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.
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 Major Accident Regulator (‘OMAR’) as necessary, and while applicants may have to submit additional information to satisfy the OSD, they need not make separate applications.
Well Operators and/or Installation Operators
The OSD introduced the new concept of well operator and installation operator and the provisions governing their appointment. These new operator provisions are separate from those in the Model Clauses attached to Petroleum Act licences, and the role of a well operator and/or installation 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 well operator and/or installation operator provisions and against the licence’s operator provisions.