Waste – Handling of Waste Offshore

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Key Legislation:

For more detail on the Legislation relevant to this page, please use the following links:
Supporting Legislation:

Other supporting legislation although not strictly applicable offshore is:

This legislation does not strictly apply offshore. However, because the offshore disposal of garbage is prohibited then all wastes must be transferred to shore for disposal. Once onshore, the wastes must meet the requirements of onshore legislation when being disposed. These regulations must therefore be considered offshore to allow onshore requirements to be met.
Guidance:
 

Garbage Management Plan: The Merchant Shipping (Prevention of Pollution by Sewage and Garbage from Ships) Regulations 2008 provide a general prohibition against the overboard disposal of all types of garbage waste from vessels and offshore installations (other than ground food wastes where the installation is more than 12 miles from the nearest land). No specific licence is therefore required by the offshore installation for garbage generation or handling.Every vessel and offshore installation must have a Garbage Management Plan which is written in accordance with the guidelines set out in Merchant Shipping Notice MSN No. 1807 (see Guidance under the Legislation tab). In addition, procedures for collecting, storing, processing and disposing of garbage must be provided including procedures for the use of any equipment on board.Every vessel and offshore installation must have a Garbage Record Book. This can either be part of the ship’s official log book or in the form specified in Merchant Shipping Notice MSN No. 1807 (see Guidance under the Legislation tab). However, the Merchant Shipping Notice states that the manifest record of garbage passed to supply vessels for shipment ashore is acceptable in lieu of a Garbage Record Book.
Waste from Offshore Installations – Transfer Notes: Transfer Notes are required for the transfer of waste to shore. If waste is hazardous, the Special Waste Regulations (Scotland) or the Hazardous Waste Regulations (England and Wales) will apply and Consignment Notes are required.Most offshore installations will have their own form of transfer paperwork so in general terms the following is needed:

  • An accurate written description of the types and quantities of waste being transferred. It is important that this note accurately describes the waste as the description will provide the basis for the waste transfer note that will be prepared onshore for onward carriage and disposal of the waste (a legal requirement).
  • The waste containers must be labelled according to their contents and to meet the requirements of the International Maritime Dangerous Goods Code (if Special Waste).

(See Transfer of Controlled Waste and Transfer of Special Waste for more detail.)

The Transfer Notes can be completed either by the waste producer or the importer. However, it is the waste producer who will have the information regarding the waste in order to complete the Transfer Notes. It is therefore standard practice for the platform or rig to complete the Transfer or Consignment Notes as far as possible and to pass this on to the waste importer (e.g. supply vessel) for completion when waste is transferred onshore.
Waste from Vessels – Landing Requirements: Specific regulations apply to landing ship generated waste, including cargo residues. See Waste from Ships.
Waste Classification: Most wastes from commerce and industry are Controlled Wastes, including materials that are to be recycled. Controlled waste includes waste arising from domestic, industrial and commercial premises as well as Special Waste (or Hazardous Waste) for which there are additional regulations for storage, transfer and disposal.
Waste Minimisation, Recovery and Reuse: The National Waste Strategies for England, Wales and Scotland set out the key principles to meet future objectives and statutory objectives for waste management with drives towards reduction of waste production at source as well as recycling and reuse of waste (see Waste Minimisation).
Overboard Disposal of Waste: The Merchant Shipping (Prevention of Pollution by Garbage) Regulations 1998 provide a general prohibition against the overboard disposal of all types of garbage waste from offshore installations (other than ground food wastes where the installation is more than 12 miles from the nearest land). BEIS encourage operators to take action to avoid the loss or and prevent the dumping of synthetic materials and other persistent refuse at sea. This includes materials such as oil drums, lengths of wire, fishing lines, ropes, seismic cables, fishing nets and other heavy objects. Petroleum Operations Notice 2 details advice on the disposal of persistent wastes. It states: “Special precautions should be taken to prevent the loss of such materials and articles mentioned above. In the event of the loss of such materials and articles overboard or when being towed, every reasonable attempt should be made to recover them”. Any loss or unregulated dumping of solid materials at sea from offshore oil and gas installations must be notified using a PON2 form (see the Reporting Requirements tab).
Placards: Every offshore installation is required to display placards, in the working language of the crew, that notify all persons on board that the over board disposal of waste, with the exception of ground food waste, is prohibited.
Other: In addition to these specific offshore regulatory requirements, the necessity to transfer waste onshore has implications for ensuring that the transfer is done in such a way that onshore regulations can be met. In particular, offshore duties include:

  • Waste segregation to allow correct disposal according to waste type. Mixed wastes (e.g. inert/scrap metal/biodegradable) are not allowed and mixing of different categories of Special/Hazardous Waste is prohibited. Mixing of non-Special/Hazardous Waste and Special Waste is prohibited. Segregation requirements also enable recycling or reuse of waste as far as possible.
  • Safe stowage of waste to prevent loss or leakage on platform and during transit.
  • Correct identification of waste and provision of accurate waste description in paperwork accompanying waste to shore (see Transfer of Controlled Waste or Transfer of Special Waste as appropriate).
  • Accurate preparation of correct waste disposal paperwork and signing of paperwork prior to onward transfer.
  • Appropriate and accurate labelling of waste receptacles as appropriate to waste.
Back loading of Oily Slops: Operations giving rise to ‘oil contaminated fluids’ include well clean-up, cementing, mud pit cleaning and operations where well bore fluids become contaminated with oil based mud, crude oil or condensate. In addition, fluids from rig floor drains and other tank cleaning operations could also be included. Back loading of slops must meet the requirements of MCA and HSEGuidance Notes:Good Practice for the Carriage of Oil Contaminated Cargoes for Transportation by Offshore Supply Vessel (PDF document)

Marine Guidance Note (MGN 283(M)) (PDF document)

Dangerous Goods – Guidance on the Back Loading of Contaminated Bulk Liquids from Offshore Installations to Offshore Supply/Support Vessels

HSE Safety Notice Bulletin Number OSD 3-2010.
Monitoring Requirements: None.
Garbage Records and Transfer Notes: See the Consent Needed tab.
Waste Reporting to EEMS: Waste production data for offshore facilities must be reported under EEMS by completing the waste EEMS Form that can be downloaded from the EEMS Website. Reports must be submitted on a monthly basis.Reports to be submitted electronically to the EEMS website.
Accidental Loss: Materials lost or dumped at sea can constitute a significant hazard to other users of the sea and to the marine environment. In order to ensure that any major hazards resulting from the loss or dumping are brought to the attention of other users of the sea, via the authorities responsible for the marine environment, all loss or unregulated dumping of solid materials at sea from offshore oil and gas installations must be notified using a PON2 form. The PON2 proforma (Word document) must be used to notify BEIS/MCA/SFF and NFFO as quickly as possible and no later than 6 hours after the loss or the dumping. Contact details are provided on the PON2 proforma. Further information on how to complete the PON2 form, timing of reporting and post reporting follow-up can be found in the PON2 Guidance.The preference is that the PON2 proforma is sent electronically by email, but fax copies can be sent in the event that electronic communications are not functioning. Contact details are available on the PON2 form.
Relevant convictions Guidance on Relevant convictions for waste environmental permits
Inspections: An inspector may inspect any offshore installation to which these regulations apply to determine if the crew are familiar with the procedures for preventing pollution by garbage.
Non Compliance: Any breach of the requirements to display placards that notify the crew of their obligations and prepare a Garbage Management Plan shall be an offence on the part of the installation manager that is punishable with a fine not exceeding the statutory maximum. Disposal overboard of garbage is an offence of both the owner and installation manager and can result in a fine of up to £25,000. Incorrect onshore disposal of waste due to mis-segregation offshore can result in prosecution, as the waste producer has the “Duty of Care” to ensure waste is transferred and disposed of properly.
Renewal of permit: N/A
Convention on the Prevention of Marine Pollution By Dumping Of Wastes and Other Matter, 1972 and its 1996 ProtocolJoint Long Term Programme (2016-2018) The “Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter 1972” (“London Convention”) has been in force since 1975 and aims to protect the marine environment from human activities, primarily by controlling all sources of marine pollution and to prevent the dumping of waste and other matter in the sea.The Joint Long Term Programme has been updated in light of achievements since 2013 and decisions at the sessions of the governing bodies since that time.
Consultation: Waste classification and assessment – Technical guidance WM3: The Environment Agency are looking for views in response to the anticipated legal changes to the List of Waste and Hazardous Waste criteria which are expected to be introduced on 1 June 2015. Open until 03/02/15; the consultation page can be accessed here.
The Thermal Treatment of Waste Guidelines 2013 (Scotland only): These guidelines set out SEPA’s approach to permitting thermal treatment of waste facilities and SEPA’s role as a statutory consultee of the land use planning system. These guidelines update and replace SEPA’s Thermal treatment of waste guidelines 2009.Further information is available on the SEPA website.