Offshore Statistics & Regulatory Activity Report 2022

Table of Contents

Preface ................................................................................................................. 3 Executive summary............................................................................................... 5 Industry Profile ...................................................................................................... 6 Regulatory activity: HSE inspections, investigations, concerns and safety case assessments ......................................................................................................... 7 Dutyholder performance: Topic scores and non-compliance issues ................... 10 Dutyholder incidents: Dangerous occurrences and Hydrocarbon releases ......... 16 Personal safety incidents: RIDDOR reported injuries and diseases ................... 19 Explanatory notes ............................................................................................... 21

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 2022 and offshore injuries and dangerous occurrences reported to HSE under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR). Information relating to ill health cases reported under RIDDOR is no longer published due to concerns over reporting rates. 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.

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.

This 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.

Nor does it include 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.

Executive summary

Regulatory activity in 2022:

⬤ There were 170 inspections undertaken at 130 offshore installations

⬤ 38 investigations were commenced

⬤ 18 workplace health and safety concerns were followed up

⬤ 54 safety cases were assessed

Dutyholder performance in 2022:

⬤ 1082 non-compliance issues were raised with operators

⬤ 26 improvement notices and 0 prohibition notices were issued

Dutyholder incidents in 2022:

⬤ There were 175 dangerous occurrences reported

⬤ There were 77 hydrocarbon releases

Personal safety incidents in 2022:

⬤ There were no fatal injuries in 2022; there have been 3 in the last ten years

⬤ There were 72 non-fatal injuries in 2022

⬤ The overall injury rate was 310 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 2022, 3.9 million days were spent offshore.

It is estimated that there was an offshore population of around 23,000 full time equivalent (FTE) workers in 2022. In 2021 there had been around 22,000 workers.

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 www.oeuk.org.uk/business-outlook- report-2023.

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 include inspecting installations, investigating incidents, following up concerns and 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.

In 2022:

⬤ 170 planned offshore inspections were undertaken at 130 installations

⬤ 38 incidents were investigated

⬤ 18 health and safety concerns were followed up

⬤ 54 safety case submissions were assessed

Notes

Inspections:

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, applying the principles set out in its Enforcement Management Model to regulatory decision making. These documents can be found atwww.hse.gov.uk/enforce/enforcement.htm.

Investigations:

HSE investigates any incidents which meet its Incident Selection Criteria. The numbers reported above reflect only the number of investigations commenced during the reporting year, to aid interpretations of trends over time. HSE will have also continued to work on concluding any ongoing investigations which were commenced in previous years.

Concerns:

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. The counts presented above show the number of concerns received during the reporting year which met the criteria for follow up.

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.

Safety cases:

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.

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 2022

⬤ 535 topic inspection scores assigned, with 79% indicating broad or full compliance but the remaining 21% rated as poor, very poor or unacceptable

⬤ 1083 non-compliance issues identified with the issues most commonly relating to maintenance, followed by emergency arrangements

⬤ 26 improvement notices and 0 prohibition notices issued

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.

The overall distribution of scores, along with a breakdown by topic area, are shown in Figures 2 and 3.

Non-compliance issues identified

Inspectors record issues they have identified and which require action to be taken by an operator.

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.

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).

Prosecutions

There were no prosecutions in 2022, following one secured conviction in 2021.

Dutyholder incidents: Dangerous occurrences and Hydrocarbon releases

Summary of findings related to dutyholder incidents in 2022

⬤ There were 175 dangerous occurrences reported in 2022

⬤ The total number of hydrocarbon releases reported under RIDDOR and/or EU Offshore Directive arrangements was 77

⬤ HCRs now account for 29% of the DOs reported under RIDDOR (51 out of 175)

⬤ 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 classfied in the same way and against the same criteria as process HCRs. In 2022, 26 of the 77 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 19% of HCR figures for 2022 (15 out of 77)

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.

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 9.

Personal safety incidents: RIDDOR reported injuries and diseases

Summary of findings relating to personal safety incidents in 2022

⬤ The total number of injuries reported under RIDDOR was 72, with a rate of 310 injuries per 100,000 full-time equivalent workers (FTE)

⬤ The number of fatal injuries was 0 and over the last ten years there have been 3 fatalities in total

⬤ The 72 non-fatal injuries include both specified injuries and injuries resulting in over 7 days off work. These are no longer distinguished in the tables due to reporting quality issues

The rate of 310 injuries per 100,000 full-time equivalent (FTE) workers for the offshore sector cannot be compared directly with injury rates for other industry sectors. This is because the way in which the industry workforce sizes for the other sector injury rates are defined is very different from the way the offshore population can be estimated for this report. The offshore population estimate used in this report instead derives from a count of Persons on Board as described in the Industry Profile section of this report. Contributing to that count

will be any individual who spent a night on board an offshore installation, regardless of whether they are employed directly in the offshore sector. This includes individuals working as contractors or for other companies whose industry classification would range across a number of sectors, for example catering, maintenance, construction or education.

Reported injury details

Some additional charts follow, that provide breakdowns of injury severity by nature of injury, part of body injured and kind of accident in 2022.

Summary of findings relating to injury details in 2022

⬤ 'Sprains and strains' accounted for 25% of all injuries, with 'fracture' accounting for a further 24%

⬤ The most common body part to be injured was 'upper limb' (56% of all injuries), followed by 'lower limb' (24%)

⬤ 'Slips, trips or falls on same level' was the most common kind of accident, accounting for 32% of all injuries, followed by 'injured while handling, lifting or carrying' (25%)

Explanatory notes

Reporting of injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR)

RIDDOR places a legal duty on employers and other specified duty holders to report certain workplace incidents to the relevant enforcing authority. A number of key changes to the reporting system and legal requirements occurred between 2011 and 2013, which have some impact on the resulting statistics for some of the data from the earlier years of the historical statistics presented in this report:

⬤ April 2012: a legislative change introduced the requirement to report injuries to workers that lead to absence from work or inability to do their usual job, for over seven days (over-7-day injuries). This replaced the previous ‘over-3-day’ legal requirement

⬤ October 2013: more extensive legislative changes were introduced to simplify the reporting of workplace injuries, including the introduction of ‘specified injuries’ to replace the previous ‘major injury’ category, the revision to ‘type number’ and description of many defined dangerous occurrence (DO) categories, and a reduction in the list of prescribed occupational diseases. These changes occurred half-way through the 2013/14 reporting year

For more information about the coverage of RIDDOR and the effect on statistics of recent changes, see www.hse.gov.uk/statistics/sources.htm#riddor.

HCRs

In these statistics, RIDDOR reportable HCRs include:

⬤ Unintended releases of petroleum gas or liquids from an offshore installation that either result in fire or explosion or require action to prevent or limit the consequences of a potential fire or explosion if ignited, or which have the potential to cause death or major/specified injury. These are often referred to as ‘process’ HCRs

⬤ The unintentional or uncontrolled release or escape of other hydrocarbons (e.g., heli-fuel) from an offshore installation which could cause a significant risk of personal injury. These are often referred to as ‘non-process’ HCRs

⬤ HCRs from wells or from pipelines within 500m of the installation

Energy Division, Health and Safety Executive

Contact: jason.currie@hse.gov.uk

Last updated: October 2023

Next update: October 2024

© Crown copyright. If you wish to reuse this information, please visit www.hse.gov.uk/copyright.htm for details. First published 10/23.