What Brexit means for UK Well Operators in terms of safety and environmental management.

The safety and environmental responsibilities of a well operator within the United Kingdom (UK) jurisdiction has, until recently, been largely dictated by the post-Macondo Directive 2013/30/EU of The European Parliament and of the Council of 12 June 2013, on safety of offshore oil and gas operations, and the amendment of Directive 2004/35/EC.

The Directive's aim was always to reduce the risk, as far as possible, of major offshore oil and gas incidents and to limit their consequences. The UK's implementation required a Competent Authority (CA) to hold various responsibilities regarding general regulation, Safety Cases, Oil Pollution Emergency Plans (OPEPs) and various other notifications, etc.

The Offshore Safety Directive Regulator (OSDR) was then created to fulfil the CA function. The OSDR comprised of the Department for Business, Energy & Industrial Strategy’s Offshore Petroleum Regulator for Environment & Decom (OPRED) and the Health & Safety Executive (HSE) who work together under a Memorandum of Understanding (MoU).

The CA inherited the role of overseeing compliance with the UK regulations that implement Directive 2013/30/EU. The regulations which enacted the EU Directive were The Offshore Petroleum Licensing (Offshore Safety Directive) Regulations 2015 and The Offshore Installations (Offshore Safety Directive) (Safety Cases etc.) Regulations 2015 (SCR15).

Following Brexit, and relaxation of the Directive, the OSDR changed name, but not purpose, to the Offshore Major Accident Regulator (OMAR) within which OPRED maintains responsibility for implementing offshore environmental legislation and the HSE continues as responsible for applying health and safety legislation for the offshore oil and gas industry.

This means the responsibilities of a UK well operator also remain unchanged with a focus on reducing the risk of major accident hazard (MAH) to as low as reasonably practicable (ALARP), the application of an appropriate Safety and Environmental Management System (SEMS) and Corporate Major Accident Prevention Policy (CMAPP), incorporation of best practice, independent well examination, emergency response provisions and mechanisms for well notifications, reporting incidents and raising safety concerns, etc.

I am proud to say that earlier in 2021 Vysus Group was comprehensively audited by an oil & gas UK HSE subject matter expert (SME). The SME was acting independently on behalf of a client to satisfy themselves that the duties imposed upon that client as licensee within Reg. 5 of SCR15 could be successfully completed by Vysus Group acting as a well operator.

Vysus Group’s Well Management division scored an impressive 36.1 out of 40 within the audit, with no non-conformances and several positive comments which identified industry best practices within our personnel and our ISO9001, ISO45001 and ISO14001 certified management system (all of our ISO certification scopes include well operatorship).

I am passionate about the energy sector, particularly within the UK, and would welcome any peer or wider cross-sector engagement on how we can collectively make the energy industry (renewable, oil & gas, etc.) a safer and more sustainable place to operate by carrying out the functions and 'discharging the duties of the operator under the relevant statutory provisions’.

If anyone would like to take me up on my offer and discuss any of the points within this article, then please get in touch for a formal meeting or an informal (coffee) conversation.

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