Chemical Spills 

For information on the impact of Brexit on oil and gas environmental legislation, please refer to the pdf document downloadable from the Home Page.

Key Legislation:

For more detail on the Legislation relevant to this page, please use the following links:
Supporting Legislation:
Guidance:
Consent Needed: N/A
How to Apply: N/A
Who to Apply to: N/A
When to Apply: N/A
CEFAS Ranked List: It is essential that the same name, as given in the CEFAS Ranked List or the relevant PETS permit, is used when reporting chemical spills, where applicable. Where a chemical is not on the CEFAS Ranked List or the permit because it is exempt from the Offshore Chemical Regulations 2002, this should still be reported as a chemical spill. However, if this is a largely oil based chemical, it should be reported as an oil spill not a chemical spill.
Reporting of Accidental Chemical spills:

All accidental chemical spills should be reported to OPRED via the Integrated Reporting Service (IRS) on the UK Energy Portal with a PON 1 submission. If the IRS system is unavailable, the PON1 – Proforma word document should be sent to OPRED. The HM Coastguard should also be telephoned where the release is > 1 tonne, within 40 km of the coast, exceeds telephone reporting threshold within the OPEP or if this the first report for an ongoing release. Guidance for the submission of a PON1 is available here.

A decision on whether to report a spill as an oil spill or chemical spill can be made depending on whether the substance spilt has been permitted under the Offshore Chemical Regulations 2002 (e.g. drilling fluids), in which case it should be reported as a chemical spill, or not (e.g. reservoir hydrocarbons, lube oils, diesel, etc.), in which case it should be reported as an oil spill.

When the spill is large/significant/ongoing then the earliest possible notification is required as per the PON1 guidance. Where only a small spill has occurred, a fax report is required, and this should be submitted within 6 hours of the spill.

Where there is a risk of significant pollution from a chemical spill incident, OPRED will inform the Secretary of State Representative (SOSREP). The SOSREP has powers of intervention and may issue directions to contain or remove the pollution risk. If any directions issued have not been effective, the SOSREP can take any further action he feels necessary, including sinking or destroying all or part of an offshore installation or taking control of the installation.
Reporting of excursion to Chemical Permit:

Unscheduled operational discharge of chemicals or a discharge that is not undertaken in accordance with the conditions detailed in the permit application or a discharge that is undertaken for the purpose of securing the safety of any person (force majeure), should not be reported on the PON1.

In these cases, the Permit Condition non-compliance Notification Form (Word document) is to be used for reporting any identified non-compliances against Chemical Permit Conditions issued under the provisions of the Offshore Chemical Regulations 2002.
Post-spill monitoring: Monitoring or sampling requirements may be imposed in the event of a major spill.
What to Report: See the Performance Standards tab for more information on the requirements of the PON1 reporting.
Who to Report to: See Above.
When to Report: See Above.
Offshore Inspection: The Offshore Oil and Gas Environment Unit Enforcement Policy sets out the general principles that Inspectors shall follow in relation to enforcement, including prosecution.
Non Compliance with permits: Under the Offshore Chemicals Regulations 2002 it is an offence to discharge chemicals above the permitted quantities or type of chemical. Any chemical excursion must be reported to the Department for Energy Security and Net Zero.
Failure to report a Spill: Failure to report an accidental spill is an offence.
Failure to comply with a Direction: Failure to comply with a direction given by the SOSREP under the Offshore Installations (Emergency Pollution Control) Regulations 2002 is an offence liable to a fine of £50,000 on summary conviction or on indictment to a fine.
Renewal: N/A
Environmental Alert (001/2014)- PON1 Reporting:

Issued by DECC (now Department for Energy Security and Net Zero) on the 31st March 2014, this environmental alert (PDF document) highlights failures by a number of operators to comply with PON1 reporting requirements. Operators are reminded that in accordance with current reporting requirements PON1s must be reported within 6 hours to:

  • Aberdeen Maritime Rescue Coordination Centre (MRCC) in addition to immediate telephone notification to the nearest MRCC Coastguard Station.
  • Department for Energy Security and Net Zero; additional telephone notification is required to the Department for specific scenarios as detailed within the PON1 reporting guidance.
  • Joint Nature Conservation Committee (JNCC) and any relevant Statutory Nature Conservation Body (SNCB) in accordance with installation oil pollution emergency plan arrangements.

The Department for Energy Security and Net Zero 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.

Provisional categorisation of liquid substances:

A circular (PDF document) was issued in late 2011 by the International Maritime Organisation in accordance with regulation 6.3 of MARPOL Annex II, replacing all previously issued circulars under this title.

Storage of Diesel and Chemicals for Temporary Equipment Environmental Alert:

Recent inspections of a number of installations by the Department for Energy Security and Net Zero representatives have found some installations using temporary equipment such as diesel generators and chemical pumps.

While in all cases management of change and/or risk assessment documentation had been completed and available for review for these temporary pieces of equipment, it was established that the storage and supply of the diesel and/or chemicals for the equipment and the associated potential for environmental incident had not been considered in all cases within the management of change/risk assessment documentation.