UK HSE energy division response to COVID-19

2 April 2020

UK Offshore Stakeholder Bodies

I wrote to you on 19 March to set out the immediate actions that HSE’s Energy Division Senior Leadership Team had agreed to take in response to the COVID-19 health crisis. In that note I explained that we were reviewing how we would prioritise our planned regulatory work, taking account of critical areas and activities and after allowing Dutyholders some time to decide how best to address their immediate challenges. This note is a follow up to that and to share our temporary sector plan with you.

We recognise that the global Covid-19 pandemic significantly impacts Great Britain’s offshore energy sector. Maintaining the operational and asset integrity of offshore energy installations in a safe condition is important during the pandemic to:

• Prevent a major accident which could harm large numbers of workers and thus significantly add to existing demands on shore-based health and social care services already under great pressure;
• Ensure a secure and uninterrupted supply of energy from offshore operations to keep Great Britain adequately supplied, and to support the nation’s economy;

The challenges to the sector during the pandemic arise from a sustained period in which the availability of personnel fulfilling key functions will be impaired because of high sickness absence rates or the need for self-isolation. Key functions include leadership, technical and logistics support, and functions that implement and maintain safety critical systems or equipment necessary to prevent or mitigate a major accident, or the loss of availability of critical energy production infrastructure. Other challenges during the pandemic arise from the economic impact on Dutyholders of a volatile global oil price, which must not adversely affect major accident hazard control measures

This temporary plan sets-out our approach to regulating the offshore energy sector during the pandemic period. It takes account of the law, the challenges the sector faces, individual installation operational pressures, and those being experienced by HSE. These factors shape how we continue to regulate throughout the period;

Temporary Offshore Sector Plan

Ensuring Dutyholders control major accident hazards will be the continued focus of HSE activities. We will work with installation Dutyholders and with principal cross-sector groups to achieve the following outcomes as a priority during the pandemic period:

• Confirm that duty holders are ensuring safe overall business continuity and are successfully managing major risk challenges, which may be unique by installation;
• Prevent major accidents associated with the loss of containment of oil and gas by ensuring that Dutyholders maintain and implement a valid approach to controlling major accident safety, including maintaining effective emergency response arrangements;
• Ensure that the structural and maritime integrity of offshore energy installations is appropriately managed in a safe condition to prevent an associated major accident;
• Ensure that Dutyholders have a clear strategy for ensuring sufficient competent personnel both on and offshore for the safe operation of offshore energy installations;
• Ensure appropriate arrangements are in place to protect the general health, safety and welfare of personnel onboard offshore energy installations;
• Confirm that offshore energy installation Dutyholders are appropriately consulting and cooperating with Elected Safety Representatives to enable them to exercise their statutory functions and powers effectively;

As I explained in my note of 19 March, HSE will continue to regulate, but we will carry out as much of our intervention work as possible remotely during the pandemic period and investigation of serious incidents and complaints from the workforce will continue. Offshore inspection or investigation visits will only be undertaken in exceptional circumstances, and this will need internal approval from Senior Leaders in HSE. Visits are only likely to be agreed if the only reasonable way to assure control measures are in place, to investigate, or to verify previously required improvements have been made, is to be physically present. Individual Focal Point Inspectors from our Inspection Management Team have reviewed the Offshore Intervention Plan for 2020/21 and are now in the process of contacting their counterparts in the Dutyholders they cover, to discuss exactly what this means in practice for them.

We will keep our approach under review and communicate with you should there be any changes.

Regards

 Chris Flint”