Health and Safety in Relation to Petroleum Exploration and Production Activities
The legislative framework for offshore safety for which the Health and Safety Authority has responsibility is the Health, Safety and Welfare (Offshore Installations) Act, 1987 (No 18 of 1987)
and the Safety, Health and Welfare at Work Act 1989, (No 7 of 1989). In addition to this legislation, regulations have been made under the Act of 1987 and the Act of 1989. These are listed beneath:
- Safety, Health and Welfare (Offshore Installations) (Installation Managers) Regulations, 1991 (SI 13 of 1991)
- Safety, Health and Welfare (Offshore Installations) (Emergency Procedures) Regulations, 1991 (SI No 14 of 1991)
- Safety, Health and Welfare (Offshore Installations) (Life Saving Appliances) Regulations, 1991 (SI No 15 of 1991)
- Safety, Health and Welfare (Offshore Installations) (Operations) Regulations, 1991 (SI No 16 of 1991)
- Safety, Health and Welfare at work (General Application) Regulations, 1993 (SI No 44 of 1993)
- Safety Health and Welfare at Work (Extractive Industries) Regulations, 1997 (SI No 467 of 1997)
There are a number of Departments and agencies involved in the regulation of safety for Exploration and Production activities. The Petroleum Affairs Division (PAD) of the Department of Communications, Marine and Natural Resources as licensing authority for these areas has a responsibility to ensure that an inclusive and effective regime is in operation and that appropriate safety management systems are in operation. Its Rules and Procedures for petroleum exploration and production set out a number of safety response related requirements.
The Safety of Offshore production operations are addressed through two mechanisms:
- for work practices and
- for hardware.
In relation to work practices, Regulations made under the Health, Safety and Welfare (Offshore Installations) Act, 1987 provide for the notification of appointment of installation managers, emergency procedures, operational measures to be taken for the safety and the protection of the health and welfare of persons on specified offshore installations and lifesaving measures to be followed. Key provisions contained in these Regulations include the following:
- The provision and maintenance of Emergency Procedures Manuals.
- The provision and maintenance of life saving appliances.
- Written safety instructions.
- The identification of hazardous areas and areas containing explosives and dangerous substances.
- Procedures for the maintenance, examination and testing of equipment, plant and appliances.
- The provision of equipment and operations for radio communication.
In relation to hardware Section 10 of the Health, Safety and Welfare (Offshore Installations) Act, 1987 requires that all offshore installations must be fit for purpose, of sound construction adequate strength, properly maintained and in compliance with an regulation issued under the section. The design of the structure must be such that accommodation modules are not part of or near a hazardous area, see Section 4(2) of the said regulation.
The operator is responsible at all times for ensuring that:
- all drilling operations are conducted safely and
- all production facilities are to be designed, constructed, installed, commissioned, operated and maintained safely
in accordance with current Good Industry Practice.
The operator will also ensure that an Independant Examination Scheme will be in place in relation to the specific matters of:
- Drilling unit fitness for purpose.
- Well design and construction.
- Well maintenance.
- Production facility design and construction.
- Production facility installation and commissioning.
- Production facility maintenance.
The operator shall have in place and operate systems involving:
- Independent, competent examiner(s) verification body(ies).
- Verification / examination processes whereby the independent, competent examiner(s) verification body(ies) assess and approve the operators proposals.
An auditor acting on behalf of the PAD audits the operator in accordance with its audit procedures (e.g Well Management Audit Scheme - WMAS) to ensure that such systems are in place and complied with before issuing any approvals (Approval to Drill, Approval for first Oil or Gas).
All relevant Acts and SI's can be accessed on the Irish Statute Book Website.