Commission for Energy Regulation Energy Safety …...The Commission for Energy Regulation (CER) is...
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Commission for Energy Regulation Energy Safety Annual Report 2016
Transcript of Commission for Energy Regulation Energy Safety …...The Commission for Energy Regulation (CER) is...
Commission for Energy Regulation
Energy Safety Annual Report
2016
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Foreword
To: Mr Denis Naughten, TD
Minister for Communications, Climate Action and the Environment
The Commission for Energy Regulation (CER) is Ireland’s independent energy and water
regulator. Our mission is to regulate water, energy and energy safety in the public interest.
The CER has an important public interest mandate.
The work of the CER impacts every Irish home and
business, by ensuring safe, secure and sustainable
energy and water supplies at a reasonable cost. The
sectors we regulate underpin Irish economic
competitiveness, investment and growth, while also
contributing to our international obligations to
address climate change.
This report describes the work of the CER in 2016
in support of its safety functions. It fulfils the
reporting requirements with respect to the Gas
Safety Regulatory Framework and the Petroleum Safety Framework1 as required by
legislation. This report also presents information on the CER’s performance with respect to
Electrical Safety Supervision.
The CER’s role as an energy safety regulator has evolved over time and the CER now
regulates:
Downstream:
o Natural Gas Undertakings
o Liquefied Petroleum Gas (LPG) Undertakings.
o Gas Installers.
o Electrical Contractors.
Upstream (petroleum exploration and extraction activities):
o Petroleum Undertakings
o Operators.
o Owners.
CER looks forward to working with all stakeholders to maintain appropriate safety standards
in energy, thereby protecting lives and property and contributing to safe infrastructure use and
development, which is vital to the economy.
1 Section 9 (1G) (a) of the Electricity Regulation Act 1999, as amended by the Energy (Miscellaneous Provisions) Act 2006 (in respect of the Gas Safety Regulatory Framework) and Section 13I (6) of the Electricity Regulation Act 1999, as amended by the Petroleum (Exploration and Extraction) Safety Act 2010 (in respect of the Petroleum Safety Framework).
(L–R) Paul McGowan (Chair), Garret Blane
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Executive Summary
At the beginning of the year, the CER submitted its 2016 Work Plan to the Minister, setting
out the prioritised specific activities, which are the most important in delivering the CER’s
mission, vision and strategic goals. As such, this 2016 CER Energy Safety Annual Report to
the Minister details how the CER has discharged its legislative role with respect to regulating
energy safety during 2016, highlighting developments during the year and considering
issues for the CER’s safety role in 2017.
As part of the CER’s continuous oversight of the energy sector with regard to safety, all
undertakings regulated under the Gas Safety Regulatory Framework and Petroleum Safety
Framework are required to submit Key (Safety) Performance Indicators (KPIs) on a quarterly
basis. The Safety Supervisory Bodies (SSBs); the Register of Gas Installers of Ireland (RGII)
and Safe Electric, are also required to submit KPIs on a quarterly basis.
This performance reporting provides the CER with data on the safety performance of each
undertaking and each SSB on an ongoing basis. It is used to monitor trends, recognise good
practice and identify areas for audit and inspection. Upon review of the submissions,
quarterly performance reports are prepared by the CER’s Safety Division and presented to
the Commissioners. The compilation of this information provides the basis for this Energy
Safety Annual Report. The main outcomes for 2016 can be summarised as follows.
Gas Safety Regulatory Framework (GSF)
GSF Update
The GSF was improved and developed regarding gas safety during 2016. The CER
appeared before the Joint Committee on Transport and Communications in February
2015. Following this, the Committee prepared a report on the Regulation and
Inspection of Gas Installers Operating in Ireland outlining a number of
recommendations. Section 1.5.2. provides an update on progress made by the CER
on these recommendations.
The Compressed Natural Gas (CNG) for Vehicular Transport: Safety Case
Guidelines Consultation Paper was published in December 2016. This paper updates
the Safety Case Guidelines for Natural Gas and LPG Licensed Undertakings to
include specific requirements for CNG supplier undertakings. All responses received
will be published, along with a decision, in 2017.
Safety Case Assessments
The two LPG undertakings operating in Ireland, Calor Teoranta and Flogas Ireland
Ltd. submitted material changes to their safety cases in respect of Emergency
Response Arrangements
Commencement of a material change
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Assessment of GNI’s safety cases for the Transmission System and Distribution
System to take account of the introduction of Compressed Natural Gas (CNG) assets
into the network.
Audits and Inspections
Each year, CER carries out a programme of audits and inspections of licensed undertakings
to monitor compliance with the undertakings’ safety case:
Eleven audits and inspections were carried out on GNI (GNI) by the GSF team
Four gas shipper/supplier audits were carried out
Two audits were carried out on both LPG undertakings operating in Ireland, Calor
Teoranta and Flogas Ireland Ltd.
Following a competitive public procurement process in 2015, the RGII was appointed
as the Gas Safety Supervisory Body (GSSB) to carry out this function for a seven-
year period commencing 1st January 2016
The number of Registered Gas Installers (RGIs) in the RGI regulatory scheme at the
end of 2016 decreased slightly to 2,971 compared to 3,063 in 2015. In 2016, the
RGII carried out 3,144 inspections of RGIs in comparison to the 3,230 inspections
planned (97%). This is a slight increase of 0.5% when compared to inspections
completed in 2015
The CER monitored the performance of the RGI scheme and conducted an audit of
the RGII on its compliance with the criteria document, which sets out the rules and
the obligations for participants operating within the RGI scheme. The audit identified
a number of non-conformances and opportunities for improvement. The CER
required submission of an action plan and will hold quarterly meetings with the RGII
during 2017 to ensure all issues raised during the audit are addressed
The CER’s Technical Specialist also monitors and inspects the RGII inspectors to
verify their safety performance through an approved audit and inspection
programme.
Enforcement
There were three successful prosecutions of illegal gas installers taken by the CER in
2016, bringing the total number of successful prosecutions to 29. Other enforcement
actions taken included cease-and-desist warning letters and interviews of suspected
illegal gas installers
68 investigations on reports regarding alleged illegal gas works were carried out by
the CER
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Incidents
20 gas safety incidents were reported to CER. Two of these incidents resulted in
hospitalisation of the individuals. Post-incident inspections identified one as resulting
from suspected misuse of an LPG cylinder, and the other inspection could not be
definitive as to the cause of the incident
12 incidents were reported to CER under guidelines, including those involving
suspected carbon monoxide, downstream customers and third-party damage to the
gas transmission or distribution networks
Three incidents were reported voluntarily to the CER. These included third-party
damage to the Dublin-Cork Pipeline, detected in September 2016. CER conducted
site visits and liaised closely with GNI on the repair strategy, which successfully
implemented.
Promotion and Public Awareness
Work also continued during 2016 on the promotion of awareness with respect to key
gas safety issues among the public. This included awareness of the dangers of
carbon monoxide through Carbon Monoxide Awareness Week and advertising of the
RGI scheme
After the 2016 campaign, 56% of adults surveyed claimed to have an audible carbon
monoxide alarm. This metric shows a positive improvement, as only 32% of adults
self-reported having an alarm following the 2014 campaign.
Electrical Safety Supervision
Following a competitive public procurement process in 2015, the Register of
Electrical Contractors of Ireland (RECI) commenced operating as the Electrical
Safety Supervisory Body (ESSB) under the Safe Electric brand, the statutory
regulatory scheme for electrical contractors
Safe Electric membership has remained at a relatively constant level with 4,213
members in 2016 compared to 4,215 members in 2015. In 2016, Safe Electric
inspectors carried out 4,345 inspections on Registered Electrical Contractors (RECs)
in comparison to 4,756 inspections planned for the year. This is an increase of 12%
compared to inspections completed in 2015
The CER monitored the performance of the Safe Electric scheme and conducted an
audit of Safe Electric, which identified a number of non-conformances and
opportunities for improvement. The CER required submission of an action plan and
will hold quarterly meetings with Safe Electric during 2017 to ensure actions are
taken to address all issues raised during the audit, by the end of 2017
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The CER’s Electrical Technical Specialist also monitors and inspects Safe Electric
and its inspectors to verify their safety performance through an approved audit and
inspection programme
The CER investigates and prosecutes unregistered individuals who carry out
restricted electrical works or portray themselves as an REC. There was one
successful electrical safety prosecution taken by the CER during 2016. Other
enforcement actions taken included cease-and-desist warning letters and interviews
of suspected illegal electrical contractors. The CER carried out 68 investigations on
reports received regarding alleged illegal electrical works.
Petroleum Safety Framework (PSF)
PSF Update
The Petroleum Safety Framework (PSF) was updated in 2016 to reflect the changes
required by the Petroleum (Exploration and Extraction) Safety Act 2015. The main
updates were the introduction of the Acknowledgement of Compliance process for
drilling units, which is a form of pre-acceptance of a drilling unit’s safety case; direct
regulation of the operator and owner by CER; and an updated classification system
of incident reporting that includes European reporting requirements
The effectiveness and successful operation of the PSF by the CER were recognised
in Europe through a request to lead the delivery of training to other Member States
via an initiative of the European Union Offshore Authorities Group, EUOAG.
Following a request, throughout 2016 Petroleum Safety team members assisted
another European Member State in the development of their regulatory Framework.
This was done through knowledge sharing of the CER Framework development and
operation and included the sharing of guidance and procedural documentation as
well as in-house training for staff.
Safety Case Assessments
In 2016, CER issued production safety permits for the Kinsale gas fields, followed by
a material change to the same. The material change was to reflect the upgrade
carried out to the offshore platform’s safe place of refuge (Temporary Refuge)
The first Acknowledgments of Compliance (AoC) were issued by CER in 2016 under
the new process. An AoC is a form of pre-acceptance of a drilling unit’s safety case,
prior to the application for any safety permit. The AoCs issued were for the Ocean
Valiant and the Ocean Guardian offshore drilling units.
Audits and Inspections
The Ocean Valiant was inspected as part of the AoC assessment process
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Two onshore inspections were carried out of the Corrib Gas production activity
Two onshore and two offshore inspections of Kinsale Gas production activity
All findings identified during the inspections were followed up and closed out to the
satisfaction of the CER.
Incidents and Performance Indicators
23 petroleum incidents were reported to CER in 2016. The reduction in reports from
previous years was the result of an updated set of reporting requirements introduced
in February, which better reflected the incidents falling within the CER’s remit
The quarterly safety performance reports submitted by production operators 2016 did
not indicate any potential for an emerging safety concern.
Enforcement
One enforcement action, a requirement for an Improvement Plan, carried over from
2015 was in relation to the production activity from the Kinsale gas fields. As
indicated in the 2015 report, the non-compliance was in relation to the offshore
platform (Alpha) not having an adequate safe place of refuge. The CER directed the
petroleum undertakings to submit an Improvement Plan where they outlined the
proposed plan to refurbish the existing accommodation block and upgrade it to a
functioning temporary refuge in the event of a major accident. On review, the CER
was satisfied that the Improvement Plan submitted was adequate. Monitoring of
progress of the Improvement Plan continued throughout 2016 and into 2017 until the
action is closed out
In 2016, the CER issued a ‘Notice of Intent to Serve an Improvement Notice’ on the
Kinsale gas production activity. The Notice was issued following identification of a
non-compliance relating to the implementation and carrying out of an Operational
Risk Assessment process. The Notice allowed the safety permit holders 21 days to
make representations to the CER, and on review of these representations, CER
deemed it no longer necessary with respect to safety considerations to proceed with
the issuance of the Improvement Notice
The CER was satisfied with the engagement and response of the operator
throughout the process of dealing with these enforcement matters.
Stakeholder Engagement
In addition to CER’s continuous engagement with European groups, such as the
North Sea Offshore Authorities Forum (NSOAF) and the European Offshore
Authorities Group (EUOAG), the Petroleum Safety team assisted another European
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Member State in the development of their regulatory framework. This reflects the
quality of the CER’s PSF and is an acknowledgement of the Petroleum Safety team’s
work to develop and maintain a robust safety environment for an ever-evolving oil
and gas industry.
Structure of the Report
The report is comprised of three parts, detailing the above work streams:
1. Gas Safety Regulatory Framework
2. Electrical Safety Supervision role
3. Petroleum Safety Framework.
The structure of this report is based on the key work priorities set out in the 2016 Work Plan
as submitted to the Minister at the beginning of 2016. The work streams are further
categorised into the following:
Compliance Assurance
Incidents
Key Performance Indicators
Enforcement
Continuous Improvement.
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Contents
Foreword ............................................................................................................................... 2
Executive Summary .............................................................................................................. 3
Gas Safety Regulatory Framework (GSF) ................................................................. 3
Electrical Safety Supervision ..................................................................................... 5
Petroleum Safety Framework (PSF) .......................................................................... 6
Structure of the Report .............................................................................................. 8
Contents ............................................................................................................................... 9
Figures and Tables ............................................................................................................. 12
Part 1: Gas Safety Regulatory Framework .......................................................................... 14
1.1 Introduction ............................................................................................................. 14
1.1.1 Objectives of the GSF ..................................................................................... 14
1.2 Regulation of Gas Undertakings .............................................................................. 15
1.2.1 Compliance Assurance ................................................................................... 16
1.2.2 Incidents Reported by Gas Undertakings ........................................................ 18
1.2.3 Enforcement ................................................................................................... 19
1.2.4 Emergency Response Programme ................................................................. 19
1.3 Registration of Gas Installers ................................................................................... 20
1.3.1 Compliance Assurance ................................................................................... 21
Enforcement ............................................................................................................ 22
1.4 Key Performance Indicators (KPIs) .......................................................................... 22
1.4.1 Key Safety Objective 1: Minimising the Risk of Loss of Containment ............. 22
1.4.2 Key Safety Objective 2: Maintaining Safe System Operating Pressure .......... 26
1.4.3 Key Safety Objective 3: Minimising the Risk of Injecting Gas of Non-
Conforming
Quality……………………………………………………………………………………….26
1.4.4 Key Safety Objective 4: Providing an Efficient and Coordinated Response to
Gas Emergencies .................................................................................................... 28
1.4.5 Key Safety Objective 5: Minimising the Safety Risks Associated with the
Utilisation of Gas ..................................................................................................... 29
1.4.6 Key Safety Objective 6: Promoting Public Awareness of Gas Safety .............. 31
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1.5 Continuous Improvement......................................................................................... 35
1.5.1 Stakeholder Engagement ............................................................................... 35
1.5.2 Joint Committee on Transport and Communications ....................................... 36
1.5.3 Development of New Performance Management Framework for RGII ............ 37
1.5.4 Review of Gas Safety Framework ................................................................... 37
1.6 Conclusion .............................................................................................................. 38
Part 2: Electrical Safety Supervision ................................................................................... 39
2.1 Introduction ............................................................................................................. 39
2.1.1 Registration of Electrical Contractors .............................................................. 39
2.2 Compliance Assurance .............................................................................................. 40
2.2.1 Audits and Inspections of Electrical Contractors ............................................. 40
2.2.2 Audits and Inspections of Safe Electric ........................................................... 40
2.2.3 Performance Reports Received from Safe Electric ......................................... 41
2.3 Enforcement ............................................................................................................ 41
2.4 Stakeholder Engagement ........................................................................................ 41
2.5 Electrical Safety Promotion and Public Awareness .................................................. 42
2.5.1 Building Public Awareness of the Electrical Safety Supervision Regulatory
Scheme ……………………………………………………………………………………...42
2.5.2 Review of Electrical Safety Promotional Material ............................................ 42
2.5.3 Redevelopment of Safe Electric Website ........................................................ 42
2.6 Conclusion .............................................................................................................. 42
Part 3: Petroleum Safety Framework .................................................................................. 44
3.1 Introduction ............................................................................................................. 44
3.2 Compliance Assurance ............................................................................................ 45
3.2.1 Safety Case Assessments .............................................................................. 45
3.2.2 Audits and Inspections .................................................................................... 47
3.3 Incidents .................................................................................................................. 47
3.4 Key Performance Indicators (KPIs) .......................................................................... 50
3.4.1 Performance Reports Received from Operators/Owners ................................ 50
3.5 Enforcement ............................................................................................................ 52
3.6 Stakeholder Engagement ........................................................................................ 53
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3.7 Continuous Improvement......................................................................................... 53
3.7.1 Introduction of Operators and Owners ............................................................ 54
3.7.2 Introduction of Acknowledgement of Compliance Process .............................. 54
3.7.3 Update to the Definition of Major Accident Hazard .......................................... 55
3.7.4 Update to Definition of Petroleum Incident ...................................................... 55
3.8 Conclusion .............................................................................................................. 55
Acronyms ............................................................................................................................ 57
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Figures and Tables
Figures
1. Registered Gas Installers (RGIs) by class of membership ............................................ 20
2. Inspections planned vs inspections completed on RGIs per quarter (2014–2016) ........ 21
3. Public reported gas escape frequencies ....................................................................... 23
4. Distribution third-party damage frequencies by supply type .......................................... 24
5. Distribution gas in buildings events and evacuations .................................................... 25
6. Number of long-term CP anomalies/faults (i.e. greater than six months) ..................... 25
7. Unplanned distribution outages .................................................................................... 26
8. Total number of planned and completed odour tests carried out .................................. 27
9. Gas escape responses efficiency by quarter ................................................................ 28
10. Numbers of meters that had been tampered with identified ......................................... 29
11. Numbers of gas escapes or faults identified as part of meter replacement programme 30
12. GNI safety disconnections at the meter ........................................................................ 30
13. Frequency of enquiries to the GNI emergency number vs actual reported escapes ..... 31
14. Plant location enquiries to the ‘Dial Before You Dig’ number ........................................ 32
15. RGI logo ....................................................................................................................... 35
16. Total number of Registered Electrical Contractors (RECs) (2009–2016) ...................... 39
17. Total inspections planned vs total inspections completed on RECs (2014–16) ............ 40
18. Safe Electric logo ......................................................................................................... 42
19. Overview diagram of Petroleum Safety Framework ...................................................... 44
20. Leading production safety performance indicators ....................................................... 50
21. Lagging production safety performance indicators ....................................................... 51
Tables
1. Accepted gas safety cases ........................................................................................... 15
2. Audits and inspections ................................................................................................. 17
3. Incidents reported to the CER in 2016 .......................................................................... 18
4. Gas Safety Promotion and Public Awareness Group – Stakeholders ........................... 33
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5. Key roles of the Petroleum Safety Framework ............................................................. 45
6. Safety permits issued by the CER in 2016 .................................................................. 45
7. Acknowledgements of Compliance issued by the CER in 2016 ................................... 46
8. CER inspections 2016 .................................................................................................. 47
9. Petroleum incidents reported to the CER in 2016 under S.I. 4/2014 ............................. 48
10. Petroleum incidents reported to the CER in 2016 under S.I. 166/2016 ......................... 48
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Part 1: Gas Safety Regulatory Framework
1.1 Introduction
This section provides an overview of the Gas Safety Regulatory Framework (GSF) and the
safety regulation of gas undertakings and gas installers by the CER through that Framework.
It details how the GSF has performed during 2016 and identifies key developments planned
for 2017.
In accordance with the Electricity Regulation Act 1999 as amended (the 1999 Act), the CER
regulates the safety performance of the downstream Irish natural gas industry. The scope of
the relevant legislation includes the safety regulation of all natural gas undertakings,
including storage, transmission, distribution, supply and shipping. Since 2014, the GSF has
also included the safety regulation of Liquefied Petroleum Gas (LPG) undertakings.
Promoting the safe utilisation of gas by domestic customers is also a responsibility of the
CER under this legislation. To ensure safe use of gas, the CER appoints a GSSB to regulate
the activities of gas installers who carry out gas works in domestic premises in Ireland with
respect to safety.
1.1.1 Objectives of the GSF
In order to deliver on its strategic goal of ensuring safe supply of gas, the CER has
established a series of high-level safety objectives for the Framework. These key objectives
are set out below. For each objective, the CER has specified a set of KPIs to be reported on
a quarterly basis by licensed natural gas and LPG undertakings and the GSSB. See Section
1.4 for further details.
Key Objectives of the Gas Safety Regulatory Framework
1. Minimising the Risk of Loss of Containment
2. Maintaining Safe System Operating Pressure
3. Minimising the Risk of Injecting Gas of Non-Conforming Quality
4. Providing an Efficient and Coordinated Response to Gas Emergencies
5. Minimising the Safety Risks Associated with the Utilisation of Gas
6. Promoting Public Awareness of Gas Safety
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1.2 Regulation of Gas Undertakings
Under the provisions of the 1999 Act, the CER has the responsibility of regulating the
activities of gas undertakings with respect to safety.
Undertaking/ Licensee Tr
ansm
issi
on
Dis
trib
uti
on
LPG
Dis
trib
uti
on
Gas
Sto
rage
Ship
pe
r
Sup
plie
r
Ship
pe
r/
Sup
plie
r
Aughinish Alumina ●
Bord Gáis Energy
●
Calor Teoranta ●
Electric Ireland
●
Energia
●
ESB Energy International
●
ESB Independent Energy
●
Flogas Ireland Limited ●
Flogas Natural Gas Ltd
●
GNI ● ●
Gazprom Marketing & Trading Retail Ltd
●
Huntstown Power
●
Just Energy
●
Manx Utilities
●
Panda Power ●
Prepay Power ●
PSE Kinsale Energy ● ●
Shell Energy Europe Limited
●
SSE Airtricity
●
SSE Energy Supply Limited
●
Statoil Exploration Ireland Limited
●
Statoil Gas Hibernia Ltd
●
Tynagh Energy Ltd
●
Vayu Energy Limited
●
Vayu Ltd
●
Vermilion Energy Ireland Limited
●
Table 1 Accepted gas safety cases
All natural gas undertakings and LPG undertakings operating piped distribution networks to
two or more domestic customers are required to submit a safety case to the CER as part of
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their licence application in accordance with the Gas Safety Regulatory Framework Safety
Case Guidelines and are subject to ongoing regulation for the duration of that licence.
Table 1 (above) provides a list of undertakings with safety cases accepted by the CER.
1.2.1 Compliance Assurance
Safety Case Assessments
In 2016, the CER continued to assess material changes to existing safety cases. This
included the commencement of a material change assessment for the safety cases of both
GNI’s Transmission System Operators and Distribution System Operators to take account of
the introduction of CNG assets into the network. The assessment continued into 2017.
Furthermore, both licensed LPG undertakings (Calor Teoranta and Flogas Ireland Limited)
submitted material changes to the CER in relation to their Emergency Response
Arrangements. Calor Teoranta’s material change was accepted in December 2016 and
Flogas Ireland Limited’s material change continued to be assessed into 2017.2
Audits and Inspections of Gas Undertakings
As part of its annual work programme, the CER agrees an audit and inspection programme
for natural gas and licensed LPG undertakings. The review topics are decided upon by
taking into account previous audit and inspection findings, incident reports and safety case
risk ratings.
All audits/inspections carried out in 2016 are detailed below and set out in Table 2.
GNI
There were 11 audits and inspections in 2016 on GNI (performing the functions of
Distribution and Transmission System Operator (DSO/TSO)). This included four inspections
on the transmission system and one joint audit with the HSE (UK) in Scotland under the
Interconnector Agreement. There were three inspections on the distribution system. Three
joint audits on both the transmission and distribution systems were also carried out.
All findings and recommendations generated from the 2016 audits and inspections were
reported to GNI for follow up within particular timeframes, as appropriate. The CER monitors
GNI’s progress in implementing these findings and recommendations by means of a
programme of scheduled verification meetings.
2 Flogas’ material change submission was subsequently accepted in January 2017.
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Table 2 Audits and inspections: distribution and transmission
Shippers/supplier audits
Five gas shipper/supplier audits were planned for 2016, four of which were completed on
schedule with one being deferred to 2017. The purpose of these audits is to ensure
compliance with the GSF and to verify that previously raised actions were addressed
satisfactorily. No actions remain open from any shipper/supplier undertakings audited in
2016.
Undertaking Shipper/Supplier
Bord Gáis Energy Supply & Shipping
Flogas Natural Gas Limited Supply & Shipping
Shell Energy Europe Limited Shipper
Vermilion Energy Ireland Limited Supply & Shipping
Table 2.1 Shipper and supplier audits
Licensed LPG undertakings
Table 2.2. LPG undertakings audits
Distribution/Transmission Inspection/Audit Topic
Distribution Inspection Non-Routine Operations
Distribution Inspection Four Bar in Buildings (Previously delayed from Aug 2015)
Distribution Inspection Mains Replacement Programme
Transmission Inspection Transmission Emergency Stores and Critical Spares
Transmission Inspection Permit to Work Quality Assurance
Transmission Inspection Sampling of AGI Locations for Proximity Infringements & QRA
Transmission Inspection CIPS Survey Inspection
Transmission Inspection Inspection of GNI Assets in Scotland (Joint CER/HSE (UK))
Joint Distribution/Transmission
Audit Non-Routine Operations
Joint Distribution/Transmission
Audit ATEX Program
Joint Distribution/Transmission
Audit Transmission/Distribution Technical Standards
Undertaking Inspection/Audit Topic
Calor Teoranta Audit Safety Case Compliance Audit 1
Flogas Ireland Limited Audit Safety Case Compliance Audit 1
Calor Teoranta Audit Safety Case Compliance Audit 2
Flogas Ireland Limited Audit Safety Case Compliance Audit 2
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Following the granting of LPG Safety Licences to both Calor Teoranta and Flogas Ireland
Limited in December 2015, the CER undertook two audits of each undertaking in 2016.
All findings and recommendations generated from the 2016 audits have been reported to the
undertakings for follow up within particular timeframes, as appropriate. The CER monitors all
undertakings’ progress in implementing recommendations and intends to establish a formal
schedule of verification meetings from 2017 onwards.
1.2.2 Incidents Reported by Gas Undertakings
The CER monitors all licensed undertakings’ safety performance and investigates incidents.
The CER reviews all reported incidents for appropriate learnings and incorporate them into
the GSF in order to prevent reoccurrence.
The criteria for natural gas incident reporting has been established and operational for a
number of years. Furthermore, 2014 regulations made it a legal requirement for specified
LPG incidents to be reported to the CER.3
The specified incident types under the natural gas and LPG regulations are as follows:
A – Involves a fatality
B – Injury requiring hospitalisation
C – Property damage in excess of €6,348.69 (natural gas) or €6,500 (LPG).
Incidents During 2016
Type A Type B Type C RuG Voluntary Reported LPG
Total
Natural Gas 0 0 0 12 - 12
LPG 0 2 0 - 3 5
Table 3 Incidents reported to the CER in 2016
20 incidents were reported to the CER during 2016, three of which, on further investigation,
did not meet the CER’s reporting requirements. A breakdown, by category, of the remaining
incidents is set out in Table 3.
Table 3 also shows Reportable under Guidelines (RuG) and Voluntary Reported LPG
incidents which do not fall under Category A, B or C. RuG are defined in procedures issued
by the CER and apply to natural gas only. LPG voluntary reporting is where the undertaking
is of the view that it would be desirable to report a particular incident to the CER.
The two reportable incidents during 2016 resulted in the hospitalisation of individuals. Post-
incident inspections identified one as resulting from suspected misuse of an LPG cylinder,
and the other inspection could not be definitive as to the cause of the incident.
3Liquefied Petroleum Gas Safety (Liquefied Petroleum Gas Incident) Regulations 2014 (S.I. No. 77), and Liquefied Petroleum Gas Safety (Liquefied Petroleum Gas Incident Reporting and Investigation) Regulations 2014 (S.I. No. 78).
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The 12 RuG incidents included those involving suspected carbon monoxide, downstream
customer-related incidents and third-party damage to the gas distribution or transmission
network. Within this figure are a number of incidents that initially appeared to meet the
criteria for RuG which, following further investigation, were found not to be related to natural
gas.
In 2016, three LPG incidents were voluntarily reported to the CER. Upon further investigation, one did not involve LPG while the other two were incidents related to third-party damage.
1.2.3 Enforcement
Three formal enforcement actions were initiated with respect to the two licensed LPG
undertakings – Calor Teoranta and Flogas Ireland Limited.
The first two enforcement actions were initiated against both licensed LPG undertakings in
relation to their Emergency Response Arrangements. This was due to the failure to
implement their Emergency Response Arrangements as set out in their respective safety
cases. Due to the importance of having in place appropriate Emergency Response
Arrangements, the CER was of the view that it should commence the process of issuing an
Improvement Notice on both undertakings under section 9JB of the 1999 Act, as amended.
The Notice of Intent to Serve an Improvement Notice was issued to both undertakings on 5
September 2016 and representations were received. The CER will conduct an audit and
inspection on these arrangements in 2017. Following the audit and inspection, the CER will
consider whether the Improvement Notice should be served or whether the Intent to Serve
an Improvement Notice should be withdrawn.
Separately, during the course of a routine audit of Calor Teoranta, the CER became aware
of unsafe pressure testing that was not in line with the requirements of standards or the
undertaking’s respective accepted safety cases. Due to the dangers, the CER was of the
view that a Direction to Submit an Improvement Plan should be issued to Calor Teoranta
under section 9JA of the 1999 Act, as amended.
The Direction was issued to Calor Teoranta on 21 September 2016 and the Improvement
Plan was submitted to the CER within the required timeframe. The CER was satisfied the
submitted Improvement Plan was adequate. An inspection will be carried out in 2017 to
verify its implementation.
1.2.4 Emergency Response Programme
GNI prepare the Natural Gas Emergency Plan (NGEP) under the direction of the CER and in
consultation with the gas industry, the electricity industry and the Government. The purpose
of the plan is to establish procedures in the event of a natural gas emergency in Ireland.
During 2016, three emergency exercises were carried out in order to test the procedures
outlined in the NGEP. Further exercises were carried out which included the Department of
20
Communications, Climate Action and Environment (DCCAE), the CER and Eirgrid. Such
exercises, which require cooperation between CER and others, are essential for ensuring
preparedness in the case of emergencies.
Separately, GNI carries out emergency exercises on the distribution network. Two such
emergency exercises took place during 2016.
1.3 Registration of Gas Installers
Under the 1999 Act, as amended, the CER has a legal function to regulate the activities of
gas installers with respect to safety. Following a competitive public procurement process in
2015, the RGII was appointed as the GSSB to carry out this function for a seven-year period
commencing January 2016. The RGII has a number of functions, duties and
responsibilities.4
Figure 1 Registered Gas Installers (RGIs) by class of membership
The number of RGIs in the regulatory scheme at the end of 2016 was 2,971 compared to
3,063 in 2015, as shown in Figure 1 below. The competence of individual installers is
affirmed at entry to the scheme by the RGII, and also through an ongoing inspection
process.
A complete list of RGIs operating in Ireland is available on the RGII website www.rgii.ie.
It is a legal requirement that gas works are undertaken only by an RGI and that a
Completion Certificate is issued in all cases. The RGII has a Suspension and Revocation
Procedure in place to address issues of non-compliance with the RGII Rules of Registration.
The media message, in relevant publicity campaigns, will continue to emphasise to
customers the requirement to use an RGI and the importance of obtaining a Completion
Certificate.
4 As set out in the 1999 Act as amended, the Gas Safety Supervisory Criteria Document V 1.6 (CER/16/222), and the Terms and Conditions of Appointment.
14 Q1 14 Q2 14 Q3 14 Q4 15 Q1 15 Q2 15 Q3 15 Q4 16 Q1 16 Q2 16 Q3 16 Q4
Trainee 10 9 5 5 8 8 8 7 9 7 8 8
Full 3070 2982 2984 3048 3097 3097 3041 3056 3080 3079 2970 2963
0
500
1000
1500
2000
2500
3000
3500
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1.3.1 Compliance Assurance
Audits and Inspections Carried Out by the RGII
The RGII is required to monitor, audit and inspect the safety standard of RGIs and their work
on an ongoing basis. Scheduling of inspections are in line with the requirements of the
published Criteria Document and the RGII submits an annual audit and inspection
programme for approval by the CER.
The RGII reports on the number of inspections of RGIs completed on a quarterly basis to the
CER. RGIs must be inspected a minimum of once per year, and new RGIs at a minimum of
twice per year. However, RGIs may be subject to additional inspections subject to their
safety performance.
Figure 2 Inspections planned vs inspections completed on Registered Gas Installers (RGIs) per quarter (2014–2016)
During 2016, the RGII carried out 3,144 inspections in comparison to the 3,230 inspections
planned for the year (97%). The figure below shows the number of inspections planned and
inspections carried out by the RGII per quarter covering 2014–2016.
Audits and Inspections of the RGII
The CER conducted an audit of the RGII to provide assurance that it is performing its core
functions in compliance with the Criteria Document5 and the Terms and Conditions of
Appointment. The audit identified a number of non-conformances and opportunities for
improvement. The CER required the submission of action plan by the RGII and will hold
quarterly meetings with the RGII during 2017 to ensure that actions are taken to address all
issues raised during the audit, by the end of 2017.
5 The current Criteria Document in respect of gas installers is Criteria Document Version 1.5, The Regulation of
Gas Installers with Respect to Safety, 19 November 2015, and is available on the CER website, www.cer.ie.
0
200
400
600
800
1000
1200
14 Q1 14 Q2 14 Q3 14 Q4 15 Q1 15 Q2 15 Q3 15 Q4 16 Q1 16 Q2 16 Q3 16 Q4
Total Inspections Planned Total Inspections Completed
22
The CER’s Technical Specialist also monitors and inspects the RGII and its inspectors to
verify their safety performance through an approved audit and inspection programme.
Enforcement
By law, in order to complete gas works relating to a domestic appliance, an individual must
be registered with the RGII. Unregistered parties who carry out gas works relating to a
domestic appliance, or who describe themselves as an RGI or act in a manner likely to
suggest that they are an RGI while not being registered, may be fined up to €15,000 or
imprisoned for up to three years or both.
In 2016, the CER commenced 68 investigations into reports received relating to allegations
of unregistered individual parties carrying out gas works, falsely portraying themselves as
registered or describing themselves in a manner likely to suggest they were registered. Of
these investigations, three successful prosecutions were undertaken by the CER in 2016,
giving 29 successful prosecutions taken by the CER since the introduction of the RGI
regulatory scheme. The status of the remaining reports received includes:
Still under investigation.
Prosecution not recommended due to:
o lack of evidence that an offence had taken place
o the alleged offence took place outside of the jurisdiction of the Republic of
Ireland.
The CER will continue to carry out investigations and take enforcement actions including
prosecutions, cease and desist warning letters and interviews of suspected illegal gas
installers during 2017, as necessary.
1.4 Key Performance Indicators (KPIs)
GNI, Calor Teoranta, Flogas Ireland Limited and the RGII report on KPIs quarterly to the
CER and compiled into performance reports. These reports provide an overview of the
performance of the GSF, including the GSSB scheme.
As Calor Teoranta and Flogas Ireland Limited received their licences in December 2015,
there is insufficient data to identify trends at this stage. The information in respect of GNI
and the RGII for 2016 is given below.
1.4.1 Key Safety Objective 1: Minimising the Risk of Loss of
Containment
Gas undertakings are required to demonstrate that they have suitable management systems
and procedures in place for managing the risks that lead to loss of gas containment events
occurring. Within the scope of this objective are:
Gas escapes reported by the public
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Damage to the gas transmission (high pressure) and distribution systems (lower
pressure) networks
Gas entry into buildings
Surveillance of works near pipelines
Corrosion protection and prevention.
Gas Escape Reports
There were 17,428 Public Reported Escapes (PREs) in 2016, a decrease on the number in
2015 (19,449). Events where ‘no gas’ was detected accounted for 9,422 (54%) of the PREs
reported in 2016.
Figure 3 Public reported gas escape frequencies
On the transmission network, there were six PREs reported compared to 11 in 2015. The
PREs were not on any part of the active transmission pipeline, but were reported as being
within Above Ground Installations (AGIs).
Third-Party Damage
On the distribution system, 93 third-party damage instances occurred to gas mains and 426
to gas services. This compares to 84 third-party damage instances on the distribution mains
and 395 on gas services in 2015.
GNI aims to mitigate instances of third-party damage through active promotion of ‘Dial
Before You Dig’ along with initiatives to promote the sharing of map data with other third
parties through the Field Access to Automated Records (FAAR) system.
24
Figure 4 Distribution third-party damage frequencies by supply type
Transmission Pipeline Encroachment
Ongoing monitoring of the national transmission pipeline ensures prevention of potential
damage to pipelines and their protective coatings. Controls are in place by GNI when third
parties carry out work in close proximity to transmission pipelines. GNI maintains a
surveillance programme by foot and by vehicular and aerial surveys, in accordance with the
UK Onshore Pipeline Operators Association guidelines.
The total number of encroachments detected in 2016 was 51 compared to 44 in 2015. They
were identified across recurrent activities such as the installation of poles, deepening of
ditches, drainage installations, road works, building works and cable laying.
During a routine inspection of the Dublin-Cork Pipeline by GNI, significant third-party
damage to the transmission pipeline in Tipperary was detected. This damage likely occurred
in 2011 caused by a mechanical excavator. GNI repaired the damage using techniques that
did not interrupt the flow of gas.
GNI notified the CER of its anticipated repair technique and CER monitored each phase of
the repair closely to ensure that all associated risks were managed to the ‘As Low As
Reasonably Practicable’ (ALARP) level in relation to the management of safety risks. The
repair works were carried out in accordance with established GNI procedures and in line with
GNI’s Safety Case, which was verified by the CER. This included multiple site visits and
inspections. Completion of the repair was without incident or loss of supply.
GNI submitted corrective and preventative actions to CER as part of its internal investigation
into the incident. A consequence of the damage to the pipeline was the diversion of
resources from within GNI to attend to the repair. This was evident in a reduction of
maintenance achieved during the repair period and was observed in submitted KPIs. GNI
will be audited on third-party damage avoidance in 2017; the audit will also review the
effectiveness of the proposed actions.
25
Gas Entry into Buildings and Evacuations
The Figure 5 below shows all gas in buildings events and/or GNI-initiated evacuations
(greater than 15 people) reported by GNI that were caused by a source outside of a building.
There were no such events during 2016.
Figure 5 Distribution gas in buildings events and evacuations
Pipeline Corrosion Protection
Continuous monitoring of Cathodic Protection (CP) was introduced in 2011. Since then, the
number of anomalies/faults existing for more than six months has reduced to zero. Now that
events are being detected and investigated sooner, faults are being repaired and the
likelihood of corrosion occurring is significantly reduced.
Figure 6 Number of long-term CP anomalies/faults (i.e. greater than six months)
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1.4.2 Key Safety Objective 2: Maintaining Safe System Operating
Pressure
Gas undertakings are required to demonstrate that they have suitable management systems
in place for managing the risks that can result in dangerously high or low gas operating
pressure in the pipeline system(s). Within the scope of this objective are:
Gas Outages
Pressure Management and Control.
Gas Outages
There were three unplanned gas outages on the distribution network during 2016, two of
which affected more than 100 customers and one of which affected between 15 and 99
customers. These outages were in relation to third-party damage to the gas distribution
network.
Figure 7 Unplanned distribution outages
System Pressure Management
As part of the Supervisory Control and Data Acquisition (SCADA) system which GNI
operates, a number of defined parameters, such as system pressure, are constantly
monitored and controlled. No system pressure drops or over-pressure events occurred on
the distribution or transmission networks in 2016.
1.4.3 Key Safety Objective 3: Minimising the Risk of Injecting Gas of
Non-Conforming Quality
Gas emergency incidents can arise due to injection of gas of inappropriate quality into the system. As such, gas undertakings are required to demonstrate that they have suitable management systems in place for gas quality monitoring and for managing the risks associated with the quality of gas injected into the system.
27
The KPIs for this objective are:
Odorant
Gas Quality.
Odorant Management
In order to identify uncontrolled escaping gas, odorant is added to natural gas, the concentration of which must be maintained within prescribed limits. To ensure consistency, tests are taken at various locations with odorant levels measured in accordance with the internationally recognised Sales scale. No non-compliant test results were returned in 2016, which was in line with 2015.
Figure 8 Total number of planned and completed odour tests carried out
Gas Quality
Ensuring that gas quality remains within a prescribed range is critical to ensuring that gas
supply remains safe. Poor quality gas could result in a fluctuation of the calorific value of gas
supplied to the customer. This could reduce heat input and increase the risk of incomplete
combustion, which would increase the levels of carbon monoxide produced.
GNI monitors specific parameters such as the Wobbe index, the Soot index and the calorific
value to ensure that gas entering the network is within the prescribed limits.
There were four non-compliant-gas-quality events in 2016 all of which related to the Corrib
entry point. These were investigated by GNI. All quality issues were associated with
hydrocarbon dewpoint; they were transient and had no downstream effects. The CER has
engaged with GNI with respect to this matter.
28
1.4.4 Key Safety Objective 4: Providing an Efficient and
Coordinated Response to Gas Emergencies
Gas emergency events occur due to insufficient supplies into the network or a transportation constraint, including the actions of third parties. GNI is required to demonstrate that it has suitable arrangements in place for:
1. Managing the response to ‘localised’ gas emergencies 2. Undertaking the role of National Gas Emergency Manager during ‘network’ gas
emergencies.
Additionally, all gas undertakings are required to demonstrate that they have suitable arrangements in place for responding to the requirements of the National Gas Emergency Manager in the event of a large-scale ‘network’ gas emergency. The KPIs for this regulatory objective are:
Gas Supply Emergencies
Public Reported Gas Escapes Response Times.
Gas Supply Emergencies
There were no gas supply emergencies during 2016 that required initiation of the Natural
Gas Emergency Plan (NGEP). This is consistent with 2015.
Public Reported Gas Escapes Response Times
GNI has committed to respond to 97% of all reported escapes of gas within one hour. In
2016, 19 responses were outside the one-hour response criterion (99.89% were within)
compared to 20 in 2015. The average response time for 2016 was 28 minutes, which is the
same as the average response time for 2015.
Figure 9 Gas escape response efficiency by quarter
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1.4.5 Key Safety Objective 5: Minimising the Safety Risks
Associated with the Utilisation of Gas
The GSF provides for a comprehensive regime relating to the regulation of gas installers. The key aim is that all categories of ‘gas works’ designated by the CER are undertaken only by competent gas installers who are registered and subject to ongoing regulation and inspection by the GSSB appointed by the CER. The safety risks associated with the connection and re-connection of customers’ installations to the gas supply network and the servicing of such installations are addressed within the scope of this objective. The KPIs for this regulatory objective are:
Registered Gas Installers and the Regulatory Scheme
Meters
Carbon monoxide
Disconnections.
Meters
Meters are monitored by reviewing meter-tampering events and meter joint gas escapes,
and by implementing the Meter Replacement Programme.
Meter-Tampering Events
In 2016, there were 393 meter-tampering events discovered compared with 524 in 2015.
The GNI Revenue Protection team and gas meter inspectors continue to monitor possible
meter-tampering events. A GNI meter-tampering advertising campaign took place in 2016.
Figure 10 Numbers of meters that had been tampered with identified
Meter Replacement Programme
The ongoing Meter Replacement Programme continued during 2016. A total of 23,668
meters were replaced as part of the Meter Replacement Programme in 2016.
30
Meter Joint Gas Escapes
During the works relating to the Meter Replacement Programme in 2016, GNI identified 86
meter joint gas escapes.
Figure 11 Numbers of meter gas escapes or faults identified as part of Meter Replacement Programme
Safety Disconnections
Figure 12 GNI safety disconnections at the meter
Where an unsafe gas situation is identified at a customer’s property, GNI will isolate the gas
supply to an appliance or installation. A Notice of Hazard (NoHZ) will then be issued to the
31
customer advising what action should be taken and requesting that a RGI is employed to
make necessary repairs.
During 2016, there were 4,952 instances resulting in GNI isolating a gas meter, down from
6,468 in 2015.
1.4.6 Key Safety Objective 6: Promoting Public Awareness of Gas
Safety
Increasing the level of gas safety awareness in general, and of the dangers of carbon
monoxide in particular are important aspects of the CER’s overall objectives. It is also
important owners and occupiers of premises are aware of their responsibilities in respect of
the maintenance of gas fittings downstream (on the customer side) of the meter. The GSF
places duties and obligations on both individual gas undertakings and the industry generally
for the promotion of gas safety awareness, which involves a combination of individual and
coordinated safety promotion activities by undertakings.
The KPIs for this regulatory objective are:
GNI Emergency Number Calls
Carbon Monoxide Reports and Website Visits
Dial Before You Dig Calls
RGII Awareness Campaign.
Emergency Number Calls
Figure 13 Frequency of enquiries to the GNI emergency number vs actual reported escapes
It is essential that when a member of the public notices a gas escape they can identify the
correct number to call to report it. To monitor public awareness and the effectiveness of
advertising of the emergency number, all calls to the number are noted. In 2016, 68.75% of
calls to the emergency number were gas escape calls with the remainder made up of calls
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that related to bill enquiries, carbon monoxide events, Dial Before You Dig enquiries,
redirected calls from 999 and calls related to issues outside the remit of GNI.
During 2016, there were 17,428 calls to the emergency number, down from 19,449 in 2015.
Carbon Monoxide Calls and Website Activity
There were 1,158 calls to the carbon monoxide number and 69,202 visits to the website
(www.carbonmonoxide.ie) during 2016.
GNI Dial Before You Dig (1850 427 747)
Figure 14 Plant location enquiries to the ‘Dial Before You Dig’ number
The ‘Dial Before You Dig’ process is designed to provide third parties with safety advice
before they excavate. GNI continues to provide access to its Field Access to Automated
Records (FAAR) to third-party contractors, utility companies and local authorities, which
allows third parties to eliminate enquiries that do not impact on the gas network. However,
instances of third-party damage continue to occur and this remains an area of focus for
continuous improvement.
Calor Teoranta and Flogas Ireland Limited also have a Dial Before You Dig system in place
in respect of their distribution networks.
Gas Safety Promotion and Public Awareness (PAPA)
The CER has statutory obligations in relation to gas safety promotion and public awareness
under the 1999 Act and increasing gas safety awareness is an integral part of the GSF
objectives.
The CER chairs the Gas Safety Promotion and Public Awareness Group (PAPA), and in
conjunction with industry oversees the development and review of national gas safety
promotion and public awareness activities. See Table 4 below for group membership.
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The activities of this group include discussion and decisions on all related media promotions,
safety surveys, public awareness initiatives and promotions external to the industry.
The 2016 promotion programme continued to focus on developing awareness among the
public of the RGI scheme and carbon monoxide (CO) safety. One of the highlights of the
2016 campaign was Carbon Monoxide Awareness Week, held in September, as outlined
below.
Key Stakeholders
GNI
RGII Electric Ireland Calor
Flogas
SSE Airtricity Bord Gáis Energy Irish Liquefied
Petroleum Gas
Association (ILPGA)
National Standards
Authority of Ireland (NSAI)
CER Energia OFTEC
Table 4 Gas Safety Promotion and Public Awareness Group – Stakeholders
The programme of campaigns used a range of media to develop public awareness and
included:
Carbon Monoxide Awareness Week
Gas escape awareness through TV, radio and national press
Carbon monoxide awareness and prevention through TV, radio, leaflets, posters,
national and local press
Promotion of the RGI scheme and of the need to hire a Registered Gas Installer,
through TV, radio and national press
Promotion of increased vigilance when working in the vicinity of buried gas assets
through national and local press and trade journals
Advertising of emergency details, advice and contact information
Instructions to landowners with gas pipelines on their property through on-site advice,
liaison and instruction leaflets
Gas safety leaflets circulated to consumers along with their gas bills.
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Carbon Monoxide Awareness Week
Carbon Monoxide Awareness Week took place from Monday 26 September to Sunday 2
October 2016. This involved a PR launch with the Minister for Communications, Climate
Action and Environment, Denis Naughten, TD, and the CER Director of Energy Safety, Ann
McGarry. Representatives of all participating groups and members of the press were also
present, and the launch involved advertising, radio, on-line press, social media and
television campaigns. At the launch the risk of carbon monoxide poisoning and the
importance of carbon monoxide alarms were discussed.
The objective of Carbon Monoxide Awareness Week is to create and maintain awareness of
the dangers associated with carbon monoxide and to communicate the preventative
measures that the public should take.
The three core messages of the campaign were:
Remember the causes: Carbon monoxide can be produced when any fuel is burnt,
including oil, gas, wood and coal
Remember to service: To prevent carbon monoxide, have your appliances serviced
annually and keep vents, flues and chimneys clear
Remember the alarm: For added protection install an audible carbon monoxide
alarm.
The evidence suggests that the Carbon Monoxide Awareness Week did affect consumer
consciousness. In 2016, 93% of people surveyed were aware that carbon monoxide is
dangerous.
85% of adults surveyed in 2016 could recall an ad about carbon monoxide in one form or
another while 94% of adults could recall at least one action they should take if they suspect
carbon monoxide is present.
Post the 2016 campaign, 56% of adults surveyed claimed to have an audible carbon
monoxide alarm. This is a positive upward metric, as only 32% of adults claimed to have an
alarm following the 2014 campaign.
To find out more about carbon monoxide causes, symptoms, prevention and protection
measures call 1850 79 79 79 or visit www.carbonmonoxide.ie.
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RGI Awareness Campaign
A new promotional campaign was developed during
2016. This campaign included national and local
press, communication with industry parties and
updating of existing television and radio
advertisements. This campaign focused on domestic
customers’ awareness of the requirement that only
RGIs can carry out domestic gas works.
Taking the campaign as a whole through all media
channels, four in five people surveyed (80%) could
recall having seen it at some stage (up from 59%). In
overall terms, recall levels are high and well ahead of 2015 levels.
Just one in ten adults have had gas works undertaken over the past 12 months. This
proportion rises to a quarter within Dublin. The vast majority of those who had gas works
carried out did so with an RGI and 88% of these were provided with a certificate for this
work. To find an RGI visit www.rgii.ie.
1.5 Continuous Improvement
1.5.1 Stakeholder Engagement
CER hold regular meetings with all relevant stakeholders including GNI, LPG undertakings,
natural gas shippers/suppliers, RGII and the Department of Communications, Climate Action
and Environment (DCCAE) to discuss natural gas and LPG safety issues. Wider industry
stakeholders, such as the National Standards Authority of Ireland (NSAI), the Health and
Safety Authority (HSA) and consumer groups and associations, are also involved in
communications on safety with the CER, as required.
A number of safety governance groups supports the CER in its work. The Gas Safety
Committee is one such group; the CER, GNI, DCCAE and representatives attend it from the
LPG industry. The Committee met three times in 2016 to discuss gas-related incidents and
associated issues in order to identify learning outcomes and to recommend any follow-up
actions, which could serve to improve safety outcomes.
During 2016, the CER and GNI attended the distribution and transmission Interface Group
on a quarterly basis to discuss progress on all major safety-related work items and
operational issues. Ongoing TSO/DSO inspection verification meetings also occurred
between the CER and GNI to discuss issues arising from the CER’s audits and inspections.
The CER intends to implement inspection verification meetings with the licensed LPG
undertakings in 2017.
Figure 15 RGI Logo
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1.5.2 Joint Committee on Transport and Communications
The CER appeared before the Joint Committee on Transport and Communications in 2015.
Representatives of both the CER and the Association of Plumbing & Heating Contractors
Ireland (APHCI) presented to the Committee. Following the meeting, a report was produced
on the Regulation and Inspection of Gas Installers Operating in Ireland outlining the
Committee’s recommendations. See below for an update on the recommendations.
Extent of Illegal Activity on Domestic Gas Market
In conjunction with GNI, in Quarter 4 2016, the CER commissioned a behavioural survey of
natural gas customers. The findings showed that 92% of respondents who had gas works
carried out in the previous 12 months had used a RGI. Almost all of these (88%) were
provided with a certificate for this work. 4% of respondents stated that they had not used an
RGI and the remaining 4% did not know if their gas installer was registered or not.
Acknowledging the limitations of the survey, the figure of 92% overall was somewhat higher
than the CER had anticipated. Nonetheless, the CER is continuing to pursue all information
provided concerning potentially illegal gas works and to prosecute those people found to be
in breach of the law. In terms of the reasons for using a RGI, their being trained and qualified
was mentioned by close to half of all respondents. The survey also revealed a high level of
awareness of the RGII scheme with close on two thirds of the adults surveyed indicating that
they had heard of the scheme.
Legislative Change to Provide that Gas Boilers Be Sold Only to RGIs
The CER is supportive of the proposed initiative that gas boilers be sold only to RGIs. The
CER has engaged with industry representatives to propose the introduction of a voluntary
scheme to restrict the sale of gas boilers to RGIs only, and to encourage sellers to place
promotional material at points of sale to reinforce the message to the public of the benefits of
using an RGI.
Industry representatives have informed the CER that for commercial reasons in the absence
of legislation they would not support the introduction of a restriction on the sale of boilers.
The CER engaged with the RGI Installer Representative Panel (IRP) to develop suitable
promotional material subsequently circulated to all retailers who sell gas appliances for
display at points of sale. The CER will continue to follow up with the Department of
Communications, Climate Action and Environment regarding a legislative basis for this
proposal.
Engagement with Insurance Ireland to Make Home Insurance Conditional on
the Provision of Evidence that Gas Boilers Are Installed and Serviced by RGIs
Since the publication of the Joint Committee’s report, the CER has met with Insurance
Ireland. The CER outlined the Committee’s recommendation that the provision of home
insurance be made conditional upon persons seeking insurance cover providing evidence,
where applicable, of gas boilers having been installed and serviced by RGIs.
37
Insurance Ireland noted the CER’s comments and stated that after careful consideration by
its members, they would not be supportive of introducing this initiative. The CER continues
to deliver the message to the public via the annual RGI and carbon monoxide awareness
campaigns that, in the interest of safety, gas appliances should be installed and serviced
only by RGls and that all gas appliances should be serviced on an annual basis.
Introduction of a Scheme of Registration for Non-Domestic Gas Works
In October 2015, the CER published a decision paper entitled Extension of the Registered
Gas Installer Scheme to include non-domestic gas works.6 This paper outlined the definition
of non-domestic gas works and the high-level approach of the regulatory model to facilitate
its introduction into the scheme. This will make it a legal requirement for non-domestic gas
works to be carried out only by a Non-Domestic RGI. The next stage of this project focuses
on stakeholder engagement, the development of legislation, the setting of a voluntary
register, and the decision on scheme entry requirements. The CER will work with industry
stakeholders to deliver a voluntary Non-Domestic Regulatory Model by Quarter 3 2017, with
full legislative implementation by January 2019.
1.5.3 Development of New Performance Management Framework
for RGII
The ‘Performance Management Framework’ developed by the CER requires the RGII to
report against a series of Key Performance Indicators (KPIs) and supporting metrics
quarterly. These reports provide assurance to the CER that the RGII is fulfilling its
obligations as detailed in the Criteria Document and the Terms and Conditions of
Appointment. In order to bring increased transparency and accountability and to promote
continuous improvement in the scheme, these KPIs will be reviewed, and a new
performance management framework will be developed by the CER in 2017.
1.5.4 Review of Gas Safety Framework
The Gas Safety Regulatory Framework is constantly kept under review and in July 2014, the
CER published an updated Gas Safety Regulatory Framework High Level Approach
document which set out developments in the GSF since 2007 (CER/14/296).
In that document, the CER committed to providing licensed undertakings with guidance as to
how safety risks can be managed to a level that is ‘As Low As Reasonably Practicable’
(ALARP). To this end, in 2015 the CER published the following consultation documents:
ALARP Guidance – Part of the PSF and the Gas Safety Regulatory Framework
Safety Case Guidelines for Natural Gas and LPG Licensed Undertakings.
6 See Extension of Registered Gas Installer Scheme to include Non-Domestic Gas Works, Final Decision Paper, CER/15/244.
38
2016 saw publication of a final ALARP Guidance Policy Document and a Decision Paper on
the Safety Case Guidelines for Natural Gas and LPG Licensed Undertakings.
Compressed Natural Gas
In June 2016, the CER published a decision paper entitled: Compressed Natural Gas (CNG)
for Vehicular Transport: Licensing Arrangements (Ref. CER/16/154). This paper set out that
CNG suppliers for vehicular transport will be required to apply for, and be issued with, a
Supply Licence in accordance with section 16 of the Gas (Interim) (Regulation) Act 2002.
CNG suppliers for vehicular transport can apply for certain derogations from the licence. As
part of the licence application, the applicant will be required to submit a safety case.
The CER Energy Safety Division will assess these safety cases against the requirements of
Safety Case Guidelines and, following issuance of a licence, the CER will audit and inspect
undertakings against their safety cases. Furthermore, the CER will assess material changes
to the Transmission and Distribution System Operators’ safety cases to incorporate CNG
and, if these are accepted, will audit and inspect the undertakings against their safety cases.
To this end, the CER set about developing Safety Case Guidelines for these undertakings in
order to assist them in developing their safety cases. To improve understanding of what the
CER would require from undertakings who engage in CNG activities, the CER engaged with
the HSA and held a workshop with both the Danish regulator (Danish Working Environment
Authority) and the HSE (UK) before drawing up these proposed guidelines. The CER also
hosted a public industry workshop. The CER then prepared and published these revised
Safety Case Guidelines for public consultation in late 2016. The CER will consider all
responses received and publish a decision in 2017.
1.6 Conclusion
As outlined above, the CER Energy Safety Division continued to carry out its legislative
safety functions during 2016 with respect to the GSF. The GSF was reviewed to ensure it is
up to date and relevant by the incorporation of new technologies such as CNG. The CER
continued to carry out audits and inspections of licensed undertakings to ensure compliance
with the GSF. This included the first audits of licensed LPG undertakings following the
acceptance of their safety cases and the granting of their licences in December 2015. The
CER Energy Safety Division also commenced three enforcement actions during 2016.
Additionally, the CER continued to carry out compliance monitoring of the RGI scheme
following assessment of KPI reporting by the RGII and the annual audits and inspections
carried out by the CER. Work also continued to be carried out on investigations of alleged
illegal gas works and enforcement actions during the year.
The CER is satisfied that through ongoing monitoring the Gas Safety Regulatory Framework
performed well during 2016, and it is committed to keeping the GSF under review to ensure
that it continues to operate effectively and remains fit for purpose.
39
Part 2: Electrical Safety Supervision
2.1 Introduction
As part of its safety functions, the CER has a statutory obligation to regulate the activities of
electrical contractors with respect to safety. It fulfils this obligation through the designation of
an Electrical Safety Supervisory Body (ESSB) and through the publication of criteria setting
out the safety standards to be achieved and maintained by electrical contractors, together
with the regulatory system to be operated by the ESSB.
Following a competitive public procurement process carried out in 2015, from 1st January
2016 the Register of Electrical Contractors of Ireland Limited (RECI) commenced operating
as the single ESSB. RECI will operate under the Safe Electric brand for a seven-year period
until the end of 2022. Safe Electric’s functions are set out in the 1999 Act, as amended, the
Electrical Safety Supervisory Criteria document V 3.0 (CER/16/001),7 and the Terms and
Conditions of Appointment.
2.1.1 Registration of Electrical Contractors
Figure 16 Total number of Registered Electrical Contractors (RECs) (2009–2016)
All RECs are required to certify all Controlled Electrical Work completed by them in a
domestic or commercial environment. Each REC that is registered with Safe Electric is
required to demonstrate that they have, or that an employee who certifies the electrical work
has, obtained a recognised National Craft Certificate as an electrician or another suitable
electrical qualification and has insurance cover as specified by Safe Electric.
7 This is the current version of the Criteria Document, published on 22 April 2016.
1,500
2,000
2,500
3,000
3,500
4,000
4,500
5,000
5,500
Q1
-09
Q3
-09
Q1
-10
Q3
-10
Q1
-11
Q3
-11
Q1
-12
Q3
-12
Q1
-13
Q3
-13
Q1
-14
Q3
-14
Q1
-15
Q3
-15
Q1
-16
Q3
-16
No
of
REC
s
40
The total number of RECs on the Safe Electric register at the end of 2016 was 4,213, as
shown in the figure below. A complete list of RECs operating in Ireland is available through
the Safe Electric website www.safeelectric.ie.
2.2 Compliance Assurance
2.2.1 Audits and Inspections of Electrical Contractors
In accordance with the Criteria Document, Safe Electric is required to monitor, inspect and
audit the standard of electrical work completed by RECs with respect to safety. Safe Electric,
therefore, submits for approval an annual audit and inspection programme and reports
quarterly to the CER on the number of audits and inspections completed in the quarter. New
RECs need to undergo a minimum of one inspection in the first six months of registration
and an additional inspection within six months of the first inspection, while RECs already on
the register for twelve months or longer need to be inspected at a minimum once per annum.
In 2016, Safe Electric inspectors carried out a total of 4,345 inspections on RECs against
4,756 inspections planned for the year, as shown in Figure 17. This is an increase of 12%
when compared to inspections completed in 2015. RECs that have not been inspected
during 2016 will be prioritised in the 2017 inspection plan of Safe Electric.
Figure 17 Total inspections planned vs total inspections completed on RECs per quarter (2014–2016)
2.2.2 Audits and Inspections of Safe Electric
During 2016, the CER conducted an audit of Safe Electric to provide assurance that Safe
Electric is performing its core functions in compliance with the Criteria Document and the
Terms and Conditions of Appointment. The audit identified a number of non-conformances
and opportunities for improvement. The CER required that Safe Electric submit an action
plan and will hold quarterly meetings during 2017 to ensure that actions are taken to address
all issues raised during the audit, by the end of 2017.
0
200
400
600
800
1000
1200
1400
1600
14 Q1 14 Q2 14 Q3 14 Q4 15 Q1 15 Q2 15 Q3 15 Q4 16 Q1 16 Q2 16 Q3 16 Q4
Total Inspections Planned vs Total Inspections Completed
Total Inspections Planned Total Inspections Completed
41
The CER’s Electrical Technical Specialist also monitors and inspects Safe Electric and its
inspectors to verify their safety performance through an approved audit and inspection
programme.
2.2.3 Performance Reports Received from Safe Electric
The CER requires assurance that Safe Electric is fulfilling its obligations as detailed in the
Criteria Document and the Terms and Conditions of Appointment. It has therefore developed
a ‘Performance Management Framework’8 under which Safe Electric reports against a series
of KPIs and supporting metrics quarterly. The CER has monitored compliance with the
requirements of the scheme and is satisfied with Safe Electric’s performance. In order to
further improve monitoring and ensure that Safe Electric is performing its core functions,
these KPIs will be reviewed, and a new performance-marking scheme will be developed by
the CER during 2017.
2.3 Enforcement
Since October 2013, by law, only RECs can carry out restricted electrical works.9 It is a
criminal offence for an individual or company to describe themselves as an REC or to act in
a manner likely to suggest that they are an REC without being registered. This could result in
(a) on summary conviction, a fine not exceeding €5,000 or a term of imprisonment not
exceeding 6 months or both, or (b) on conviction on indictment, a fine not exceeding €15,000
or a term of imprisonment not exceeding three years or both.
The CER undertakes investigations into all reports received regarding alleged illegal
electrical works. During 2016, the CER commenced 68 investigations and one successful
prosecution was undertaken. The status of the remaining reports includes: still under
investigation; prosecution not recommended due to lack of evidence that an offence had
taken place; and the alleged offence took place outside of the jurisdiction of the Republic of
Ireland. The CER will continue to carry out investigations and take enforcement actions
including prosecutions, cease and desist warning letters, and interviews of suspected illegal
electrical contractors during 2017, as necessary.
2.4 Stakeholder Engagement
The CER has a schedule of regular meetings with groups relevant to the electrical safety
scheme including Safe Electric, the Department of Communications, Climate Action and
Environment (DCCAE), the Electricity Modifications Committee, the National Standards
Authority of Ireland (NSAI) and relevant standards committees.
8 CER/08/108 ‘Economic Regulation of the Gas Safety Supervisory Body and any Electrical Safety Supervisory Bodies to be designated by the CER’. 9 (CER/13/147) Decision on the Scope of Restricted Electrical Works.
42
2.5 Electrical Safety Promotion and Public Awareness
2.5.1 Building Public Awareness of the Electrical Safety
Supervision Regulatory Scheme
In 2010, the CER launched a Safe Electric Promotion and Public Awareness campaign
across a range of media including TV, radio, press and digital. The campaign runs annually
since then and aims at raising public awareness of the Safe Electric scheme. It highlights the
need to hire an REC to carry out restricted electrical works in a domestic setting and to ask
for a certificate when the work is complete. It also emphasises that it is illegal for an
unregistered individual to carry out this type of work. In order to assess the campaign’s
effectiveness in terms of raising awareness of the Safe Electric scheme, pre- and post-
campaign research is carried out each year.
2.5.2 Review of Electrical Safety Promotional Material
While these media have been effective in increasing the profile of Safe Electric and the need
to use an REC, they have reached the end of their lifespan and there have not been any
improvements in awareness in 2016 as compared to 2015. In addition, given the switch from
two ESSBs to one in 2016, it is timely that there is an increase in the focus on the Safe
Electric brand. The CER is therefore planning to review the promotional material and
develop new media in 2017.
2.5.3 Redevelopment of Safe Electric Website
2017 will also see the redevelopment of the Safe
Electric website. Customers use the Safe Electric
website to locate RECs in their area to carry out
required electrical works and RECs use it to access
technical bulletins and other documentation related to
the Safe Electric scheme.
As RECI is now operating under the Safe Electric
brand, the new Safe Electric website will replace both
the existing Safe Electric and RECI websites, and it will
be a key form of communication with both the public
and the electrical contracting industry regarding electrical safety. To find an REC visit
www.safeelectric.ie.
2.6 Conclusion
The CER is satisfied that the Safe Electric scheme performed well during 2016 following the
transition to a single ESSB, and is committed to monitoring the scheme on an ongoing basis
to ensure that it continues to operate effectively. Compliance monitoring was carried out
successfully through Safe Electric’s reporting on KPIs and annual audits and inspections
carried out by the CER, ensuring that follow-up actions are undertaken by Safe Electric
Figure 18 Safe Electric logo
43
when non-compliances are identified. The CER also carried out investigations on reports
received regarding alleged illegal electrical works and worked towards increasing public
awareness of the Safe Electric scheme to improve safety within the home.
The CER is committed to ensuring that the next stage of the scheme benefits the public and
improves safety in the home, and it will work closely with Safe Electric and all the industry
stakeholders to ensure that this is the case.
44
Part 3: Petroleum Safety Framework
3.1 Introduction
The PSF covers upstream, designated petroleum activities, i.e. those onshore and offshore
activities involved in the exploration for or extraction of oil and gas and the subsequent
processing. The diagram below illustrates the PSF through its legislative and regulatory
documentation, which was updated in 2016.
Figure 19 Overview diagram of Petroleum Safety Framework
Table 5 below sets out the key roles of the CER with respect to petroleum safety. These roles
reflect our legislative functions set out in the Act.
The remainder of this section illustrates the CER work undertook in 2016 to deliver on these
roles, including the carrying out of safety case assessments and audits and inspections, and
the analysis of petroleum incidents and safety performance data.
45
Key Roles of the Petroleum Safety Framework
1. Foster and encourage safety in petroleum exploration and extraction activities;
2. Actively monitor and enforce compliance by petroleum undertakings with their obligations;
3. Promote a regulatory framework that encourages continuous improvement of safety;
4. Work with other authorities to achieve our vision; and
5. Provide safety information to the public.
Table 5 Key roles of the Petroleum Safety Framework
3.2 Compliance Assurance
3.2.1 Safety Case Assessments
The CER continued assessment of production safety permit applications for the Kinsale gas
fields10 and issued safety permits on the 14th January 2016.
In May 2016, the Kinsale gas fields’ safety permit holders submitted an application to the
CER to materially change the previously approved safety case. This material change was
connected to an enforcement action taken by CER in 2015 (see Section 3.5) and set out the
upgrade work required on their temporary refuge. The CER carried out an assessment of the
material change application and on 16th December 2016 issued updated safety permits to
take account of the revised safety case.
Safety permit
type
Application
date
Petroleum undertaking(s) Safety Permit reference and date issued
Production November
2014
PSE Kinsale Energy/PSE Seven
Heads
SP08 & SP09 issued 14th Jan 2016
Material
Change
May 2016 PSE Kinsale Energy/PSE Seven
Heads
SP08A & SP09A issued 16th Dec 2016
Table 6 Safety permits issued by the CER in 2016
10 ‘Kinsale gas fields’ refers to the PSE Kinsale Energy Limited Kinsale/Ballycotton/Southwest Kinsale gas field and the PSE Seven Heads, Island (Seven Heads) Limited and Sunningdale Oils (Ireland) Limited in relation to Seven Heads Gas Field.
46
Table 7 Acknowledgements of Compliance issued by the CER in 2016
The CER also took receipt of two safety cases as part of the Acknowledgement of
Compliance (AoC) application process for the Ocean Valiant and the Ocean Guardian
drilling units in May 2016. An AoC is a form of pre-acceptance of a drilling unit’s safety case
prior to the application for an associated safety permit. Introduction of this process was in
2016 as part of the Framework update (see Section 3.7). Assessments on these safety
cases were carried out and, on the 9th November 2016,
CER issued AoCs for the Ocean Valiant and the Ocean Guardian. These AoCs are valid for
five years from the date of submission to the CER.
Details of the Safety Permits and Acknowledgements of Compliance issued by the CER in
2016 are provided in Tables 6 and 7 below.
Picture: Ocean Valiant
Safety permit
type
Application date Drilling unit name AoC reference and date issued
AoC May 2016 Ocean Valiant AoC-02 issued 9th Nov 2016
AoC May 2016 Ocean Guardian AoC-03 issued 9th Nov 2016
47
3.2.2 Audits and Inspections
The CER carries out regular audits and inspections of permitted petroleum activities to
ensure compliance with the safety permit and the approved safety case. Table 8 sets out the
audits and inspections carried out by the CER under safety permits in 2016.
Safety permit Activity Location No. of inspections
SP 01B – Corrib Gas Field Production Bellanaboy Bridge
Terminal
2 carried out
SP 08/09 – Kinsale/Seven Heads Production Kinsale 4 carried out –
2 offshore
2 onshore
Table 8 CER inspections 2016
A number of factors, including, determines the scope of inspections: items identified during
the assessment of the associated safety permit applications; previous inspection findings;
enforcement actions; incidents; and safety performance reports. Where the CER identified
findings as part of the audit and inspection, i.e. potential non-compliances with an approved
safety case or safety permit, the petroleum undertakings were notified of these findings via a
CER Report of Audit and Inspection (ROAI).
ROAIs are not enforcement actions as prescribed by the Act, but are used by the CER to
monitor the compliance of petroleum undertakings with their requirements under the
Framework. Findings are issued in an ROAI when it is deemed by the CER that the taking of
an enforcement action is not proportionate to the finding identified. Where findings of audits
and inspections are assessed and deemed to be at a level proportionate to requiring a
formal enforcement action, the CER can employ its enforcement options in place of, or in
addition to, setting out the findings in an ROAI.
ROAIs were issued to the petroleum undertakings for each of the inspections listed in Table
8. Petroleum undertakings are required to submit a plan to the CER for addressing the
findings set out in the ROAIs within one month of receipt of the ROAI. In all cases in 2016,
the petroleum undertakings responded to the ROAI with a plan to address the findings within
the required timeline. The CER tracks findings of the inspections as part of its ongoing
monitoring function. This tracking ensures all actions and findings are closed out to the
satisfaction of the CER.
3.3 Incidents
Operators and owners are required to notify the CER of petroleum incidents under
Petroleum Safety (Petroleum Incident) Regulations 2016 (S.I. No. 166 of 2016), which came
into force on 29th February 2016. Incidents reported in 2016 prior to 29th February were
required to be reported by the petroleum undertaking under the previous regulations (S.I.
No. 4 of 2014).
48
Incident type 2016 to Feb 28th
E Failure or malfunction of plant and equipment used as part of or in a manner closely associated with petroleum infrastructure
3
F7 Instance of a stand-by vessel not being in a position to provide rescue to persons on offshore petroleum infrastructure
1
F9 Mustering on onshore or offshore petroleum infrastructure, other than for planned drills
3
Total incidents 7
Table 9 Petroleum incidents reported to the CER in 2016 under S.I. 4/2014
Guidance on reporting under the 2016 regulations is provided in the CER Guidance for
Notification of Incidents (CER/16/037).
The tables below detail all incidents reported by safety permit holders in 2016 across both
sets of regulations. There cover incidents associated with the Corrib gas and Kinsale gas
production activities.
Incident type 2016 from Feb 29th
A Unintended release of oil, gas or other hazardous substances, whether or not ignited
4
B Loss of well control requiring actuation of well control equipment, or failure of a well barrier requiring its replacement or repair
1
C Failure of a safety and environmentally critical element (SECE)
2
H Any serious injury 2
I Any evacuation of personnel 1
N Mustering on onshore or offshore petroleum infrastructure, other than for planned drill
5
P The collapse, overturning, or failure of any load-bearing part of any lift, hoist, crane, or derrick
1
Total incidents 16
Table 10 Petroleum incidents reported to the CER in 2016 under S.I. 166/2016
Each petroleum incident notification received was reviewed by the CER and a determination
was made as to the extent of the investigation required on a case-by-case basis. Where it
was deemed appropriate, further information on the petroleum incident was requested by the
CER from the petroleum undertaking. As with the review and recording of the safety
performance reports (see Section 3.4 of this report), the CER reviews petroleum incidents
notified as part of its overall regulation of petroleum activity. This means that while an
individual petroleum incident may be closed out to the satisfaction of the CER at the time of
49
the incident, the CER retains and exercises its right to follow up on the topic during future
audits and inspections.
The four Type A incidents (unintended releases) relate to small volumes of fluid weeping
from various valves (i.e. PSVs, gasket, compressor valves, etc.). The volume of escaped
liquid for all occurrences was between 1 and 35 litres. Operators addressed and cleaned up
the incidents and no further action was required from the CER.
The Type B incident (loss of well control) occurred during routine testing on a downhole
safety valve when it was not possible to achieve a successful function test or leak test. The
well downhole safety valve was stuck in the open position; however, the hydraulic (fail-safe)
functionality was unaffected. The wing valve and master valve had both been function tested
and were operating satisfactorily. An Operational Risk Assessment was put in place and the
operator assured well integrity to the CER. No further action was required from the CER.
With regard to the Type C incidents (failure of an SECE), one occurred during fugitive
emission testing, which found that a valve had been weeping. The system was isolated and
tagged out in accordance with procedures. The valve was replaced. The second incident
occurred during a planned emergency shutdown test where a valve failed to open, due to a
faulty actuator, later repaired. The CER required no further action.
With regard to the two Type H incidents (serious injury), in one case, the injured person was
able to return to work the following day with restricted duties, and in the other, the injured
person was put on light duties. There was no action required by the CER.
The Type I incident (evacuation of personnel) was also reported as a Type H incident,
where, following Emergency First Responder treatment, an employee was sent to hospital
for investigation of a damaged foot from a trip on the site. On receipt and review of the
information from the petroleum undertaking. The CER required no further action.
The five Type N incidents (mustering) break down as follows:
1. While operating a compressor discharge valve, a gas release from the body bleed was detected by gas detectors resulting in a mode one shutdown and muster. The valve was closed immediately and the control room was informed as to the source of the leak. This was then rectified. No action was required by the CER
2. Due to confirmed gas indication caused by fire and gas testing, a full plant muster
occurred. This also initiated a full power outage of plant and caused the wells to shut-in and the landfall valve installation to trip due to high inlet pressure. A Site Wide Alarm Auto Reset and stand down was completed. No action was required by the CER
3. A technician investigating a fault with a smoke detector inadvertently activated the
alarm trigging a muster. No action was required by the CER
4. Following power loss due to power systems trip by ESB, the on-site generator failed to pick up extra load causing plant equipment to load shed. This in turn shut down the compressor and auxiliary equipment. A partial blowdown of the plant was
50
initiated. Site Wide Alarm was not initiated. Admin Alarm Initiated due to power loss. No action was required by the CER
5. A false activation of a smoke head in the control room was caused by a trip that was found to be loose. The CER required no action.
With regard to the Type P incident (failure of any load-bearing part), this occurred during re-
instalment of a port protection cover (protection covers are used to protect pipelines and
other subsea structures from impact of dropped objects or trawls). During the task, an issue
occurred that resulted in the lift wires parting; this in itself was the reportable incident.
Reasons for the incident included poor communication between workers and lack of
familiarisation with equipment. Following receipt of further information it was deemed that the
operator had addressed the matter sufficiently and no further action by the CER was
required.
3.4 Key Performance Indicators (KPIs)
3.4.1 Performance Reports Received from Operators/Owners
Figure 20 Leading production safety performance indicators
L1
L2
L4
L5L6
0
20
40
60
80
100
120
Q1 2016 Q2 2016 Q3 2016 Q4 2016
Nu
mb
er o
f in
dic
ato
rs
QuarterL1 - Number of anomalies raised by ICB(s) in the quarter
L2 - Number of verification anomalies that were not closed-out by the planned due date at the end of the quarter
L4 -Number of S(E)CEs with overdue preventative maintenance at the end of the quarter.
L5 - Number of S(E)CEs maintenance hours required to clear any backlog in safety performance indicator L4.
L6 - Number of live operational risk assessments at the end of the quarter.
51
Operators and owners holding a safety permit are required to report on safety performance
to the CER on a regular basis. The full list of safety performance indicators is set out in the
CER Compliance Assurance System document11 and the indicators include both leading and
lagging indicators with the lagging indicators linked to the reportable petroleum incident.
The following figures set out all leading safety performance indicators reported to the CER in
2016 relating to the Corrib gas and Kinsale gas production activities. The CER assessed
each report as part of ongoing trend analysis throughout the year.
Figure 21 Lagging production safety performance indicators
11 Compliance Assurance System (CER/16/016).
A4
B3
C1
C2
C3
H1
H3
IL
N
P
0
2
4
6
8
10
12
14
16
Q1 2016 Q2 2016 Q3 2016 Q4 2016
No
.
QuarterA4 - Number of unintentional releases or escapes of any non-petroleum hazardous substance
B3 - Number of instances of a mechanical failure of any part of a well
C1- Number of instances of an S(E)CE not meeting its performance standard, requiring Immediate Remedial Action
C2 - Number of instances of an S(E)CE not meeting its performance standard, not reportable under C1
C3 - Number of activations of an S(E)CE except where testing and/or maintenance is being carried out.
H1 - Number of serious injuries to workers resulting from a designated petroleum activity;
H3 - Number of injuries to workers where: the person could not perform all of their normal work activities for more than 3consective days or treatment at hospital
52
Analysis
Operators are subject to ongoing regulation by the CER through its suite of compliance
assurance activities. The CER analyses all KPI information received and where required will
request clarification from the petroleum undertaking.
Following assessment of the 2016 reports, an increase in maintenance hours required for
SECE backlogs to be cleared was noted by CER. Following investigation, the apparent
increase in time spent maintaining SECEs was found to be the result of the operator working
to a different definition of ‘backlog’ in previous years than that used by the CER. Once this
was corrected by the operator the number of hours subsequently appeared to have risen
significantly. On receipt of this information, the CER required no further action.
The CER continues to review the individual reports as well as the trends arising from the
submitted safety performance indicators. Based on the data received to date, subsequent
CER analysis, and follow up with operators, no potential for an emerging safety concern has
been noted by the operators or the CER.
3.5 Enforcement
The CER issued an Improvement Plan enforcement action in 2015 on the Kinsale gas
production activity following identification of a non-compliance.12 The non-compliance was
identified as part of CER’s ongoin assurance activities and related to the requirement to
provide a safe refuge.
The operator was non-compliant in this respect and CER directed the petroleum
undertakings to submit an Improvement Plan specifying the actions proposed to return the
activity to a state of compliance, i.e. provision of an adequate safe place of refuge. The
petroleum undertakings submitted the Improvement Plan and on review, the CER was
satisfied that the Improvement Plan submitted was adequate to proceed. Throughout 2016,
progress against the Improvement Plan was monitored and this carried forward into 2017.
Progress will be monitored until all the actions within the plan are closed out.
In 2016, the CER issued a ‘Notice of Intent to Serve an Improvement Notice’ on the Kinsale
gas production activity. This was following identification of a non-compliance relating to the
implementation and carrying out of an Operational Risk Assessment process. The Notice
allowed the safety permit holders 21 days to make representations to the CER, which they
did. The CER considered these representations and, following assessment, deemed it no
longer necessary from a safety point of view to proceed with the issuance of the
Improvement Notice. In effect, the operator had addressed the matter to a satisfactory level
by the time the 21 days had elapsed, resulting in a positive safety outcome.
12 As the non-compliance was associated with production being carried out under two safety permits, one by PSE
Kinsale Energy Limited and one by PSE Seven Heads Limited and partners, two Directions to Submit an Improvement Plan were required to be issued.
53
The CER was satisfied with the interaction and responsiveness of the operator throughout
the process of dealing with these enforcement matters.
3.6 Stakeholder Engagement
During 2016, the CER continued its active participation with European safety regulators
through the North Seas Offshore Authorities Forum (NSOAF). CER Petroleum Safety team
representatives participated in the NSOAF Plenary, the NSOAF EU Network, the Wells
Working Group and the Health, Safety and Environment Working Group.
In additional to the NSOAF, the CER actively engaged with the European Union Offshore
Authorities Group (EUOAG). The EUOAG was set up in 2013 under Directive 2013/30/EU
and its objectives include the sharing, prioritisation and supervision of the development of
guidelines on best practices and the rapid exchange of information on incidents. During
2016, the focus of EUOAG meetings was on Accident Reporting Software tools and
Emergency Response Preparedness.
Interactions with groups such as the NSOAF and EUOAG ensure CER can regularly share
knowledge on the sector with our European counterparts to maintain high standards of
safety regulation across the EU.
Following the commencement of operations of the Framework in 2013, the CER continued to
have regular communication with industry through the Irish Offshore Operators Association
(IOOA). These discussions and meetings facilitated information sharing on safety regulatory
aspects of the industry in Ireland and in the early part of 2016 also facilitated the close out of
consultations on the implementation of Directive 2013/30/EU.
The effectiveness and successful operation of the PSF by the CER regulatory team were
recognised through a request to lead the delivery of training to other Member States via an
initiative of the EUOAG. On request from the European Joint Research Centre via the
EUOAG, Petroleum Safety team members assisted another European Member State in the
development of their regulatory framework throughout 2016. This was through knowledge
sharing of the CER Framework development and operation and included the sharing of
guidance and procedural documentation as well as in-house training for staff.
3.7 Continuous Improvement
On the 28th June 2013, the European Commission published the Directive on the Safety of
Offshore Oil and Gas Operations (Directive 2013/30/EU). The Directive was transposed into
Irish legislation in July 2015, with the enactment of the Petroleum Safety Act 2015 (the 2015
Act). Among other things, the 2015 Act identifies the CER as the ‘competent authority’ for
offshore safety and extends the scope of the Framework to cover the risk and potential
consequences of major accidents, including major environmental incidents. Certain
responsibilities for the safety of petroleum activities being carried on offshore are also
transferred from petroleum undertakings to operators and owners of non-production
installations.
54
Following the enactment of the 2015 Act, the CER revised the majority of published
documents under the Framework to reflect the new legislation. The full update process was
completed in 2016. The updated documents include the following, available on the CER’s
website:
1. Requirements of the Petroleum Safety Framework (CER/16/023).
2. Safety Case Requirements (CER/16/024).
3. Compliance Assurance System (CER/16/016).
4. CER Audit and Inspection System (CER/16/015).
5. Guidance for Notification of Incidents (CER/16/037).
6. Petroleum Safety (Petroleum Incident) Regulations 2016 (S.I. No. 166/2016).
More information on the main updates to the Framework is provided below.
3.7.1 Introduction of Operators and Owners
Under the 2010 Act, all responsibilities were placed on a petroleum undertaking. The 2015
Act introduced the concepts of operators and owners, as is common internationally, and
transferred certain obligations from the petroleum undertaking to them. While this does not
change the requirements of a safety case, it changes the entity that has primary
responsibility for safety.
A petroleum undertaking must appoint an operator to carry on a designated petroleum
activity. The appointed operator now has primary responsibility for the control of risks of a
major accident resulting from the carrying on of designated petroleum activities. An owner
controls the operation of a non-production installation, i.e. the mobile drilling unit that is used
for offshore well work and exploration.
3.7.2 Introduction of Acknowledgement of Compliance Process
With the update to the Framework, the CER also introduced a new Acknowledgment of
Compliance (AoC) process. Unlike the other updates, this was not a regulatory requirement
of the 2015 Act but rather a process introduced by the CER to streamline the well work
safety permit application assessment process. The new process allows owners to submit a
non-production safety case to the CER for assessment prior to the submission of a safety
permit application and the safety case will undergo the same assessment process as it
would at the time of a safety permit application.
Where granted, this means that an AoC is confirmation for the owner that, at the time of the
related non-production safety case assessment the information submitted satisfied the
requirements of the CER Safety Case Guidelines. The aim of this process is a more efficient
55
safety case assessment process for the owner during a safety permit application
assessment.
An AoC does not allow the carrying on of a designated petroleum activity and does not
constitute a formal acceptance of a safety case. The formal acceptance is given only upon
assessment of a safety permit application.
3.7.3 Update to the Definition of Major Accident Hazard
The definition of a major accident hazard (MAH) is now included in the 2015 Act and thereby
replaces the previous definition in the CER High Level Design of the PSF paper. An MAH is
defined in the 2015 Act as:
(a) An event involving an explosion, fire, loss of well control, or release of oil, gas or
dangerous substances involving, or with a significant potential to cause, fatalities or
serious personal injury
(b) An event leading to serious damage of petroleum infrastructure involving, or with a
significant potential to cause, fatalities or serious personal injury
(c) Any other event leading to fatalities or serious injury to multiple persons
(d) Any major environmental incident resulting from incidents referred to in paragraphs
(a), (b) and (c) and which relate to petroleum activities carried out offshore.
3.7.4 Update to Definition of Petroleum Incident
As noted previously, on 29th February 2016, the Petroleum Safety (Petroleum Incident)
Regulations 2016 came into force. These updated incident regulations were put in place to
reflect the mandatory Commission Implementing Regulation (EU) 1112/2014. That EU
regulation sets out a common format for the reporting of incidents/data by operators and
owners to Member States (in this case CER), who must then report these incidents on to the
EU Commission. This common format provides for union-wide comparable public
information intended to facilitate the dissemination of lessons learnt from major accidents
and near misses.
The deadline for the first submission to the EU Commission under the European regulations
is the 1st June 2017 and this will cover incidents that occurred in 2016. A summary of this
report will be available on the CER website on that date. More detail on the implementation
of this reporting format will be provided in the Energy Safety Annual Report for 2017.
3.8 Conclusion
2016 marked the third full year of operations for the Petroleum Safety Framework, with a
significant workload to be delivered. Ongoing audit and inspection of the Corrib and Kinsale
gas fields' production activity was carried out. In addition, the PSF team completed the
56
assessment of the material changes to the safety cases for the Kinsale fields’ production
activity and also carried out an inspection of one drilling vessel and issued the first
Acknowledgements of Compliance to two drilling vessels.
Away from the operational work, 2016 also marked the implementation of the 2015 Act,
closing out a significant body of work that was undertaken throughout 2015 to update the
majority of documents across the Framework. Through its ongoing continuous improvement
process, the CER also took this opportunity to improve the Framework in a number of ways,
both internally and externally, based on the operational learnings since November 2013.
Such improvements have created greater efficiencies across the Framework. They were
achievable, in part, through effective engagement with our colleagues both in Ireland and in
other European Member States.
Following this successful implementation of the Directive, CER was requested to assist
another Member State in the set up and implementation of their Directive-compliant
regulatory team. Such a request for support positively illustrates the transparent and
effective way in which CER has carried out its role and implemented its legislation.
57
Acronyms
AGI Above Ground Installation ALARP As Low As Reasonably Practicable
AoC Acknowledgment of Compliance
CER Commission for Energy Regulation
CO Carbon Monoxide
DCCAE Department of Communications, Climate Action and Environment
DSO Distribution System Operator
ESSB Electrical Safety Supervisory Body
GNI GNI
GSSB Gas Safety Supervisory Body
HAZID Hazard Identification
HAZOP Hazard and Operability Studies
HSA Health and Safety Authority
HSE Health and Safety Executive (UK)
ICB Independent Competent Body
IRB Independent Review Body
KPI Key Performance Indicator
LPG Liquefied Petroleum Gas
MoU Memorandum of Understanding
NGEP Natural Gas Emergency Plan
NoHZ Notice of Hazard
NSAI National Standards Authority of Ireland
OFTEC Voluntary Association of Oil Fired Technicians
PAPA Promotion and Public Awareness
PRE Public Reported (Gas) Escape
QRA Quantitative Risk Analysis
REC Registered Electrical Contractor
RECI Registered Electrical Contractors of Ireland Limited
RGI Registered Gas Installer
58
RGII Registered Gas Installers of Ireland Limited
RuG Reportable under Guidelines
SCADA Supervisory Control and Data Acquisition
SECE Safety and Environmentally Critical Element
SP Safety Permit
TSO Transmission System Operator
UKOPA UK Onshore Pipeline Operators Association
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