Dropped Objects

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:

No consents are required, however:

  • Any dropped objects must be notified via PON2
  • Any activities to recover dropped objects in Scottish inshore and offshore waters must be notified to Scottish Ministers to meet the Marine Licensing requirements
  • A licence may still be required in English and Welsh waters to recover objects – more information from the MMO Marine Licensing website. (Note: activities regulated under the Petroleum Act 1998 are exempt from the Marine Licensing requirements)
How to Apply: N/A
Who to Apply to: N/A
When to Apply: N/A
Adverse Weather: DECC requests that operators assess installations for any structures which may become detached during adverse weather.Appropriate action must be taken to prevent articles from being lost or dropped.Operators should review their adverse weather policies during periods of high winds to ensure the risk of lost or dropped articles to sea is minimised.Operators should ensure all loose articles are securely stored during periods of adverse weather.For more information see the Department for Energy Security and Net Zero (then DECC) Environmental Alert 02/2011 (PDF document).
PON2 Requirements:
  • The attention of all those working on or near offshore installations is drawn to the hazard created by floating or submerged materials.
  • Synthetic materials, which are impervious to rot, are used in the construction of a wide variety of fishing lines, ropes, seismic and other cables and fishing nets, which, if lost or discarded at sea, 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, and again 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, or otherwise interfere with navigation, and can snag and damage fishing nets, resulting in lost fishing time, or in extreme cases, pose a threat to 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 that was not anticipated at the deposit location.
  • No materials should be intentionally discarded at sea, with the exception of material that are legally deposited in accordance with the requirements of relevant legislation or deposited under conditions of force majeure. The latter will only be relevant if the dumping is necessary to secure the safety of the vessel or installation, or its crew.
  • Special precautions should be taken to prevent the loss of materials at sea.
  • Submission of the PON2 enables the Department for Energy Security and Net Zero to decide what action should be taken and to allow notification of other users of the sea of any navigational hazards.
Recovery of Dropped Objects: Every reasonable measure should be taken to retrieve dropped objects.
Dropped Objects within Safety Zones: A PON2 notification should be submitted whether in a safety zone or not, but the presence of a safety zone will be a consideration in what might be considered reasonable measures in deciding to attempt removal or address the problem at end of field life.
Sampling/Monitoring: N/A
What to Report: Materials lost or discarded at sea, including any materials deposited under conditions of force majeure, but excluding any materials legally deposited in accordance with the requirements of relevant legislation, must be reported to DESNZ, and every reasonable attempt must be made to recover them. PON2 reporting should be made via the Integrated Report Service (IRS) (guidance available here).  If the IRS system is unavailable, a PON2 Reporting Form should be used for the PON2 notification. General guidance on PON2 is available here.
Who to Report to: The PON2 notification must be made as quickly as possible and no later than 6 hours after the loss or the dumping. It is recognised that full information (particularly in relation to any recovery plans should these be applicable) may not be available within 6 hours but it is important that notifications are received as quickly as possible to allow any applicable response actions/instructions to be taken. Where all information is not available within 6 hours, the PON2 can be amended at a later time. 
When to Report: If a vessel is making immediate attempts to retrieve the object then a report can be delayed, and if recovery is successful then no report is required. However, if it is going to take time to retrieve the object, or successful retrieval is doubtful, a PON2 notification should be submitted to DESNZ immediately.
Inspection and Non-Compliance: N/A
Permit Duration: N/A
Renewal and Variation: N/A
Snippets: Some common sense should be applied as to the lower level of item that is reportable, e.g. a spanner is not reportable, but a scaffold pole could be pulled up by nets, plastic sheeting can harm wildlife and block water intakes and small items, e.g. radioactive sources, can be hazardous.