OFFSHORE SAFETY DIRECTIVE
In January 2017 the Offshore Safety Directive 2013/30/EU (in short: OSD) was implemented in the Dutch legislation. The OSD is applicable to offshore installations related to the exploration and production of oil and gas. It was decided in the Netherlands to declare the OSD partly applicable also for onshore oil and gas installations.
For new installations the OSD regulations are applicable from July 2016, while for existing installations the new regulations are applicable from July 2018. Staatstoezicht op de Mijnen (SodM) has to approve the Report on Major Hazards for offshore installations. For onshore installations an approval is not required; a letter of no objection suffices.
The main aspects of the OSD are:
- Each operator is obliged to prepare a Major Hazard Report (MHR) for every installation. This report resembles the Safety Report (SR) from the Seveso legislation in which consistent presentation of data and scenario-based thinking is key. Additionally, the Safety and Health Document (often referred to as Safety Case) is still required from the existing mining sections in the Dutch Health and Safety legislation. It is expected that the MHR and the Safety Case will be combined into one document and assessed as such. An important distinction between the MHR and the Safety Case is the clear focus on major hazards and the additional assessment of environmental hazards.
- Each operator is required to (1) identify Safety and Environmental Critical Elements (SECEs) for each installation, (2) to specify performance standards for these systems and (3) to assure their function and operation during their lifetime (external verification and internal assurance). The first two elements are already part of the Safety Case, but the requirement of external verification and internal assurance is new for the Dutch operators. Each installation needs a verification scheme which will guide the external verification of the performance of the SECEs. In addition, the internal assurance should be risk-based. The verification of SECEs is required to be carried out by an independent party.
- Each Member State must have a competent authority for the enforcement of the OSD legislation. At European level, a cooperation will be set up to allow the various authorities to exchange knowledge and experience. The objective is to formulate best practices for reporting, risk assessment, verification and implementation of SECEs.
HOW CAN TREECON HELP WITH THE IMPLEMENTATION OF THE OSD LEGISLATION?
- TREECON has extensive experience and knowledge in developing and maintaining Safety Cases for different operators, for both onshore and offshore installations. We are also experienced in preparing safety reports for natural gas storage in compliance with Seveso legislation. Therefore TREECON can prepare the combined reporting of MHR and Safety Cases in an efficient manner. With our experience in UK Safety Case Regulations for operators active in the United Kingdom, where the verification of SECEs already has been implemented, TREECON is well known with SECEs and the associated performance standards necessary for the fulfilment of the requirements of the OSD legislation. Our knowledge from the UK enables us to develop the design and maintenance of the SECEs in a way that fits your business.
- TREECON can support the operator in managing the performance of the SECEs during the operational phase (internal assurance). Together with maintenance management consultants we can develop and implement maintenance strategies and schemes for SECEs.
- Alternatively, TREECON can act as an Independent Verifier and in that capacity draft the SECE verification schemes (written schemes of verification) to comply with the regulations.
For more information, please contact us.
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