Offshore oil and gas activities
The Danish Working Environment Authority (DWEA) supervises the health and safety aspects of the offshore installations on the Danish Continental Shelf in the North Sea.
DWEAs responsibilities and duties
The DWEA has the jurisdiction regarding health and safety on offshore installations and for certain vessels related to the exploration and production of oil and gas. Offshore installations are facilities for exploration and production of oil and gas from beneath the seabed including subsea production wells. These installations are divided into two categories, production facilities from which oil and gas are produced, and non-production installations, including the rest, including drilling rigs.
Safety includes the inherent safety of the installations and equipment on them (“process safety”), and safety at the workplace and at work (occupational safety). Health includes health conditions at the workplace and at work and other health conditions.
Regulatory duties include:
- Approvals of planned well operations where there is a risk of accidental release of oil, gas or hazardous substances or materials that could lead to a major accident.
- Review of design of production facilities and fixed non-production installations and pipelines.
- Permits in connection with the operation, modification and dismantling of offshore installations and pipelines.
- Approvals and review notified well operations.
- Safety and health inspection on offshore installations etc., including well operations.
- Preparation of safety and health rules, including implementation of EU directives.
In connection with the performance of these duties, the DWEA participates in national and international cooperation to build-up experience and to fulfil legislative and international obligations regarding health and safety offshore.
The DWEA duties mentioned are performed by the Offshore Safety Unit.
Approvals and notification of well operations
The operator shall, prior to commencement of a well operation, ensure that a risk assessment of the operation is made which amongst others assesses if there is a potential for accidental release of substances and materials that may lead to a major accident.
Well operations with a potential risk for accidental release of substances and materials that may lead to a major accident must be approved by the DWEA prior to commencement of the well operation pursuant to section 28a of the Offshore Safety Act.
If the risk assessment of the well operation concludes that accidental release of substances and materials would not lead to a major accident, the well operation does not need an approval by the DWEA, however the operation must be notified to the DWEA as per section 28b of the Offshore Safety Act.
It is therefore solely the outcome of the risk assessment of a well activites that decides if the well activites needs an approval by the DWEA or is subject to notification to the DWEA.
Notification of planned design of production facilities etc.
Before a production installation, fixed non-production installation or pipeline is detailed design, built and installed, the overall design must be notified to the DWEA pursuant to section 27 of the Offshore Safety Act. The DWEA has the opportunity to comment on the design, which must then be incorporated into the forthcoming safety and health report of the installation or pipeline.
In addition, major restructuring of existing installations with connected infrastructure and new pipelines must be reported pursuant to section 27 of the Offshore Safety Act. Notifications must be submitted to the DWEA as early as possible during the design phase, so that the DWEA's possible remarks regarding safety and health conditions and the prevention of major environmental incidents may be included in the completion of the design and in the subsequent safety and health case.
Approvals and permits
Before fabrication of a fixed offshore installation its overall design has to be approved by the DWEA pursuant to section 27 of the Offshore Safety Act.
Before commencement of operation from a fixed offshore installation an operation permit must be obtained pursuant to section 28 of the Offshore Safety Act.
Similarly, a mobile offshore installation (drilling rig, accommodation platform or otherwise) must obtain an operating permit pursuant to section 28 of the Offshore Safety Act before it is used.
Permission for operation, modifications and disassembly
Before a production installation can start production of oil or gas, permission must be obtained from the DWEA pursuant to section 28 of the Offshore Safety Act.
Similarly, a non-production facility (drilling rig, accommodation platform or other) must have a permit pursuant to section 28 of the Offshore Safety Act before it is put into operation.
The same applies to a pipeline before it is put into operation.
If you wish to make significant changes to the physical or operating conditions of an installation or a pipeline and the changes are important for the risk of major accidents, the DWEA's permission must be obtained pursuant to section 29 of the Offshore Safety Act before the changes are put into effect.
Prior to initiate a combined operation, i.e. an activity carried out from an installation together with one or more other facilities, a permit shall be obtained from the DWEA pursuant to section 29a of the Offshore Safety Act. Section 29a of the Offshore Safety Act shall only apply from 19 July 2018 if one of the installations is an existing installation, i.e. a installation for which an operating license has been granted before 19 July 2015. Until then, permission for combined operation will be given in the form of separate modifications pursuant to section 29 of the Offshore Safety Act for each of the installations.
Prior to dismantling a fixed production installation, a permanent non-production installation or a pipeline, permission must be obtained from the DWEA pursuant to section 31 of the Offshore Safety Act.
Health and Safety Case
For an installation, a Health and Safety Case (SSR) must be available, which shall explain how health and safety risks and risks for major environmental incidents have been assessed and reduced as much as reasonably practicable in connection with the design, construction and operation of the installation. It is the operator of a production installation or the owner of a non-production installation or a pipeline responsible for this.
The Health and Safety Case for the installation, connected infrastructure or pipeline must be prepared before installation, connected infrastructure or pipeline are put into operation and at the latest submitted in connection with the application for operating permit. Measures described in the Health and Safety Case, which must be taken in conjunction with the operation to reduce the safety and health risks under the ALARP principle, must be completed and documented before installation, connected infrastructure or pipeline are put into operation.
The Health and Safety Case shall be updated in case of significant changes to the installation or pipeline or operational conditions and thoroughly reviewed at least every five years by the operator or the owner, respectively.
The Health and Safety Case must be prepared before applying for operating license and submitted with the application.
Prior to start-up of an installation, connected infrastructure or a pipeline, the rules of general duties of the safety and health conditions during designing, installation and construction apply.
Inspection of health and safety conditions
The DWEA supervises the compliance with the health and safety regulations through visits to the offshore installations and the companies' onshore offices.
Supervision focuses on the companies' management and control of the health and safety risks as well as the risks of major environmental incidents through their management systems for health and safety. In addition, supervision of equipment, preparedness and permanent and temporary workplaces at the installations. Interviews are conducted with management and employee representatives and employees, and further focuses on the involvement of employees in terms of safety and health at the installations.
Installations operating in Danish territory must have a safety organisation that complies with the conditions in Danish regulations, cf. Executive Order No. 1201 of 23 October 2015 on cooperation on health and safety in connection with offshore oil and gas operations etc. Compliance with the rules will normally require that the safety representatives of the employees are chosen on the installation. Safety representatives and management representatives must collaborate in safety groups and committees for handling and improve all health and safety conditions on the installation. The members of the safety organisation must be trained as stated in Executive Order No. 1200 of 23 October 2015 on the safety group's work environment education in connection with offshore oil and gas activities etc.
Councils, Committees and Commissions
Under the Offshore Safety Act, an Offshore Safety Council has been set up, which is in cooperation between a number of authorities, employer representatives and employee representatives as well as a number of commissions, etc. with different purposes. There includes, among other committees, such as the Emergency Preparedness Committee and the Accident Investigation Board.
The DWEA participates in international cooperation in a number of areas relating to health, safety and environment on the offshore installations.
The DWEA is involved in cooperation with its counterparts in the North-West European region through the North Sea Offshore Authorities Forum (NSOAF), bilaterally with Norway and the UK as well as participation in the Offshore Mechanical Handling Equipment Committee (OMHEC). The DWEA also attends a global cooperation regarding health and safety through the International Regulators Forum (IRF).
Finally, the DWEA participates i.a. in EU cooperation on the implementation of the Offshore Safety Directive through the EUOAG (EU Offshore Authorities Group).