Oil Pollution Emergency Plan – Onshore Pipelines

Consent Needed:

No consent is required but operators must produce and maintain a Major Accident Prevention Document as outlined below.

Major Accident Prevention Document:

No particular consent is required, however the Pipeline Safety Regulations (PSR) do require operators to create and maintain emergency procedures, detailing the appropriate organisation, arrangements and procedures for different emergencies. These procedures should be prepared in consultation with relevant external bodies (e.g. emergency services and local authorities).

Operators of Major Accident Hazard Pipelines must prepare a Major Accident Prevention Document (MAPD) as defined by Regulation 23 which must demonstrate that:

  1. All hazards relating to the pipeline with the potential to cause a major accident have been identified.
  2. The risks arising from these hazards have been evaluated.
  3. The Safety Management System (SMS) is adequate.
  4. That adequate arrangements have been established for undertaking of audits and reports.
Safety Management System:

The Safety Management System should be in place throughout the lifecycle of the pipeline from concept design through to decommissioning. It must ensure that:

  • Systems are in place for coordination of personnel involved in safety.
  • Operating procedures for normal, abnormal and non-routine operations are in place
  • Communication of procedures through operating manuals, etc., is adequate.
  • Procedures are in place to monitor the safety performance of contractors.
  • Safety training is available to all relevant personnel.
  • Major accident hazards associated with the pipeline are systematically evaluated and this information fed into the SMS and MAPD.
  • Procedures are in place for the planning of modifications to be made to the pipeline.

Operators provisions for dealing with accidents involving a pipeline, including where applicable the Major Accident Prevention Document, must be approved by the Health and Safety Executive, (HSE).

Prior Notification Required:

Operators of Major Accident Hazard Pipelines must notify the Health and Safety Executive:

  • At least 6 months prior to the commencement of construction.
  • At least 14 days before the conveyance of fluid in the pipeline.
Notification of Other Changes:

Operators of Major Accident Hazard Pipelines must notify the HSE where changes occur in the:

  • Route or position of the pipeline.
  • Service conditions of the pipeline.
  • Pipeline materials and equipment.
Monitoring: N/A
Reporting of Incidents: Incidents must be reported immediately where:

  • Any uncontrolled or accidental release from a pipeline has the potential to cause the death of, major injury or damage to the health of any person.
  • It results in the pipeline being shut down for more than 24 hours.
  • Any incident associated with the sudden, uncontrolled release of specified quantities of flammable substances.
What to Report: For all incidents a record must be kept of the:

  • Date and time of the accident or dangerous occurrence.
  • Location of accident or dangerous occurrence.
  • Circumstances in which the accident or dangerous occurrence occurred.
  • Date on which the event was reported to the HSE.
  • Method by which the event was reported.
  • Pipeline designation.
  • Pipeline duty (contents).
  • Initial and potential size of leak.
  • Details of how the pipeline has been made safe.

This information should be followed up as soon as possible with a completed F2508 and/or F2508A (Forms can be found on the RIDDOR website) within 24 hours of the incident.

Who to report to: Incidents must be reported through the RIDDOR website at www.riddor.gov.uk
Penalties:  (-)
Renewal of Major Accident Prevention Document: Regulation 24 of the PSR states that emergency procedures should be kept in an up-to-date operational state; the frequency of tests is not specified. Regulation 25 reiterates this for MAPD stating that the plan must be kept up to date and reflect relevant changes in risk, procedure and personnel.
Environmental Liability Directive 2004/35/EC: The Environmental Liability Directive was adopted in 2004 and was required to be implemented by 30 April 2007. The Directive enforces strict liability for prevention and remediation of environmental damage to ‘biodiversity’, water and land from specified activities and remediation of environmental damage for all other activities through fault or negligence. The Environmental Liability Directive is now implemented in England and Wales (see Environmental Liability). The Scottish Government has completed its second consultation and regulations are pending.Following the Deepwater Horizon incident in the Gulf of Mexico in 2010 and the European Commission’s communication “Facing the challenge of the safety of offshore oil and gas activities” (published in October 2010), the EU Directive on the “Safety of Offshore Oil and Gas Operations” was published on 28 June 2013 (Directive 2013/30/EU (PDF document)).