Offshore Safety Directive

Offshore Safety Directive

The Offshore Safety Directive of 2013 (‘OSD’) was implemented in the UK by the Offshore Petroleum Licensing (Offshore Safety Directive) Regulations 2015 (‘the 2015 Regs’) and other regulations. The 2015 Regs impose obligations and liabilities on offshore licensees and NSTA strongly recommends that all such licensees should read and consider them carefully.

Guidance from the Offshore Safety Directive Regulator (‘OSDR’)

Licence awards and assignments

Among other things, the 2015 Regs require the NSTA, as the ‘Licensing Authority’ for OSD purposes, to take certain things into account when considering the award or assignment of a Seaward Production Licence. The NSTA will consult the Offshore Safety Directive Regulator (‘OSDR’) as necessary, and while applicants may have to submit additional information to satisfy the OSD, they need not make separate applications.

OSD Operators

The OSD introduced new provisions governing the appointment of operators. These new operator provisions are separate from those in the Model Clauses attached to Petroleum Act licences, and the role of operator under the OSD is separate and different from that in a licence. In many cases, though, the same company will be considered against the OSD’s operator provisions and against the licence’s operator provisions.

The 2015 Regulations prohibit the appointment of an operator by a Licensee unless the Licensee has first notified the NSTA and the NSTA does not object (see Reg 5). Any Licensee who wishes to make such notification to the NSTA should complete the Nomination Form OSD-F1  and submit it, with supporting information, by email to with a subject line beginning with the words “OSD....." (e.g. “OSD Well Operator [and/or] Installation Operator on licence(s) on P123, P456”).

The proposed OSD Operator notification must be approved by all parties to the licence(s) prior to submission to the NSTA.  In your cover email you will need to make clear that the notification is made either in your capacity as licence operator for and on behalf of the licensees, or by the licensees collectively.

Additional guidance (including the supporting information required by OSDR) is set out in “appendix C”.  OSD Operator notifications are subject to a three-month consultation, subject to the receipt of all the necessary documents.