Offshore Statistics and Regulatory Activity Report October 2024

Contents

Preface 2

Executive summary 3

Industry Profile 4

Regulatory activity: HSE inspections, investigations, concerns and safety case assessments 5

Dutyholder performance: Topic scores and non-compliance issues 7 Summary of findings relating to dutyholder performance in 2023 7 Topic scores 8 Non-compliance issues identified 11 Enforcement 12 Prosecutions 13

Dutyholder incidents: Dangerous occurrences and Hydrocarbon releases 14 Summary of findings related to dutyholder incidents in 2023 14 Dangerous occurrences 15 Hydrocarbon releases 16

Personal safety incidents: RIDDOR reported injuries and diseases 17 Summary of findings relating to personal safety incidents in 2023 17 Reported injury details 18 Summary of findings relating to injury details in 2023 18

Explanatory notes 19

Preface

1. The Offshore Major Accident Regulator (OMAR) is the Competent Authority (CA) responsible for regulating offshore major accident hazards. This regulatory body comprises HSE working in partnership with Offshore Petroleum Regulator for Environment and Decommissioning (OPRED) under a Memorandum of Understanding (MoU), to deliver the CA functions. The North Sea Transition Authority (NSTA) are also involved in the regulation of the offshore sector, with a focus on reducing upstream emissions and the move towards net zero.

2. The Health and Safety at Work etc Act 1974 (HSWA), supported by the HSWA (Application outside Great Britain) Order 2013, defines HSE's jurisdiction.

3. This Offshore Statistics & Regulatory Activity Report provides details of HSE’s regulatory activity offshore during 2023 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.

4. 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.

5. 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.

6. 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 2023: • There were 124 inspections undertaken at 96 offshore installations. • 33 investigations were commenced. • 17 workplace health and safety concerns were followed up. • 73 safety cases were assessed.

Dutyholder performance in 2023: • 665 non-compliance issues were raised with operators. • 24 improvement notices and 0 prohibition notices were issued.

Dutyholder incidents in 2023: • There were 174 dangerous occurrences reported. • There were 85 hydrocarbon releases.

Personal safety incidents in 2023: • There was one fatal injury in 2023; there have been 4 in the last ten years. • There were 80 non-fatal injuries in 2023. • The overall injury rate was 369 per 100,000 FTE workers.

Industry Profile

Estimates of the size of the offshore working population are derived from data held on the Vantage-POB (Persons on Board) system. This is a shared industry system which is run on a not-for-profit basis on behalf of the offshore industry by LOGIC (Leading Offshore Energy Industry Competitiveness) as the system custodian. Vantage-POB was developed as a collaborative industry project to harmonise aviation logistics systems and processes across all UKCS (United Kingdom Continental Shelf) operators and launched in 2004. It is now in use worldwide for personnel tracking and flight scheduling. Vantage-POB is currently administered by Restrata who have extracted the data from the Vantage system used in this report.

Vantage-POB figures show that the number of days spent offshore in 2023 totalled 3.7 million days. This equates to an offshore population of around 22,000 full time equivalent (FTE) workers in 2023. This conversion is based on the assumption that each shift on average lasts 12 hours, and that an FTE worker works 2,000 hours annually:

FTE = Total PoB Nights x 12 ÷ 2000

The assumption that a full-time equivalent works 2,000 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.

Note that a change in the administration of the Vantage-POB system this year means that the POB and FTE figures above are not directly comparable with those presented in previous versions of this annual report.

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 2023:

• 124 planned offshore inspections were undertaken at 96 installations. • 33 incidents were investigated. • 17 health and safety concerns were followed up. 73 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 at www.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 2023 • 439 topic inspection scores assigned, with 85% indicating broad or full compliance but the remaining 15% rated as poor, very poor or unacceptable. • 665 non-compliance issues identified with the issues most commonly relating to maintenance, followed by control of work. • 24 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 three prosecutions in 2023, following none in 2022.

Dutyholder incidents: Dangerous occurrences and Hydrocarbon releases

Summary of findings related to dutyholder incidents in 2023 • There were 174 dangerous occurrences reported in 2023. • The total number of hydrocarbon releases reported under RIDDOR and/or EU Offshore Directive arrangements was 85. • HCRs now account for 34% of the DOs reported under RIDDOR (60 out of 174) • 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 2023, 25 of the 85 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 28% of HCR figures for 2023 (24 out of 85)

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 2023 • The total number of injuries reported under RIDDOR was 81, with a rate of 369 injuries per 100,000 full-time equivalent workers (FTE) • The number of fatal injuries was 1 and over the last ten years there have been 4 fatalities in total.

The 80 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 369 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 2023.

Summary of findings relating to injury details in 2023 • 'Fracture' accounted for 38% of all injuries, with 'sprains and strains' accounting for a further 25%. • The most common body part to be injured was 'upper limb' (46% of all injuries), followed by 'lower limb' (34%)

'Injured while handling, lifting or carrying' was the most common kind of accident, accounting for 28% of all injuries, followed by 'slips, trips or falls on same level' (27%)

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

Further information For information about health and safety, or to report inconsistencies or inaccuracies in this guidance, visit the HSE website. You can order HSE priced publications at the HSE books website. HSE priced publications are also available from bookshops. This publication is available on the HSE website HSE Offshore: Statistics © Crown copyright If you wish to reuse this information visit the HSE website for details. First published 10/24. Published by the Health and Safety Executive 10/24.