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 and Industrial Strategy OPRED 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 online.
Reporting incidents to OPRED
Integrated Reporting Service (IRS)
IRS is a service hosted within the United Kingdom Energy Portal. IRS is used to report the following to the Department;
- PON1 - Releases to sea of oil or offshore chemicals
- PON2 - Loss of deposition of materials to sea
- PON10 - Non-compliance with Part 4A of the Energy Act/Consent to Locate (including Standard Marking Schedule)
- OPPC NCN - Non-compliance with the OPPC Regulations / an OPPC Permit
- OCR NCN - Non-compliance with the OCR Regulations / an OCR Permit
- PPC NCN - Non-compliance with the PPC Regulations / a PPC Permit
- F-Gas/ODS NCN - Non-compliance with the F-Gas / ODS Regulations
- General Regulatory NCN - Any breach / non-compliance with Regulations not listed above, for example a breach associated with the conditions of a Geological Survey or Marine Licence.
You may find it useful to consult OPREDs offshore environmental legislation page for information on environmental regulations and guidance on offshore oil and gas exploration and production, offshore gas unloading and storage and offshore carbon dioxide storage activities.
To access the IRS users must first register for an Energy Portal Login Account https://itportal.beis.gov.uk/eng/fox/beis/BEIS_LOGIN/login/. Thereafter to access the IRS users must be given the appropriate permissions by their organisations IRS administrator. Access to IRS is through the same link https://itportal.beis.gov.uk/eng/fox/beis/BEIS_LOGIN/login/.
IRS has been designed to allow any installation operating in the UKCS, be that a fixed installation, mobile drilling unit, diving support vessel, flotel etc which may require to make a notification through IRS. If you require an IRS installation account to be set up contact OPRED@energysecurity.gov.uk
In the event there are any issues relating to the functionality of IRS contact email@example.com or 0300 067 1682.
If IRS is unavailable incidents should be notified using the following pro-formas:
- 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
Details of incidents reported to OPRED can be found using this link.
Reporting oil and chemical releases and permitted discharge notifications from offshore installations and pipelines
A Petroleum Operations Notice 1 (PON1) is the notice used to report all releases to sea of oil and offshore chemicals that occur during offshore oil and gas activities.
The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (OPPC) and the Offshore Chemical Regulations 2002 (OCR) include provisions which require the permit holder or, if there is no permit holder, the operator to provide details of the following:
- Any Incident resulting in a release
- Any other incident involving oil/offshore chemicals where there has been or may be any significant effect on the environment by means of pollution
OPPC and OCR also require that a person who releases oil or offshore chemicals must provide the Secretary of State with such information as they may reasonably require for the purpose of performing their functions under the Regulations.
In addition to the requirements of the Regulations, the terms and conditions attached to OPPC and OCR permits require that the permit holders must report all releases of oil and/or offshore chemicals to the Department by means of a PON1 notification.
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 historical data about oil and chemical releases.
Readers should be aware that HSE and OPRED publish Hydrocarbon Release data on their website in accordance with regulatory reporting requirements. HSE and OPRED have different regulatory responsibilities and this is reflected in the incident reports received. Most notably 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 or on some occasions to both, depending on circumstances. Quantities reported may also vary as OPRED is only notified of quantities spilled to sea whereas HSE may be notified of incidents with the potential to cause pollution.
Please direct any queries to: OPRED@energysecurity.gov.uk
Submitting a PON1
The PON1 must be submitted via IRS in accordance with the IRS Guidance document.
Where access to IRS is unavailable the PON1 reporting form, available above, must be submitted in accordance with the information detailed in the PON1 guidance document.
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. A PON2 must be submitted to report material lost or dumped to sea that has the potential to pose a threat to navigation or the safety of users of the sea. Note – this excludes material that is deposited in accordance with an approved Consent/Marine Licence etc.
Offshore Wind Operations – To notify any objects dropped / lost to sea during offshore wind operations please contact Marine Scotland for Scottish waters and the Marine Management Organisation (MMO) for English inshore/offshore waters and Northern Ireland offshore waters. A PON2 should not be submitted to OPRED for such incidents.
The following information is provided to assist with PON2 reporting:
- material deposited under conditions of force majeure (i.e. material lost or dumped to sea in order to protect the safety of any person or the installation) must be reported.
- synthetic materials, which are impervious to rot, can foul the propellers of vessels and present a 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 presenting 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.
- any maritime safety equipment (e.g. life rafts, life rings, life jackets etc) lost to sea must be reported to minimise the likelihood of unnecessary response mobilisation.
- materials lost or dumped to sea may move considerable distances and may have significant impacts away from the initial deposit location.
- caissons which drop from installations have the potential to impact oil and gas bearing subsea infrastructure.
- any other object which if dropped has the potential to pose a threat to navigation or the safety of users of the sea.
Submitting the PON 2 form
The PON2 must be submitted via IRS in accordance with the IRS Guidance document.
Where access to IRS is unavailable the PON2 reporting form, available below, must be submitted to OPRED, 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 6 hours after the event takes place. If all the information is not available within 6 hours, the PON 2 form can be updated at a later time.
A PON10 is used to report a non-compliance with the conditions of a Consent to Locate or any other breach of the applicable Energy Act Part 4A Regulations.
You must submit a PON10:
- immediately and within 1 hour if any part of the Works and associated infrastructure is wrecked or damaged or goes adrift
- immediately and within 1 hour if all Aids to Navigation are non-operational
- immediately and within 1 hour if the nominal range of either the main or secondary white lights is less than 10 nautical miles
- within 24 hours if any element of the aids to navigation are operating on secondary power because of a primary power systems failure
- within 24 hours of detection of any non-compliance relating to the consent conditions including the requirements set out in the Marking Schedule
The PON10 must be submitted via IRS in accordance with the IRS Guidance document.
Where access to IRS is unavailable the PON10 form, available below, must be sent to OPRED 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.
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. 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
- if the incident is new/or 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
What happens after you have submitted a report
OPRED 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 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 Public Registers of Enforcement Activity - OPRED Offshore Enforcement Policy