Offshore Safety Directive

Offshore Safety Directive

The Offshore Safety Directive of 2013 (‘OSD’) was implemented in the UK by the Offshore Petroleum Licensing (Offshore Safety Directive) Regulations 2015 (‘the 2015 Regs’) and other regulations. The 2015 Regs impose obligations and liabilities on offshore licensees and OGA strongly recommends that all such licensees should read and consider them carefully. The Offshore Safety Directive Regulator (‘OSDR’) has published guidance at http://www.hse.gov.uk/osdr/index.htm.

Licence awards and assignments

Among other things, the 2015 Regs require the OGA, as the ‘Licensing Authority’ for OSD purposes, to take certain things into account when considering the award or assignment of a Seaward Production Licence. The OGA will consult the Offshore Safety Directive Regulator (‘OSDR’) as necessary, and while applicants may have to submit additional information to satisfy the OSD, they need not make separate applications.

OSD Operators

The OSD introduced new provisions governing the appointment of operators. These new operator provisions are separate from those in the Model Clauses attached to Petroleum Act licences, and the role of operator under the OSD is separate and different from that in a licence. In many cases, though, the same company will be considered against the OSD’s operator provisions and against the licence’s operator provisions.

The 2015 Regulations prohibit the appointment of an operator by a Licensee unless the Licensee has first notified the OGA and the OGA does not object (see Reg 5). Any Licensee who wishes to make such notification to the OGA should complete the Nomination Form OSD-F1  and submit it, with supporting information, by email to approvals@ogauthority.co.uk with a subject line beginning with the words “OSD Operator” (e.g. “OSD Operator on Big Installation, P666”).