How to report incidents, including pro-formas for PON1 and PON2 and guidance on completion; listing of environmental alerts for operators in the North Sea.
Environmental Alert Notices
The Department for Business, Energy & Industrial Strategy OPRED(BEIS) regularly issues environmental alert notices in order to raise awareness of any environmental issues on the United Kingdom Continental Shelf (UKCS) so companies can respond appropriately. They are issued directly to Oil and Gas operators and published here.
Reporting incidents to OPRED(BEIS)
A list of pro-formas and guidance documents operators can use when reporting incidents:
- for reporting any chemical use or discharge made without a permit being granted, or any identified non-compliance against the terms and conditions included in a previously granted chemical permit as per the Offshore Chemicals Regulations 2002 as amended
Reporting oil and chemical releases and permitted discharge notifications from offshore installations and pipelines
Licensees and operators are obliged to report under the following circumstances:
- a permit holder or operator of an offshore installation must inform the Secretary of State of a release, discharge or incident where there has been or may be a significant effect of pollution on the environment (see Regulation 11A(1) and (2) of the Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (as amended) and Regulation 15(1) and (1A) of the Offshore Chemicals Regulations 2002 (as amended))
- a petroleum licence may require the licensee to notify the minister and/or Chief Inspector of HM Coastguard of any event causing escape or waste of petroleum.
- offshore and pipeline operators who become aware of any event involving any discharge of oil at sea (regardless of quantity) must report it to the HM Coastguard without delay (see Regulation 5(2) of the Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998).
In compliance with international agreements, the Maritime and Coastguard Agency has issued instructions to captains of all service and civilian ships and aircraft to report immediately the following matters:
- any shipping casualty likely to result in the release of oil or other harmful substances into the sea
- any ship observed discharging oil or other harmful substances into the sea
- any release of oil or other harmful substances sighted at sea
- any incident noticed elsewhere
Petroleum Operations Notice No.1 (PON 1) is the form operators and permit holders are directed to use to satisfy the above reporting obligations.
PON 1 Data
The following spreadsheet presents data about oil and chemical releases that took place between 2005 and 2012. Petroleum Operations Notices (PONs) are used to report oil and chemical releases. PON 1 is used to report oil and chemical releases and Permitted Discharge Notifications (PDNs) from offshore installations and pipelines.
Readers should be aware that HSE and OPRED(BEIS) publish Hydrocarbon Release data on their website in accordance with regulatory reporting requirements. HSE and OPRED(BEIS) have different regulatory responsibilities and this is reflected in the incident reports received.
OPRED(BEIS), as the offshore environmental regulator, requires operators to submit details of all chemical and oil releases/spills to sea, regardless of quantity. It is only the quantity of oil or chemical released/spilled to sea that is reported. This information is submitted by operators using a Petroleum Operations Notice 1 (PON1). The PON1 does not record gaseous releases. This data is available below.
Hydrocarbon Release data submitted to HSE is primarily concerned with gaseous and flammable liquid releases capable of causing serious injury or fatality or a major accident. Where required to be reported it is the total quantity released that is reported regardless of whether the hydrocarbon enters the sea.
As a result of the above reporting requirements there may be incidents that are reported independently to HSE or OPRED(BEIS) or on some occasions to both, depending on circumstances. Quantities reported may also vary as OPRED(BEIS) is only notified of quantities spilled to sea with the potential to cause pollution.
Please direct any queries to: [email@example.com] (mailto:firstname.lastname@example.org)
Loss or dumping of materials at sea from offshore oil and gas installations
Materials lost or dumped at sea can constitute a significant hazard to other sea users and the marine environment. To ensure other sea users are aware of major hazards resulting from such incidences, all loss or unregulated dumping of solid materials at sea from offshore oil and gas installations must be reported through a PON 2 form (liquid materials released should be reported using a PON 1)
What should be reported?
Although small objects dropped into the sea are unlikely to affect the environment and other sea users, it is impossible to set a threshold under which reporting is unnecessary. Instead, operators are advised to report any lost/dropped object if they’re unsure of the hazard it might cause.
Please consider the following when deciding whether or not to report materials lost or dumped at sea:
- material deposited under conditions of force majeure, excluding material legally deposited in accordance with the requirements of – or exemptions from – relevant legislation, must be reported to OPRED(BEIS).
- synthetic materials, which are impervious to rot, can foul the propellers of vessels and present a very real hazard to divers and submersibles. They also constitute a significant hazard to marine life.
- plastic sheeting, bags and containers can block the cooling water intakes of vessels of all sizes as well as constitute a significant hazard to marine life.
- materials such as oil drums, lengths of wire and other heavy objects can represent a hazard to vessels and/or interfere with navigation. They can also snag and damage fishing nets, resulting in lost fishing time or in extreme cases, threaten the safety of the fishing vessel.
- materials lost or discarded at sea may be moved considerable distances by currents and tides, and may eventually have a significant impact not anticipated at the deposit location.
- no material should be intentionally discarded at sea, except material that is legally deposited in accordance with the requirements of relevant legislation or deposited under conditions of force majeure. The latter is only relevant if the dumping is necessary to secure the safety of the vessel, installation or crew.
- if lost or discared material is resting and likely to remain within a permanent 500m safety zone, it may be possible to defer removal until final decommissioning. If the material rests outside of a 500m safety zone or within a short-term safety zone (such as a safety zone attached to a drilling installation), every reasonable attempt must be made to remove or recover the material.
Submitting the PON 2 form
The form must be submitted to OPRED (BEIS), the Marine Coastguard Authority, Kingfisher at Seafish, the Scottish Fishermen’s Federation and/or the National Federation of Fishermen’s Organisations as soon as possible and no later than six hours after the event takes place. If all the information is not available within six hours, the PON 2 form can be updated at a later time.
Please email the form if possible, but it can be faxed if electronic communication is not functioning. Contact details are available on the PON 2 form.
Once the PON 2 form has been received by the relevant authorities, the submitter may be contacted if further information is required. With the exception of the original submission and any following updates, all correspondence with authorities should be copied to OPRED (BEIS) Business Support Team at email@example.com
Any non-compliance with the consent conditions relating to the provision of any lights, signals or other aids to navigation; the stationing of guard ships in the vicinity of operations; and the taking of any other measures for the purposes of, or in connection with, controlling the movements of ships in the vicinity of the operations must be reported immediately by completing the PON10 form and sending it to OPRED(BEIS) and the UK Hydrographic Office.
Reports should also be copied to the Maritime and Coastguard Agency (MCA), Kingfisher at Seafish and the relevant General Lighthouse Authority and fishermen’s representative body.
Any other non-compliance with the consent conditions should be reported to OPRED(BEIS) within 24 hours, who will decide whether to copy this to the relevant third parties.
Anonymously reporting environmental concerns relating to offshore oil and gas operations
If you have a concern about an environmental pollution incident/breach of offshore regulations you can report it online to OPRED (BEIS). This section of the GOV.UK website, provides a mechanism for those aware of an environmental offshore incident, such as the release or unpermitted discharge of oil or chemicals to sea, to report this information anonymously.
You will not be required to provide any personal details should you wish to remain anonymous. However, in these circumstances the Department will be unable to update you with its response to the information you provided. Should you wish to receive an update, we require you to leave sufficient personal details and advise us of your preferred method of communication. Where you provide your personal details the Department will strive to protect your confidentiality, however it cannot guarantee your anonymity.
Before you start
There has to be a good reason for investigating environmental concerns relating to offshore oil and gas operations so you’ll need to provide as much of the following information as possible including:
- the name of the installation involved?
- a detailed description of the incident?
- is the incident new/or is it ongoing?
The information you provide is strictly confidential.
You don’t have to give your name unless you want to.
To submit a report please access the form here – Anonymous Reporting form - on Portal
Other ways to apply
You can also report an environmental concern by telephone or post.
OPRED (BEIS) Anonymous Reporting Hotline Telephone: 01224 254138
Monday to Friday, 8:30am to 4:30pm
If your call is outwith office hours, you may wish to contact the MET Office out of hours service: 01392 886160
What happens after you have submitted a report
OPRED (BEIS) Offshore Environmental Investigation Team will review the information you have reported. If you’ve given enough information they’ll investigate the incident.
The Investigation Team may not always be able to tell you the outcome and sometimes no action is taken.
OPRED (BEIS) Offshore Environmental Inspectorate will take action if they find there is evidence of an incident that results in pollution or a contravention of the regulations. The enforcement options available are detailed in the Department’s Enforcement policy which can be accessed here at Oil and Gas: OPRED (BEIS) Public Registers of Enforcement Activity - OPRED (BEIS) Offshore Enforcement Policy