on judgement
Fluids
All phases considered in guidance
Consequences
All potential consequences considered both unignited and ignited
Assessment showed for consequences in last bullet that either the potential for death or specified injury was not credible or reportable limit for jet & pool fire will be reached before reportable limit for these other consequences
Main body of guidance focuses on first four bullets

8. RIDDOR DO 75 Assessment Flowchart
Release of Petroleum Hydrocarbons
Defined in previous slide
Confirmed
Not explicit in RIDDOR 2013 definition but was in RIDDOR 95. We have retained this as it is an important step in determining if a release is reportable.
Indication on fixed, temporary or portable fire & gas detectors
Manual detection
Any other evidence that demonstrates that a loss of containment occurred
Not spurious
Unintentional
Unplanned or uncontrolled
Not planned release from vent or sample point
Fire or Explosion
Ignition
Guidance does not define ignition
Automatic Executive Action
Leading to stoppage of plant
Systems are designed to respond to potential major accident hazards
Other Action & Potential for Death or Specified Injury
This addresses taking of action which can be initiation of isolation & blowdown, removing people from the area, not starting up following a release, etc.
Taking action in itself does not mean the release will be reportable
For potential for death or a specified injury the release rate or quantity release must exceed a certain limit, this is the reportable limit developed in the Technical Assessment
In Summary
For a HCR on or from an offshore installation to be RIDDOR reportable it needs to:
Be a release of petroleum hydrocarbons; and
Be confirmed; and
Be an unintentional release; and
Result in a fire or explosion; or
Initiate automatic executive action; or
Require the taking of other actions to prevent or limit the potential for death or a specified injury to any person, from:
Potential fire or explosion; or
Another hazard not covered by the preceding sections of this guidance and as described in Section 3.6.

9. Reportable Limits Type of Release Phase Hazard Fluid Reportable Limit
Continuous
Gas / Vapour / Mist
Jet Fire
Natural Gas
Natural Gas Liquids
Condensate
Crude Oil
3 kg/hour
( kg/s) OR
20% LFL at 0.5 m
Liquid
Pool Fire
100 kg/hour
(0.028 kg/s)
Discrete
Fireball
0.15 kg
3 kg
10 kg
30 kg
Table 1, page 17.
Simple reportable limit for each release type
Combines the effects of all hazard types, but the worst cases are jet fire, pool fire, fire ball, pool fire (respectively)
Harm criteria documented in detail
It is the responsibility of the duty holder to determine the actual release rate
20% LFL at 0.5m is an alternative to a calculation and is equivalent to 3 kg/hour – not a statement about the hazard at 0.5m

10. Regulatory Requirements
Unignited Release
RIDDOR 2013
Dangerous Occurrence
RIDDOR
Reportable Limit
OIR/12
Wells
DO 20 No
All releases
Pipelines
DO 21
Yes
(See HSE Website)
Only if release is within 500m zone
Release of petroleum hydrocarbons
DO 75
(See Sections 3 & 4)
All RIDDOR DO 75 reportable releases
Release of non-petroleum hydrocarbons
DO 77
(See Section 5)
Not required
Ignited Release
RIDDOR 2013
Dangerous Occurrence
RIDDOR
Reportable Limit
OIR/12
Wells
DO 20 No
All releases
Pipelines
DO 21
Only if release is within 500m zone
Release of petroleum hydrocarbons
DO 75
All fires & explosions
Release of non-petroleum hydrocarbon fluids
DO 76
Not required
This table provides an overview of where offshore releases are reportable under different sections of RIDDOR including whether an OIR/12 submission is required. This includes both unignited and ignited releases.
The reportable limits for DO 21 are already defined on the HSE website. For DO 75 and DO 77, reportable limits are defined in this OGUK Guidance.
Note that OIR/12 forms are not required for non-petroleum hydrocarbons either ignited or unignited.

11. Forward Plan Go Live 1 April 2014 Guidance Assessment Tool
Presentation + Notes
Feedback Workshop October 2014
Usability of Guidance
Requirement for further guidance
Additional Examples
Assess impact of EU Offshore Safety Directive
April 2015 (subject to HSE guidance availability)
The guidance will be published on 1 April 2014 and available for download from Oil & Gas UK website.
Towards the end of 2014 a review of the guidance will be held; helpful if operators can collate feedback and examples over this period to assist the review.
The impact of the EU Offshore Safety Directive will be assessed and any amendments incorporated as needed once the new requirements have been incorporated into UK regulation and HSE guidance

12. Guidance on Hydrocarbon Release Reporting