Health and Safety Executive

Offshore Statistics & Regulatory Activity Report 2020

Contents Preface .......................................................................................................... 2

Executive Summary ....................................................................................... 3

Industry profile ............................................................................................... 3

Regulatory activity: HSE inspections, investigations, concerns and safety case assessments ......................................................................................... 4

Dutyholder performance: Topic scores and non-compliance issues .............. 9

Dutyholder incidents: Dangerous occurrences and Hydrocarbon releases .. 14

Personal safety incidents: RIDDOR reported injuries and diseases ............. 16

Explanatory notes ........................................................................................ 22

Preface HSE is responsible for regulating health and safety matters offshore. The Health and Safety at Work etc Act 1974 (HSWA), supported by the HSWA (Application outside Great Britain) Order 2013, defines HSE's jurisdiction. HSE works with other regulators under Memorandum of Understandings and agency agreements where there are potential overlaps in responsibilities In July 2015, HSE and the Department of Energy and Climate Change (DECC) created the Offshore Major Accident Regulator (OMAR) (previously known as the Offshore Safety Directive Regulator (OSDR)), which is the Competent Authority (CA) responsible for implementing the requirements of the EU Directive on the safety of offshore oil and gas operations. The Department for Business, Energy and Industrial Strategy (BEIS) was created on 14 July 2016 as a result of a merger between the DECC and the Department for Business, Innovation and Skills. OMAR is therefore now a partnership jointly managed and operated by BEIS’s Offshore Petroleum Regulator for Environment & Decommissioning unit (OPRED) and HSE. The Oil and Gas Authority (OGA) became an Executive Agency of DECC on 1 April 2015 and on 1 October 2016 was incorporated as a Government Company with the Secretary of State for BEIS as the sole shareholder. The OGA licence oil and gas exploration and extraction and operates independently from BEIS and HSE.

This Offshore Statistics & Regulatory Activity Report provides details of HSE’s regulatory activity offshore during 2020 and offshore injuries, dangerous occurrences and ill health reported to HSE under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR). The data in this report is a frozen, validated snapshot of operational information from HSE systems, and is published as Official Statistics. Wherever possible, data is based on a calendar year. Data for the most recent year is marked with a ‘p’ for provisional to allow for minor adjustments to be made when they are released as final in the subsequent annual report. This may be necessary if there are, for example, late reports or corrections. In practice, such changes are infrequent and would usually make a negligible difference to the numbers.

General inclusions to this report The regulatory activity information includes the following:  Safety case assessments  Complaints (Concerns)  Inspections  Investigations  Enforcement (Notices and Prosecutions) The RIDDOR data includes incidents occurring on:  offshore installations  offshore wells and activities in connection with them  offshore pipelines, pipeline works and certain activities in connection with pipeline works  offshore diving operations

General exclusions to this report This Offshore Statistics & Regulatory Activity Report does not include:  Incidents arising from marine activities that are not directly connected with offshore operations (e.g. vessels or rigs in transit). The Maritime and Coastguard Agency (MCA) has primary responsibility for maritime safety. Information on marine incidents can be found on the MCA website at www.gov.uk/government/organisations/maritime-and-coastguard-agency.  Air transport activities (including transport to, from or between installations), except incidents involving helicopters whilst on an offshore installation. The Civil Aviation Authority (CAA) has responsibility for aircraft flight safety. HSE has responsibility to ensure that heli-decks on offshore installations are safe. Information on air transport incidents can be found on the CAA website at www.caa.co.uk. Oil & Gas UK (OGUK), the leading representative body for the UK offshore industry, also produce an annual health and safety report. This can be found on their website at www.oilandgasuk.co.uk.

Executive summary Regulatory activity in 2020:  There were 157 inspections undertaken at 116 offshore installations  84 investigations were completed  36 workplace health and safety concerns were followed up  85 safety cases were assessed

Dutyholder performance in 2020:  899 non-compliance issues were raised with operators  26 enforcement notices were issued (24 improvement notices and two prohibition notices)  There were no prosecution cases initiated in 2020

Dutyholder incidents in 2020:  There were 172 dangerous occurrences reported  There were 94 hydrocarbon releases

Personal safety incidents in 2020:  There were no fatal injuries in 2020; there have been six fatalities in the last ten years  There were 11 specified injuries, with a rate of 52 per 100,000 full-time equivalent (FTE) workers  There were 47 over-seven-day injuries, with a rate of 224 per 100,000 FTE workers

Industry profile The UK offshore industry operates the Vantage personnel tracking system, which records the number of nights of Persons on Board (PoB). Details can be found at www.logic-oil.com/vantagepob. Using this information, it can be determined that in 2020, 3.5 million days were spent offshore. It is estimated that there was an offshore population of around 21,000 full time equivalent (FTE) workers in 2020, around 8,000 less than the number in 2019. FTE is based on the assumption that each shift on average lasts 12 hours, and an FTE worker works 2000 hours annually: FTE = Total PoB Nights x 12 ÷ 2000 The assumption that a full time equivalent works 2000 hours a year is based on what other regulators do, in particular the Occupational Safety and Health Administration (OSHA), the regulatory agency of the US federal government found at www.osha.gov. Each year, OGUK publish a report on activity in the UK Offshore Oil & Gas industry. Further Information can be found at oilandgasuk.co.uk/product/business-outlook-report.

Regulatory activity: HSE inspections, investigations, concerns and safety case assessments HSE's regulatory programme for the offshore industry seeks to ensure major hazard and personal risks are properly managed in compliance with legislative requirements. Key regulatory activities are:  Inspecting installations  Investigating incidents  Following up concerns  Assessing safety cases

More information can be found in the HSE Business Plan for 2021/22, which is available at www.hse.gov.uk/aboutus/strategiesandplans/businessplans. Data on regulatory activity covers the last nine- year period from 2012 to 2020.

Summary of ED offshore activity in 2020  157 planned offshore inspections undertaken at 116 offshore installations, lower than the 2019 figure, but still higher than the 2014 to 2018 period  84 investigations completed, representing the highest number of investigations completed since 2013  36 health and safety concerns followed up: lower than the previous year  85 safety case submissions assessed: similar to 2019 but still lower than the previous three years

Inspections undertaken Delivering and properly prioritising inspections is a high priority activity for HSE in ensuring it implements its major hazard strategy while supporting businesses to grow. Therefore, HSE’s Energy Division Offshore aims to ensure its regulatory activity is proportionate to the risks to people, taking into account the operator’s performance in controlling risks. This means that ED Offshore will inspect higher hazard installations and operators with poorer performance with greater frequency and in greater depth than installations and operators where risks are perceived to be better managed. HSE’s policy is to conduct inspections in accordance with its Enforcement Policy Statement at https://www.hse.gov.uk/enforce/enforcepolicy.htm, applying the principles set out in its Enforcement Management Model at www.hse.gov.uk/enforce/enforcement-management-model.htm to regulatory decision making. This includes 33 planned inspections that were completed in 2020 during the initial stages of the Covid pandemic. These inspections were conducted onshore and involved discussions with both on and offshore personnel using industry standard IT conferencing systems.

Figure 1. Number of inspections undertaken by HSE Energy Division Offshore at offshore installations, 2012-2020p 250

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150

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0 2012 2013 2014 2015 2016 2017 2018 2019 2020p Count 196 165 132 138 134 141 126 174 157

Source: HSE operational information (p = provisional)

Investigations completed HSE investigates any incidents which meet its Incident Selection Criteria. Trends over time are difficult to interpret since counts are based on the total number of investigations that are closed on the data management system within the calendar year. Actual incidents and any associated regulatory work may have largely been completed in previous years meaning that peaks and troughs may represent periods of greater or lesser internal focus on completing written reports rather than actual fluctuations in the number of incidents.

Figure 2. Number of investigations completeted by HSE Energy Division Offshore, 2012-2020p 180

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0 2012 2013 2014 2015 2016 2017 2018 2019 2020p Count 153 94 58 52 48 23 35 48 84

Source: HSE operational information (p = provisional)

Concerns followed up Any employee can raise a health and safety concern with HSE if they believe that health and safety law is being broken, or minimum standards are being ignored within the workplace, and if neither the employer nor the work/safety representative can satisfactorily resolve their concern. HSE will only take action if it relates to a work activity and the issue raised has caused or has potential to cause significant harm, alleges the denial of basic employee welfare facilities or appears to constitute a significant breach of health and safety law. More detail about the concerns process is available at www.hse.gov.uk/contact/concerns.htm.

Figure 3. Number of workplace health and safety concerns followed up by HSE Energy Division Offshore, 2012-2020p 70

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0 2012 2013 2014 2015 2016 2017 2018 2019 2020p Count 59 57 56 55 40 13 22 42 36

Source: HSE operational information (p = provisional)

Safety case submissions assessed Dutyholders are required by the Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015 (SCR 2015) to submit a safety case for each installation. This is a written demonstration of safety that has to be updated whenever necessary, to reflect changing knowledge and operational conditions. HSE must accept the safety case before an installation can operate. More detail can be found at www.hse.gov.uk/offshore/safetycases.htm. Counts are based on the total number of completed assessments in each calendar year.

Figure 4. Number of safety case submissions assessed by HSE Energy Division Offshore, 2012-2020p 250

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0 2012 2013 2014 2015 2016 2017 2018 2019 2020p Count 79 70 70 107 199 132 134 84 85

Source: HSE operational information (p = provisional)

Dutyholder performance: Topic scores and non-compliance issues During an inspection, the HSE inspector will assess the dutyholder against the selected inspection topics and award a score per topic. They will also record any non-compliance issues identified at inspection (or during investigations) that require action by an operator, and these are normally communicated to an operator within a formal letter. Where appropriate, HSE will also take formal enforcement action such as Notices and Prosecutions, to prevent harm and secure justice in line with its Enforcement Policy.

Summary of findings relating to dutyholder performance in 2020

 314 topic inspection scores assigned, with 66% indicating broad or full compliance but 34% rated as poor, very poor, or unacceptable  899 non-compliance issues identified with the issues most commonly identified relating to maintenance and operating procedures  24 improvement notices and 2 prohibition notices issued  No prosecution cases instituted

Topic scores

Inspectors assign scores in relation to health and safety management observed on site, in accordance with HSE’s Offshore Topic Inspection Guides at www.hse.gov.uk/offshore/inspection.htm.

Figure 5: Offshore Topic Inspection Scores - Overview, 2019 and 2020p 2019 2020p Fully 49 Compliant 15

Broadly 267 Compliant 193

102 Poor 94

8 Very Poor 11

0 Unacceptable 1

250 200 150 100 50 0 0 50 100 150 200 250

Source: HSE operational data (p = provisional)

Figure 6. Offshore Topic Inspection Scores - by Inspection Topic, 2019 and 2020p

Maintenance 2019 5 58 17 3 Management 2020p 26 22 4

Operational Risk 2019 16 25 10 Assessment 2020p 2 26 10

Loss of 2019 1 14 16 3 Containment 2020p 1 16 13 3

Control of Work 2019 14 26 8 2020p 4 16 31

Evacuation, 2019 1 30 7 Escape & Rescue 2020p 13 11 1

Pipelines 2019 4 22 5 2020p 10 6

2019 1 15 9 1 Verification 2020p 2 16 4

Mech Handling & 2019 1 23 7 Crane Ops 2020p 2 5 3

Temporary 2019 8 7 Refuge 2020p 1 10 5 1

Workforce 2019 4 6 1 Engagement 2020p 1 13 5

Well Integrity 2019 1 12 1 2020p 1 7 2

Loss of Stability 2019 3 9 1 & Position 2020p 5 3 11

Wells 2019 9 1 Competence 2020p 7

Structural Integrity 2019 1 4 2 Management 2020p 8 1

Well Control 2019 8 2 2020p 3

Marine Operation 2019 2020p 1 6 4

Well Examination 2019 1 2020p 6

Noise & Vibration 2019 3 2020p 2 0 10 20 30 40 50 60 70 80 90

Fully Compliant Broadly Compliant Poor Very Poor Unacceptable

Source: HSE operational data (p = provisional)

Non-compliance issues identified

Figure 7. Number of non-compliance issues identified by HSE Energy Division Offshore, 2012-2020p 1400

1200

1000

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0 2012 2013 2014 2015 2016 2017 2018 2019 2020p Count 652 825 688 962 1153 1152 1254 1062 897

Source: HSE operational information (p = provisional)

Figure 8. Types of issue identified by HSE Energy Division Offshore in 2020p

Maintenance 137

Operating procedures 110

Safety critical systems 107

Risk profiling 87

Plant integrity 79

Emergency arrangements 77

Leadership & management 76

Plant & process design 60

Control of work 49

Competence 49

Verification 43

Management of change 14

Contractors 3

Not yet assigned 6

0 20 40 60 80 100 120 140 160

Source: HSE operational information (p = provisional)

Enforcement

While the number of issues identified over the course of a year gives an idea of dutyholder performance, the number that are resolved within a given year (which will include issues first identified in previous years) provides an indication that issues are being addressed. In the majority of cases, where issues have been identified a letter is written to the dutyholder identifying the non-compliance and the remedial action required. An issue is not normally considered as being resolved until HSE is able to verify that the required action has been taken. Formal enforcement action is taken where there are more serious breaches.

Figure 9. Types of issue resolved in 2020p

Maintenance 72

Emergency arrangements 54

Operating procedures 46

Safety critical systems 42

Risk profiling 35

Leadership & management 34

Plant integrity 33

Control of work 28

Competence 28

Verification 22

Plant & process design 19

Management of change 5

Contractors 2

0 10 20 30 40 50 60 70 80

Source: HSE operational information (p = provisional)

ED Offshore applies the principles detailed in HSE's Enforcement Policy Statement which can be found at www.hse.gov.uk/enforce/enforcepolicy.htm when enforcing health and safety legislation. There are a range of tools at its disposal in seeking to secure compliance with the law and ensure a proportionate response to offences. For more serious offences, inspectors may serve improvement notices and prohibition notices, and they may prosecute (or in Scotland, report to the Crown Office and Procurator Fiscal Service (COPFS) with a view to prosecution).

Figure 10. Number of enforcement notices issued by HSE Energy Division Offshore, by type of notice, 2012-2020p

45

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25

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15

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5

0 2012 2013 2014 2015 2016 2017 2018 2019 2020p Improvement notices 13 20 43 34 38 37 30 20 24 Prohibition notices 4 5 7 1 2 6 2 6 2

Source: HSE operational information (p = provisional)

No prosecutions were initiated in 2020.

Dutyholder incidents: Dangerous occurrences and Hydrocarbon releases Summary of findings relating to dutyholder incidents in 2020

 There were 172 DOs reported in 2020, lower than any reported number in the 2007/08-2019 period  The number of reported wells DOs is the lowest reported and has been decreasing steadily in recent years  The total number of hydrocarbon releases reported under EU Offshore Directive arrangements decreased from 128 in 2019 to 94 in 2020.  Hydrocarbon releases reported under RIDDOR increased slightly as did the proportion of HCRs, now accounting for 36% of the DOs reported under RIDDOR (63 of 172) compared to the prior 30%  Since the introduction of the ROGI (‘Reporting of Oil and Gas Incidents’) form, all non-process HCRs (for example, helicopter fuel and diesel spills) reported under the EU Offshore Directive arrangements are classified in the same way and against the same criteria as process HCRs. In 2020, 13 of the 94 HCRs were reported solely under the EU Offshore Directive arrangements and did not meet the criteria to be reportable under RIDDOR.  Non-process HCRs accounted for just over 30% of HCR figures for 2020 (31%; 29 out of 94), slightly lower than the 2019 figure of 37% Dangerous occurrences As part of the changes introduced in October 2013 following a full-scale review of RIDDOR, many defined dangerous occurrence (DO) categories changed ‘type number’ as well as description. For more detail on DOs that are reportable at an offshore workplace, see www.hse.gov.uk/riddor/dangerous-occurences.htm.

Figure 11. Reported dangerous occurences (offshore), 2007/08-2020p 600

500

400

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200

100

0 07/08 08/09 09/10 10/11 11/12 12/13 2012 2013 2014 2015 2016 2017 2018 2019 2020p HCRs 189 158 188 168 133 97 105 118 94 93 61 67 57 61 63 Wells 37 45 29 47 37 52 42 51 36 34 30 24 17 17 7 Pipelines 10 7 41 35 26 39 29 51 40 45 4 19 17 18 16 Other 273 267 176 180 267 204 183 205 239 140 114 107 132 113 86

Source: RIDDOR (p = provisional)

Hydrocarbon releases Hydrocarbon releases (HCRs) are classified as ‘Minor’, ‘Significant’, or ‘Major’ on the basis of their severity; these definitions have been agreed with the offshore industry. Full HCR incident data and population data from 1992 to 2016 can be found in two separate spreadsheets at www.hse.gov.uk/offshore/statistics.htm. By combining incident and population data, estimates of the frequency of loss of containment incidents for equipment and system types can be