Health and Safety Executive

Offshore Statistics & Regulatory Activity Report 2021

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 North Sea Transition Authority (NSTA) (formerly Oil and Gas Authority) 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 NSTA 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 2021 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. Offshore Energies UK (OEUK) (formerly Oil & Gas UK), 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.oeuk.org.uk.

Executive summary Regulatory activity in 2021:  There were 114 inspections undertaken at 112 offshore installations  66 investigations were commenced  23 workplace health and safety concerns were followed up  57 safety cases were assessed

Dutyholder performance in 2021:  752 non-compliance issues were raised with operators  28 enforcement notices were issued (all improvement notices)  One conviction was secured

Dutyholder incidents in 2021:  There were 198 dangerous occurrences reported  There were 91 hydrocarbon releases

Personal safety incidents in 2021:  There were no fatal injuries in 2021; there have been four fatalities in the last ten years  There were 16 specified injuries, with a rate of 74 per 100,000 full-time equivalent (FTE) workers  There were 53 over-seven-day injuries, with a rate of 244 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 2021, 3.6 million days were spent offshore. It is estimated that there was an offshore population of around 22,000 full time equivalent (FTE) workers in 2021, around 1,000 more than the number in 2020. 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, OEUK publish a report on activity in the UK Offshore Oil & Gas industry. Further Information can be found at oeuk.org.uk/business-outlook-report-2022.

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 2022/23, which is available at www.hse.gov.uk/aboutus/the-hse-business-plan.

Summary of ED offshore activity in 2021  114 planned offshore inspections undertaken at 112 offshore installations  66 reported incidents met the criteria for investigation  23 health and safety concerns, raising 33 issues, were followed up  57 safety case submissions assessed

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.

Figure 1. Number of inspections undertaken by HSE Energy Division Offshore at offshore installations, 2017-2021p 200

180

160

140

120

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40

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0 2017 2018 2019 2020 2021p Count 141 126 174 157 114

Source: HSE operational information (p = provisional)

Investigations HSE investigates any incidents which meet its Incident Selection Criteria. The numbers reported below reflect the number of investigations commenced. This is a change from previous reports, and should make it easier to interpret trends over time as investigations may be completed outside the reporting year.

Figure 2. Number of investigations commenced by HSE Energy Division Offshore, 2017-2021p 70

68

66

64

62

60

58

56

54

52 2017 2018 2019 2020 2021p Count 58 58 69 68 66

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. In 2021, 23 concerns (which raised 33 separate issues) met the criteria for follow up.

Figure 3. Number of workplace health and safety concerns followed up by HSE Energy Division Offshore, 2017-2021p 40

35

30

25

20

15

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5

0 2017 2018 2019 2020 2021p Count 25 26 37 22 23

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, 2017-2021p 160

140

120

100

80

60

40

20

0 2017 2018 2019 2020 2021p Count 132 134 84 85 57

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 2021

 332 topic inspection scores assigned, with 74% indicating broad or full compliance but the remaining 26% rated as poor, very poor, or unacceptable  752 non-compliance issues identified with the issues most commonly identified relating to maintenance, followed by plant integrity  28 improvement notices (and no prohibition notices) issued  1 conviction secured

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, 2020 and 2021p

2020 2021p Fully 15 28 Compliant Broadly 193 219 Compliant

94 Poor 81

11 Very Poor 4

1 Uanacceptable

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, 2020 and 2021p 0 10 20 30 40 50 60 Maintenance 2020p 26 21 4 Management 2021 1 38 12 2 Operational Risk 2020p 2 26 10 Assessment 2021 4 22 3 Loss of 2020p 1 17 13 3 Containment 2021 1 13 16 Control 2020p 4 16 3 1 of Work 2021 6 21 4 1 Evacuation, 2020p 13 11 1 Escape & Rescue 2021 18 5 Pipelines 2020p 10 6 2021 3 5 8 Verification 2020p 2 16 4 2021 20 3 Mech Handling 2020p 2 5 3 & Crane Ops 2021 1 9 2 Temporary 2020p 1 10 5 1 Refuge 2021 2 8 8 Workforce 2020p 1 12 5 Engagement 2021 10 2 Well 2020p 1 7 2 integrity 2021 10 2 Loss of Stability 2020p 5 3 1 & Position 2021 6 3 2020p 7 Wells Competence 2021 2 4 1 Structural Integrity 2020p 8 1 Management 2021 8 4 Well 2020p 3 Control 2021 2 8 1 Marine 2020p 1 6 4 Operation 2021 3 12 2 Well 2020p 6 Examination 2021 1 1 Noise & 2020p 2 Vibration 2021 1 1

Fully Compliant Broadly Compliant Poor Very Poor

Source: HSE operational data (p = provisional)

Non-compliance issues identified

Figure 7. Number of non-compliance issues identified by HSE Energy Division Offshore, 2017-2021p 1400

1200

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0 2017 2018 2019 2020 2021p Count 1152 1254 1062 899 752

Source: HSE operational information (p = provisional)

Figure 8. Types of issue identified by HSE Energy Division Offshore in 2021p

Maintenance 141

Plant Integrity 83

Operating procedures 74

Safety Critical Systems 74

Leadership & Management 72

Emergency arrangements 65

Control of work 63

Risk profiling 61

Plant & Process design 34

Verification 33

Competence 23

Management of Change 18

Contractors 2

Not yet assigned 4

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 2021p

Maintenance 82

Leadership & Management 45

Control of work 44

Plant Integrity 43

Operating procedures 36

Emergency arrangements 36

Safety Critical Systems 33

Risk profiling 29

Verification 19

Management of Change 11

Plant & Process design 9

Competence 6

Contractors 1

0 10 20 30 40 50 60 70 80 90

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, 2012-2021p

45

40

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5

0 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021p Improvement notices 13 20 43 34 38 37 30 20 24 28 Prohibition notices 4 5 7 1 2 6 2 6 2 0

Source: HSE operational information (p = provisional)

Prosecutions

One conviction was secured in 2021.

Dutyholder incidents: Dangerous occurrences and Hydrocarbon releases Summary of findings relating to dutyholder incidents in 2021

 There were 198 DOs reported in 2021, higher than the 172 reported in 2020 but lower than all other counts in the last ten year period  The number of reported wells DOs increased slightly after having been previously decreasing steadily in recent years  The total number of hydrocarbon releases reported under RIDDOR and/or EU Offshore Directive arrangements further decreased from 94 in 2020 to 91 in 2021, the lowest number in recent years  The number of hydrocarbon releases reported under RIDDOR was the same as last year, but their proportion amongst all DOs increased slightly, with HCRs now accounting for 32% of the DOs reported under RIDDOR (63 of 198) 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 2021, 28 of the 91 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 under a quarter of HCR figures for 2021 (24%; 22 out of 91), lower than the 2020 figure of 31% 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), 2012-2021p 450

400

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200

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0 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021p HCRs 105 118 94 93 61 67 57 61 63 63 Wells 42 51 36 34 30 24 17 17 6 11 Pipelines 29 51 40 45 44 19 17 18 17 19 Other 183 205 239 140 114 107 132 113 88 105

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 determined. The HCR release rate is based on the level of production in million barrels of oil equivalent per day (boe/d) reported by OGUK in their annual Business Outlook Report. As a result of the new EU Commission Implementing Regulation No. 1112/2014, some of HSE’s voluntary notification scheme became mandatory. As such, from July 2015, some non-process HCRs were allocated severity classifications again and by July 2018 all non-process HCRs were classified. To maintain a consistent back series, the non-process HCRs are still presented separately in Figure 12.

Figure 12. Hydrocarbon releases (offshore), 2012 to 2021p 160 85

140 75

65 120 55 100 45 80 35 60 25 40 15

20 5

0 -5 2012 2013 2014 2015 2016 2017 2018 2019