Oil and gas: environmental alerts and incident reporting including anonymous reporting

## Environmental Alert Notices The Department for Business, Energy and Industrial Strategy OPRED regularly issues environmental alert notices in order to raise awareness of any environmental issues on the United Kingdom Continental Shelf (UKCS) so companies can respond appropriately. They are issued directly to Oil and Gas operators and published online. [View the latest Environmental Alert Notices](https://www.gov.uk/guidance/oil-and-gas-environmental-alert-notices). ## Reporting incidents to OPRED ### Integrated Reporting Service (IRS) IRS is a service hosted within the United Kingdom Energy Portal. IRS is used to report the following to the Department; * PON1 - Releases to sea of oil or offshore chemicals * PON2 - Loss of deposition of materials to sea * PON10 - Non-compliance with Part 4A of the Energy Act/Consent to Locate (including Standard Marking Schedule) * OPPC NCN - Non-compliance with the OPPC Regulations / an OPPC Permit * OCR NCN - Non-compliance with the OCR Regulations / an OCR Permit * PPC NCN - Non-compliance with the PPC Regulations / a PPC Permit * F-Gas/ODS NCN - Non-compliance with the F-Gas / ODS Regulations * General Regulatory NCN - Any breach / non-compliance with Regulations not listed above, for example a breach associated with the conditions of a Geological Survey or Marine Licence. You may find it useful to consult OPREDs offshore environmental legislation page for information on environmental regulations and guidance on offshore oil and gas exploration and production, offshore gas unloading and storage and offshore carbon dioxide storage activities. #### Guidance * [Integrated Reporting Service (IRS) Guidance](https://assets.publishing.service.gov.uk/media/66d953f5fb86ba5a1f214e23/IRS_Guidance_September_2024.pdf) (PDF, 503 KB, 62 pages) To access the IRS users must first register for an Energy Portal Login Account <https://itportal.energysecurity.gov.uk/eng/fox/beis/DESNZ_LOGIN/login/>. Thereafter to access the IRS users must be given the appropriate permissions by their organisations IRS administrator. Access to IRS is through the same link <https://itportal.energysecurity.gov.uk/eng/fox/beis/DESNZ_LOGIN/login/>. IRS has been designed to allow any installation operating in the UKCS, be that a fixed installation, mobile drilling unit, diving support vessel, flotel etc which may require to make a notification through IRS. If you require an IRS installation account to be set up contact OPRED@energysecurity.gov.uk In the event there are any issues relating to the functionality of IRS contact ukop@nstauthority.co.uk or 0300 067 1682. If IRS is unavailable incidents should be notified using the following pro-formas: * [PON1 – pro-forma for reporting oil and chemical releases-discharges from offshore installations and pipelines](https://assets.publishing.service.gov.uk/media/66029212f1d3a06c5532ade6/PON1_Email_Template_-_Rev_2_-_March_2024.docx) (MS Word Document, 106 KB) * [PON1 Guidance for Reporting Oil and Offshore Chemical Releases](https://assets.publishing.service.gov.uk/media/69ba6bc0a564b64fbe35abb8/PON1_Guidance_for_Reporting_Oil_and_Offshore_Chemical_Releases_March_2026.pdf) (PDF, 324 KB, 28 pages) * [PON1 Guidance - Consultation Supporting Document - Summary of Key Contents and Changes](https://assets.publishing.service.gov.uk/media/6149e799d3bf7f05afde050b/PON1_Guidance__Notes_-_Rev_0_-_Key_Changes.pdf) (PDF, 167 KB, 6 pages) * [PON2 Reporting Form](https://assets.publishing.service.gov.uk/media/66019b8aa6c0f7bb15ef9261/PON2_reporting_form_March_2024.docx) (MS Word Document, 51.2 KB) * [PON10 Reporting Form](https://assets.publishing.service.gov.uk/media/66019be6f1d3a06c5532ada4/PON10_reporting_form_-_March_2024.docx) (MS Word Document, 53.8 KB) * [OCR non-compliance notification form](https://assets.publishing.service.gov.uk/media/66019c22a6c0f7580fef9179/OCR_Non-compliance_Form.docx) (MS Word Document, 79.2 KB) for reporting any chemical use or discharge made without a permit being granted, or any identified non-compliance against the terms and conditions included in a previously granted chemical permit as per the Offshore Chemicals Regulations 2002 as amended * [OCR non-compliance notification form – guidance notes](https://assets.publishing.service.gov.uk/media/66019c6f65ca2fa78e7da7df/Guidance_on_the_OCR_Non-Compliance_Notification_Form.doc) (MS Word Document, 108 KB) * [OPPC non-compliance notification form](https://assets.publishing.service.gov.uk/media/66019c9965ca2fa78e7da7e5/OPPC_Non-compliance_Form.docx) (MS Word Document, 81.2 KB) * [OPPC non-compliance notification form – guidance notes](https://assets.publishing.service.gov.uk/media/5a7485cc40f0b616bcb17291/oppc-noncomp-guide__2_.doc) (MS Word Document, 44.5 KB) * [PPC non-compliance notification form](https://assets.publishing.service.gov.uk/media/66019cc5f1d3a06c5532adb0/PPC_Non-compliance_Form.docx) (MS Word Document, 74.6 KB) * [F-Gas non-compliance notification form](https://assets.publishing.service.gov.uk/media/66965fcd49b9c0597fdafdb9/Reporting_form_for_F-Gases.docx) (MS Word Document, 32.4 KB) * [Incident Response Telephone Checklist](https://assets.publishing.service.gov.uk/media/5c93a1beed915d07a4a46556/Incident_Response_Checklist_Jan_2018.docx) (MS Word Document, 76.1 KB) ### IRS Data Details of incidents reported to OPRED can be found using this [link](https://itportal.energysecurity.gov.uk/irs/publications). ## PON 1 ### Reporting oil and chemical releases and permitted discharge notifications from offshore installations and pipelines A Petroleum Operations Notice 1 (PON1) is the notice used to report all releases to sea of oil and offshore chemicals that occur during offshore oil and gas activities. The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (OPPC) and the Offshore Chemical Regulations 2002 (OCR) include provisions which require the permit holder or, if there is no permit holder, the operator to provide details of the following: * Any Incident resulting in a release * Any other incident involving oil/offshore chemicals where there has been or may be any significant effect on the environment by means of pollution OPPC and OCR also require that a person who releases oil or offshore chemicals must provide the Secretary of State with such information as they may reasonably require for the purpose of performing their functions under the Regulations. In addition to the requirements of the Regulations, the terms and conditions attached to OPPC and OCR permits require that the permit holders must report all releases of oil and/or offshore chemicals to the Department by means of a PON1 notification. In compliance with international agreements, the Maritime and Coastguard Agency has issued instructions to captains of all service and civilian ships and aircraft to report immediately the following matters: * any shipping casualty likely to result in the release of oil or other harmful substances into the sea * any ship observed discharging oil or other harmful substances into the sea * any release of oil or other harmful substances sighted at sea * any incident noticed elsewhere Petroleum Operations Notice No.1 (PON 1) is the form operators and permit holders are directed to use to satisfy the above reporting obligations. ### PON 1 Data The following spreadsheet presents historical data about oil and chemical releases. Readers should be aware that HSE and OPRED publish Hydrocarbon Release data on their website in accordance with regulatory reporting requirements. HSE and OPRED have different regulatory responsibilities and this is reflected in the incident reports received. Most notably PON1 does not record gaseous releases. This data is available below. [Hydrocarbon Release data submitted to HSE](http://www.hse.gov.uk/offshore/hydrocarbon.htm) is primarily concerned with gaseous and flammable liquid releases capable of causing serious injury or fatality or a major accident. Where required to be reported it is the total quantity released that is reported regardless of whether the hydrocarbon enters the sea. As a result of the above reporting requirements there may be incidents that are reported independently to HSE or OPRED or on some occasions to both, depending on circumstances. Quantities reported may also vary as OPRED is only notified of quantities spilled to sea whereas HSE may be notified of incidents with the potential to cause pollution. Please direct any queries to: OPRED@energysecurity.gov.uk ## Submitting a PON1 The PON1 must be submitted via IRS in accordance with the IRS Guidance document. Where access to IRS is unavailable the PON1 reporting form, available above, must be submitted in accordance with the information detailed in the PON1 guidance document. ## PON 2 ### Loss or dumping of materials at sea from offshore oil and gas installations Materials lost or dumped at sea can constitute a significant hazard to other sea users and the marine environment. A PON2 must be submitted to report material lost or dumped to sea that has the potential to pose a threat to navigation or the safety of users of the sea. Note – this excludes material that is deposited in accordance with an approved Consent/Marine Licence etc. Offshore Wind Operations – To notify any objects dropped / lost to sea during offshore wind operations please contact Marine Scotland for Scottish waters and the Marine Management Organisation (MMO) for English inshore/offshore waters and Northern Ireland offshore waters. A PON2 should not be submitted to OPRED for such incidents. The following information is provided to assist with PON2 reporting: * material deposited under conditions of force majeure (i.e. material lost or dumped to sea in order to protect the safety of any person or the installation) must be reported. * synthetic materials, which are impervious to rot, can foul the propellers of vessels and present a hazard to divers and submersibles. They also constitute a significant hazard to marine life. * plastic sheeting, bags and containers can block the cooling water intakes of vessels of all sizes as well as presenting a significant hazard to marine life. * materials such as oil drums, lengths of wire and other heavy objects can represent a hazard to vessels and/or interfere with navigation. They can also snag and damage fishing nets, resulting in lost fishing time or in extreme cases, threaten the safety of the fishing vessel. * any maritime safety equipment (e.g. life rafts, life rings, life jackets etc) lost to sea must be reported to minimise the likelihood of unnecessary response mobilisation. * materials lost or dumped to sea may move considerable distances and may have significant impacts away from the initial deposit location. * caissons which drop from installations have the potential to impact oil and gas bearing subsea infrastructure. * any other object which if dropped has the potential to pose a threat to navigation or the safety of users of the sea. ### Submitting the PON 2 form The PON2 must be submitted via IRS in accordance with the IRS Guidance document. Where access to IRS is unavailable the PON2 reporting form, available below, must be submitted to OPRED, the Marine Coastguard Authority, Kingfisher at Seafish, the Scottish Fishermen’s Federation and/or the National Federation of Fishermen’s Organisations as soon as possible and no later than 6 hours after the event takes place. If all the information is not available within 6 hours, the PON 2 form can be updated at a later time. * [PON2 Reporting Form](https://assets.publishing.service.gov.uk/media/66019b8aa6c0f7bb15ef9261/PON2_reporting_form_March_2024.docx) (MS Word Document, 51.2 KB) ## PON10 A PON10 is used to report a non-compliance with the conditions of a Consent to Locate or any other breach of the applicable Energy Act Part 4A Regulations. You must submit a PON10: * immediately and within 1 hour if any part of the Works and associated infrastructure is wrecked or damaged or goes adrift * immediately and within 1 hour if all Aids to Navigation are non-operational * immediately and within 1 hour if the nominal range of either the main or secondary white lights is less than 10 nautical miles * within 24 hours if any element of the aids to navigation are operating on secondary power because of a primary power systems failure * within 24 hours of detection of any non-compliance relating to the consent conditions including the requirements set out in the Marking Schedule The PON10 must be submitted via IRS in accordance with the IRS Guidance document. Where access to IRS is unavailable the PON10 form, available below, must be sent to OPRED and the UK Hydrographic Office. Reports should also be copied to the Maritime and Coastguard Agency (MCA), Kingfisher at Seafish and the relevant General Lighthouse Authority and fishermen’s representative body. * [PON10 Reporting Form](https://assets.publishing.service.gov.uk/media/66019be6f1d3a06c5532ada4/PON10_reporting_form_-_March_2024.docx) (MS Word Document, 53.8 KB) ## Anonymously reporting environmental concerns relating to offshore oil and gas operations If you have a concern about an environmental pollution incident/breach of offshore regulations you can report it online to OPRED. This section of the GOV.UK website, provides a mechanism for those aware of an environmental offshore incident, such as the release or unpermitted discharge of oil or chemicals to sea, to report this information anonymously. You will not be required to provide any personal details should you wish to remain anonymous. However, in these circumstances the Department will be unable to update you with its response to the information you provided. Should you wish to receive an update, we require you to leave sufficient personal details and advise us of your preferred method of communication. Where you provide your personal details the Department will strive to protect your confidentiality, however it cannot guarantee your anonymity. ### Before you start There has to be a good reason for investigating environmental concerns relating to offshore oil and gas operations so you’ll need to provide as much of the following information as possible including: * the name of the installation involved * a detailed description of the incident * if the incident is new/or ongoing The information you provide is strictly confidential. You don’t have to give your name unless you want to. To submit a report please access the form here – [Anonymous Reporting form - on Portal](https://itportal.energysecurity.gov.uk/irs/anonymous-reporting/start) ### What happens after you have submitted a report OPRED Offshore Environmental Investigation Team will review the information you have reported. If you’ve given enough information they’ll investigate the incident. The Investigation Team may not always be able to tell you the outcome and sometimes no action is taken. OPRED Offshore Environmental Inspectorate will take action if they find there is evidence of an incident that results in pollution or a contravention of the regulations. The enforcement options available are detailed in the Department’s Enforcement policy which can be accessed here at Oil and Gas: OPRED Public Registers of Enforcement Activity - [OPRED Offshore Enforcement Policy](https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/857913/OPRED_ENFORCEMENT_POLICY_revised_-_03_Jan_2020.pdf) --- Petroleum Operations Notice 1 (PON1) Guidance for Reporting Oil and Offshore Chemical Releases March 2026 © Crown copyright 20[XX] This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk. Where we have identified any third-party copyright information you will need to obtain permission from the copyright holders concerned. Any enquiries regarding this publication should be sent to us at: opred@energysecurity.gov.uk Contents 1. Introduction _____________________________________________________________ 4 2. Legislative Background ____________________________________________________ 5 3. PON1 Reporting __________________________________________________________ 6 3.1 Application of the PON1 Regime __________________________________________ 6 3.2 Reporting Timeframes __________________________________________________ 6 3.3 PON1 Reporting Method ________________________________________________ 7 3.4 PON1 Reporting Responsibility ___________________________________________ 7 3.5 Required Information Regarding Owner/Operator/Permit Holder etc. _______________ 8 3.6 PON1 Reporting for Ongoing Releases _____________________________________ 8 3.7 Permitted Discharge Notifications __________________________________________ 9 3.8 Third-Party Oil Pollution identified During Offshore Oil and Gas Activities ___________ 9 4. PON1 Review, Pollution Response and Investigation ____________________________ 10 APPENDIX A: Reporting Flow Diagrams ________________________________________ 11 APPENDIX B: Definition of Release and Discharge ________________________________ 13 APPENDIX C: Definitions of Oil and Offshore Chemicals ___________________________ 14 APPENDIX D: Quantification of Release Quantities _______________________________ 15 APPENDIX E: Reporting Subsea Emissions of Offshore Chemicals ___________________ 16 APPENDIX F: Reporting Emissions from Drainage Systems _________________________ 18 APPENDIX G: Reporting Emissions from Produced Water Caissons __________________ 21 APPENDIX H: Reporting Emissions from NPIs and Vessels _________________________ 22 APPENDIX I: Reporting of Oil Releases during Flaring Operations ____________________ 24 APPENDIX J: Excessive Venting of Bulk Powders ________________________________ 25 APPENDIX K: Definitions ____________________________________________________ 26 3 1. Introduction This document is the Guidance on the provision of information in relation to releases to sea of oil or offshore chemicals during offshore oil and gas activities. This Guidance includes Directions under regulation 11A(2) of The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (OPPC) and regulation 15(1A) of The Offshore Chemicals Regulations 2002 (OCR) as to the form and manner of reports issued by the Secretary of State. Offshore oil and gas activities are those activities carried out at or from an offshore installation in relation to: • The exploration for or exploitation of mineral resources • Activities associated with gas storage, loading and unloading • Conveyancing by pipeline • The decommissioning of any offshore installation or pipeline • The provision of accommodation on an offshore installation related to the above activities An offshore installation is any structure maintained on station by any means for the purposes of oil and gas activities. This includes all fixed oil and gas production platforms, floating production or storage facilities, subsea oil and gas infrastructure (including all wells), oil and gas pipelines, Non-production Installations (NPI) and vessels (when undertaking oil and gas activity). Specific guidance on the application of this to NPIs and vessels is provided in Appendix H. This means all exploration, production and decommissioning activity involving any offshore installation in the relevant area is considered to be an offshore oil and gas activity. The requirements in this document are applicable to all offshore oil and gas activities conducted in the “relevant area” as defined in OPPC and OCR, which is the territorial sea adjacent to the UK (with the exception of Scottish and Welsh controlled waters) and any area designated under section 1(7) of the Continental Shelf Act 1964. This means: • For English and Northern Irish waters it applies from the Low Water Mark to the maximum extent of the UK Continental Shelf • For Scottish waters it applies from 3 nautical miles from the Low Water Mark to the maximum extent of the UK Continental Shelf • For Welsh waters it applies from 12 nautical miles from the Low Water Mark to the maximum extent of the UK Continental Shelf 4 This document supersedes the previous Petroleum Operations Notice 1 (PON1) Guidance which was issued by the Department of Energy & Climate Change and is effective from the date of publication. 2. Legislative Background This Guidance articulates the Secretary of State’s requirements for the provision of information in relation to all releases including Directions as to the form and manner in which this information is provided. A release is the emission to sea of oil or offshore chemicals (other than by way of a discharge). A discharge is the intentional emission to sea of oil or offshore chemicals. For more details see Appendix B. A PON1 is the method used to report all releases to sea of oil and offshore chemicals that occur during offshore oil and gas activities. Definitions of ‘oil’ and ‘offshore chemical’ are provided in Appendix C. OPPC and OCR require the Permit Holder or, if there is no Permit Holder, the operator to provide details of the following: • Any incident resulting in a discharge of oil/offshore chemicals save in accordance with the terms or conditions attached to a permit • Any incident resulting in the use of offshore chemicals save in accordance with the terms or conditions attached to a permit • Any incident resulting in a release • Any other incident involving oil/offshore chemicals where there has been or may be any significant effect on the environment by means of pollution OPPC and OCR also require that a person who releases or discharges oil or uses, discharges or releases an offshore chemical must provide the Secretary of State with such information as they may reasonably require for the purpose of performing their functions under the Regulations. In addition to the requirements of the Regulations, the terms and conditions attached to Chemical Permits or Oil Discharge Permits require that the Permit Holders must report all releases of oil and/or offshore chemicals to the Department by means of a PON1 notification. It is an offence to fail to supply information required to be supplied by OPPC and OCR and the terms and conditions attached to Chemical Permits or Oil Discharge Permits. The Department may investigate any instance of the failure to provide required information in line with OPRED’s Enforcement Policy. This may result in the imposition of a civil penalty or other enforcement action. Further details can be found within the OPRED Enforcement Policy. 5 A person guilty of an offence under the regulations shall, on summary conviction, be liable to a fine not exceeding the statutory maximum and, on conviction on indictment, to an unlimited fine. Requirements regarding the provision of information to the Secretary of State relating to non- compliant discharges of oil and/or the non-compliant use or discharge of offshore chemicals can be found at [LINK to IRS Guidance] 3. PON1 Reporting 3.1 Application of the PON1 Regime A PON1 must be submitted following any release to sea of oil or offshore chemical during offshore oil and gas activities, regardless of quantity. Flow diagrams depicting the reporting requirements for emissions of oil and offshore chemicals are included at Appendix A. All PON1 submissions must take account of any relevant Guidance provided in the Appendices A – J of this document. 3.2 Reporting Timeframes The timescale for the submission of a PON1 must be in accordance with the terms and conditions of the approved Chemical Permit or Oil Discharge Permit i.e. within six hours of becoming aware of the release. Where no permit is in force, the PON1 must be submitted without delay and the Department expects this will be within six hours. Initial submission of the PON1 must not be delayed beyond six hours to allow the gathering of further information. The PON1 can be updated at any time if additional information becomes available. All PON1 submissions must state the quantity of oil and/or offshore chemicals released. Appendix D must be used when determining the quantity of the release. The Department and HM Coastguard must also be notified by telephone without delay and within one hour of becoming aware of the release, where the release meets any of the following criteria: • exceeds 1 tonne • cumulatively exceeds 1 tonne (for ongoing releases) • is within 40 kilometres of the coast 6 • exceeds any specific telephone reporting threshold detailed within a relevant OPEP, Chemical Permit or Oil Discharge Permit • is ongoing (telephone notification to HM Coastguard only) Contact telephone numbers for OPRED and HM Coastguard are in the relevant Oil Pollution Emergency Plan (OPEP). The OPEP may also contain requirements to notify additional organisations about a PON1 reportable release. The OPEP details the circumstances in which such organisations must be notified of an oil release and the method by which the notification must be made. The same notification criteria must be applied in the event of a release of offshore chemicals. 3.3 PON1 Reporting Method PON1s must be submitted using the UK Energy Portal. It is the responsibility of all Installation Operators, Well Operators, Pipeline Operators, NPI Owners and Permit Holders who may be required to submit a PON1 to ensure they have appropriate access to the UK Energy Portal. UK Energy Portal accounts that enable the submission of PON1s can be requested by contacting ukop@ogauthority.co.uk Should the UK Energy Portal be unavailable PON1s must be submitted by email using the PON1 pro-forma [CREATE LINK]. The required distribution list is detailed on the PON1 pro- forma. Any PON1 reported by email in this manner must be subsequently reported via UK Energy Portal at the earliest opportunity. 3.4 PON1 Reporting Responsibility Production Installation/Pipeline Operations (including Combined Operations between a Production Installation and a Non-Production Installation) The Permit Holder is responsible for ensuring that the PON1 is submitted in accordance with the terms and conditions of the approved Chemical Permit or Oil Discharge Permit. If there is no Permit Holder the responsibility for ensuring the submission of the PON1 rests with the appointed Installation/Pipeline Operator. Well Operations undertaken from a Non-Production Installation (including Combined Operations between two NPIs) The Permit Holder is responsible for ensuring that the PON1 is submitted in accordance with the terms and conditions of the approved Chemical Permit or Oil Discharge Permit. If there is no Permit Holder the responsibility for ensuring the submission of the PON1 rests with the appointed Well Operator. 7 Vessel Operations (where the Vessel is an Offshore Installation as defined in Appendix H) The Permit Holder is responsible for ensuring that the PON1 is submitted in accordance with the terms and conditions of the approved Chemical Permit or Oil Discharge Permit. If there is no permit the Consent to Locate holder or the Responsible Person for the implementation of the approved OPEP must ensure the PON1 is submitted. Remote Suspended Wells The responsibility for PON1 submission rests with the Permit Holder. If there is no permit holder the appointed Well Operator has this responsibility. In the absence of a separately appointed Well Operator, this obligation rests with the Licensee. In all the above cases the submission of the PON1 may be made by any person on behalf of the company responsible for the PON1 submission. 3.5 Required Information Regarding Owner/Operator/Permit Holder etc. The PON1 must detail all companies involved in the oil and gas activities. Where applicable, details of the following must be provided: • Production Installation Operator: This is the company appointed or accepted to operate the production installation. • Well Operator: This is the company appointed or accepted to undertake the well operations and for the purposes of this Guidance includes the company responsible for the operation and maintenance of any well during production operations. • NPI Owner: The company who controls the operation of the non-production installation, also known as the NPI duty holder. • Permit Holder: The company holding the Chemical Permit and/or Oil Discharge Permit (where there is no Permit Holder, this section of the PON1 must detail the holder of the Consent to Locate if applicable). • Pipeline Operator: The company who controls the day to day operation of the pipeline. This is the company holding the approved OPEP(s) for the pipeline. 3.6 PON1 Reporting for Ongoing Releases The Department considers any continuous or intermittent release from the same source to be “ongoing”. PON1s which detail ongoing releases must be updated on a 24-hourly basis unless otherwise agreed with the Department. 8 The PON1 notification form requires the submitter to state whether the ongoing release rate has “increased”, “decreased” or there has been “no change”. The reporter is given the option to add a justification for any change in release rate. For continuous releases this refers to the rate of emission from the release point. For intermittent releases this refers to the rate of emission from the release point during each intermittent release event. It does not refer to the number of intermittent release events. If the release rate is unchanged or there has been no further release the reporter should select the “no change” option. 3.7 Permitted Discharge Notifications The requirement to submit PON1 Permitted Discharge Notifications has been withdrawn. To reflect this withdrawal, the terms and conditions attached to permits issued under the OPPC regulations have been updated and amended non-compliance reporting requirements have been introduced. All requirements regarding the reporting of OPPC non-compliances can be found at [LINK]. 3.8 Third-Party Oil Pollution identified During Offshore Oil and Gas Activities Third-party oil pollution is considered to be marine pollution the source of which is not related to the activities of the reporting installation/vessel. Following the observation of third-party oil pollution it is incumbent on relevant companies (as per Section 3.5) to investigate all potential sources of oil pollution from their operations before concluding the oil pollution is a third-party incident. All third-party oil pollution incidents should be reported by telephone to HM Coastguard in accordance with their requirements. Previously there was a requirement to report third-party oil pollution incidents as ‘Known or Unknown Third-Party PON1s’. This requirement has been withdrawn. The Department may liaise with HM Coastguard in relation to third-party oil pollution incidents reported during offshore oil and gas activities. Any reported third-party oil pollution incident subsequently identified to be a release or discharge arising from offshore oil and gas activities will be investigated by the Department. 9 4. PON1 Review, Pollution Response and Investigation PON1s are notifications of releases and are not required to specifically identify the relevant company (as per Section 3.5) who may ultimately be accountable for the release. All PON1s are assigned to an Offshore Environmental Inspector. The Inspector will review and initially determine whether any further information relevant to pollution response is required. The Inspector will then investigate the circumstances of the PON1. This may necessitate contacting the submitter of the PON1 and/or the relevant companies (as per Section 3.5) to obtain further information regarding the release. All investigations concerning PON1 reportable releases are undertaken in accordance with OPRED’s Enforcement Policy and may result in enforcement action. Further details can be found within the OPRED Enforcement Policy. 10 APPENDIX A: Reporting Flow Diagrams 11 12 APPENDIX B: Definition of Release and Discharge OPPC and OCR define a release and discharge as follows: A release is the emission to sea of oil or offshore chemicals (other than by way of a discharge). A discharge is the intentional emission to sea of oil or offshore chemicals. All discharges of oil or offshore chemicals must be subject to a permit. Any such discharge without a permit is non-compliant with OPPC or OCR and must be reported as a non- compliance. In determining whether an emission is intentional the Department will consider the intent of the system from which the discharge takes place. For example, it is intended to discharge oil from the discharge point of a drainage system with oil recovery facilities. Therefore, oil cannot be released from that discharge point irrespective of the manner in which the oil entered into the drainage system. The oil discharge can only be compliant or non-compliant with the OPPC regime. Intentional emissions can only occur from systems that are designed to (including systems deliberately reconfigured to) emit oil/chemical to sea. All discharges of oil or offshore chemicals which are not in accordance with the terms and conditions of the permit are non-complaint, as are all discharges which occur in circumstances other than those detailed in the permit application. All such discharges must be reported as a non-compliance. All other emissions of oil or offshore chemicals to sea are releases and must be reported on a PON1. Permits cannot be obtained for potential or confirmed releases of oil or offshore chemicals 13 APPENDIX C: Definitions of Oil and Offshore Chemicals What is Oil? OPPC defines oil as any liquid hydrocarbon or substitute liquid hydrocarbon, including dissolved or dispersed hydrocarbons or substitute hydrocarbons that are not normally found in the liquid phase at standard temperature and pressure, whether obtained from plants or animals, or mineral deposits or by synthesis. What is an Offshore Chemical? OCR defines an offshore chemical as any chemical, whether comprising a substance or a preparation, used or intended to be used in connection with offshore activities. Any chemical included on the CEFAS OCNS Lists and/or any chemical included on a chemical permit is an ‘offshore chemical’. All releases of offshore chemicals to sea from an offshore installation, including any of the chemical’s degradation or transformation products must be reported on a PON1 notification. Hydrocarbon Based Offshore Chemicals Releases of hydrocarbon based offshore chemicals (e.g. oil-based drilling mud, base oil etc) must be reported as a release of an offshore chemical(s) if detailed on a Chemical Permit. If the substance is not included on a Chemical Permit or the CEFAS OCNS Lists it must be reported as an oil release. 14 APPENDIX D: Quantification of Release Quantities The quantity released to sea must be included on all PON1 submissions. There are several ways quantities can be determined: • Measured – e.g. quantities are determined based on level indication, tanks drop, tanks volume, metering, etc. • Calculated – e.g. quantities are determined based upon a known flow rate to sea for a known duration, an estimated flow rate and duration or calculated from known quantities and known concentrations. • Estimated – e.g. Bonn Agreement Oil Appearance Code quantities are estimated based upon observations of sheen size, appearance and coverage on the sea surface. Mobilisation of dedicated surveillance aircraft must be considered if the circumstances of the release deem it necessary in order to better estimate the quantity released. All available methods must be considered to ensure that the quantification of released oil/offshore chemical is as accurate as possible. Reporting of Chemical Mixtures and Dilutions PON1 submissions must specify all offshore chemicals as they are detailed in the permit application e.g. PON1s for releases of drilling mud must list the quantity of each individual offshore chemical as detailed in the permit application. Where a mixture of offshore chemicals is released to sea which is not subject to an approved Chemical Permit the individual offshore chemicals that comprise the mixture must be reported as detailed in the CEFAS Offshore Chemicals Notification Scheme Lists of Notified and Ranked Products (CEFAS OCNS Lists). To achieve the required concentration certain offshore chemicals may require dilution with water prior to use. Water can only be deducted from a PON1 submission where the offshore chemical is detailed in the permit application in its undiluted form. If an offshore chemical which is not subject to an approved Chemical Permit is diluted with water prior to use and subsequently released to sea the added water cannot be deducted from the PON1 submission. If any offshore chemical is diluted with water after use (e.g. in a water injection system) and subsequently released to sea this water can be deducted from the PON1 submission. 15 APPENDIX E: Reporting Subsea Emissions of Offshore Chemicals The permit requires all offshore chemicals are used or discharged in accordance with the conditions detailed in the permit application. Any permit issued where the permit application describes the discharge to sea of offshore chemicals from a subsea system is considered to authorise the discharges of the offshore chemicals only from the specific discharge locations utilised during the normal operation of the system e.g. the vent port on a subsea valve that emits hydraulic fluid as a consequence of valve actuation. All discharges of offshore chemicals from these specific discharge locations are either compliant or not with the conditions detailed in the permit application. Any such non-compliant discharge must be reported as a non-compliance and is not PON1 reportable. Any emission to sea of offshore chemicals from any other subsea location is a release and must be reported on a PON1. Specific Guidance on Subsea Control Systems Utilising Hydraulic Control Fluid Any subsea hydraulic control system that is identified to have increasing hydraulic fluid use must be investigated to determine if the discharge is as per system intent. Any such increase in hydraulic fluid use remains compliant with the permit provided: • • • the discharge is in accordance with system intent the annual permitted use and discharge quantities are not exceeded, and the hydraulic control fluid used is detailed on the relevant Chemical Permit application Any emission of hydraulic control fluid out with system intent must be reported as follows: PON1 reportable releases from subsea hydraulic control systems include: • loss of containment from failed hoses, pipes, connections etc. Non-compliant discharges from subsea hydraulic control system include: • control valves seized or stuck in position that results in an emission of hydraulic fluid from the location intended to discharge hydraulic fluid Investigation of Increased Subsea Emissions of Offshore Chemicals The Department recognises that investigation may be required to ascertain the location of any subsea release or non-compliant discharge. In these circumstances Permit Holders may request the addition of the tracer dye to their permit. However, any further release or non- 16 compliant discharge of the incumbent offshore chemical(s) during the leak investigation must be reported by updating the original PON1 or non-compliance. 17 APPENDIX F: Reporting Emissions from Drainage Systems Emissions of Oil from Recoverable Drainage Systems Recoverable drains are systems which route fluids to sea which have the provision for oil recovery thus reducing the amount of oil discharged. The OPPC permit regime allows for the discharge of oil from recoverable drainage systems in the circumstances described in the permit application. The permit details the sources of oil and will specify the approved location(s) for the discharge of oil from drainage systems. Any discharge of oil from this location that is not in accordance with the terms and conditions of the approved permit is non-compliant and must be reported as a non-compliance. Any discharge of oil to sea from a recoverable drain that was not subject to a permit, but where a permit would reasonably have been expected to be issued is still non-compliant with OPPC and must be reported as a non-compliance. This is because the intent of the drainage system is to emit oil in a manner that is compliant with a permit. Any emission of oil to sea from any other part of the recoverable drainage system (e.g. from pipework or vessel failure) is a release (as the Department does not consider it is the intent of the drainage system to emit oil from such a failure point) and must be reported on a PON1. Any aspect of a recoverable drainage system which by-passes the oil recovery system e.g. a direct to sea top-hat/storm drain, is considered to be a non-recoverable drain and the sections below apply. Emissions of Oil from Non-Recoverable Drainage Systems Non-recoverable drains are systems which route fluids to sea which have no provision for oil recovery meaning that all oil entering the system will be emitted to sea. This can include scuppers, top-hats and storm drains etc. The Department does not consider that the intent of non-recoverable drainage systems is to discharge oil. Permits will not be issued for the discharge of oil from non-recoverable drainage systems. Any emission of oil to sea from a non-recoverable drain is a release and must be reported as a PON1. Examples of Drainage Reporting Requirements (Oil) PON1 reportable releases from drainage systems: 18 • the release to sea of oil following a loss of integrity within the drainage system • overflowing oily fluids from a drains tank direct to sea • loss of containment in a diesel tanks which results in the emission of oil via a non- recoverable drainage system • disposal of waste oil to sea via a non-recoverable drainage system • emission of oil to sea following the flushing of oil spilled to deck into a non-recoverable drainage system. • A blockage in any drainage system resulting in the emission of oil to sea via a top hat/storm drain arrangement. Non-compliant discharges to sea from drainage systems • discharges which occur after the failure of any aspect of the oil recovery systems described in the permit application • discharges which exceed the drainage system limits as specified in Table 1 of the permit • discharges from a location in the drainage system that was intended to emit oil but was not described in the permit application • discharges of oil via the drainage system that are not subject to a permit, but where a permit would reasonably have been expected to have been issued. Emission of Offshore Chemicals from Drainage Systems Offshore chemicals may be included on a permit for discharge via drainage systems. Any discharge to sea out with the circumstances described in the permit application is non- compliant and must be reported as such. This means any discharge of an offshore chemical via the drainage system which entered that system in a manner not described in the permit application is a non-compliant discharge and not a release (provided that chemical was included on the permit for discharge via the drains). Any intentional emission to sea of an offshore chemical from a drainage system that was not permitted for discharge, but where a permit would reasonably have been expected to be issued, is non-compliant with OCR and must be reported as a non-compliance. Any other emission of an offshore chemical to sea via the drainage system is a release and must be reported on a PON1. Examples of Drainage Reporting Requirements (Offshore Chemicals) PON1 reportable offshore chemical releases from drainage systems: • the release to sea of offshore chemical following a loss of integrity within the drainage system. • overflowing drains tank fluids which contain offshore chemical residues direct to sea. 19 • the loss of containment of offshore chemicals (from tanks, pumps, pipework etc) into a drainage system where the chemicals are emitted to sea and no permit is in place for their discharge from that system and where no permit would reasonably have been expected to have been issued. Non-compliance offshore chemical discharges to sea from drainage systems: • discharges which exceed the maximum permitted quantity. • discharges of offshore chemicals which are permitted for discharge (from the drainage system) but have entered the system in a manner not detailed in the permit application. • the discharge of an offshore chemical from the drainage system where the discharge was not included on a permit but where a permit would reasonably have been expected to be issued. 20 APPENDIX G: Reporting Emissions from Produced Water Caissons Oil Emissions from Produced Water Caissons Discharges of oil to sea from produced water caissons must be subject to an Oil Discharge Permit which identifies the permitted discharge location. Any emission of oil to sea from any point in the caisson other than from the permitted discharge location is a release and must be reported on a PON1. Offshore Chemical Emissions from Produced Water Caissons Discharges of offshore chemicals entrained with produced water from produced water caissons must be subject to a Chemical Permit. Any emission to sea of offshore chemicals entrained with produced water that is released from a produced water caisson must be reported on the same PON1 as the oil release. 21 APPENDIX H: Reporting Emissions from NPIs and Vessels An offshore installation is any structure maintained on station by any means for the purposes of oil and gas activities. For an NPI holding an accepted Safety Case the following PON1 notification requirements apply in the event of a release: • any release of oil or offshore chemicals from an NPI (including attached equipment e.g. ROV) which is maintained on location to undertake offshore oil and gas activities must be reported on a PON1 notification providing the NPI was within 500m of the location of the offshore oil and gas activity at the time of the release. • if the NPI is located beyond 500m from the location of offshore oil and gas activity any release of oil or chemical should be reported by telephone to HM Coastguard in accordance with their requirements. For the purposes of PON1 reporting a vessel is an offshore installation when: • • • the vessel is maintained on station for the purposes of oil and gas activity and there is an approved Chemical Permit or Oil Discharge Permit for the activity being undertaken from the vessel; and/or the vessel is included in the scope of an approved OPEP relevant to the activity being undertaken; and/or the vessel is included in the scope of a Consent to Locate issued under part 4a of the Energy Act 2008. This means that any release of oil or offshore chemicals from a vessel, or anything attached to that vessel, when it is an offshore installation as defined above must be reported on a PON1 e.g. a release of hydraulic control fluid from an ROV deployed from a vessel is PON1 reportable if the vessel has a Chemical Permit or Oil Discharge Permit, is included in the scope of a Consent to Locate and/or an approved OPEP. If a vessel is not an offshore installation as defined above, any release of oil or chemical should be reported by telephone to HM Coastguard in accordance with their requirements. During bunkering and offloading operations between vessels and offshore installations any hose utilised for such operations is considered to be part of the offshore installation. This means a PON1 notification is required for all releases from equipment up to and including the vessel hose end valve on bunkering and offloading hoses. 22 All other releases of oil or chemicals from the vessel during such operations (e.g. releases from vessel thrusters) should be reported by telephone to HM Coastguard in accordance with their requirements. 23 APPENDIX I: Reporting of Oil Releases during Flaring Operations The introduction of high efficiency burners to prevent oil drop out during flaring operations is considered BAT/BEP. Therefore, any oil drop out to sea during such operations is a release and must be reported on a PON1. 24 APPENDIX J: Excessive Venting of Bulk Powders A PON1 must be submitted where there has been an excessive vent of bulk powders (cement, barite etc). OPRED expects measures are implemented to prevent excessive vents. These may include constant monitoring of vents during bunkering, robust procedures in place and an awareness of what a normal vent looks like (photographs/video) which can be used to compare against any perceived excessive vent. To determine if an excessive vent has occurred permit holders / installation operators should determine if any of the following scenarios have been realised. Equipment Malfunctions: Damaged seals, worn-out gaskets or holes in ductwork can allow powders to escape. Over-pressurization: Silos or vessels can become over-pressurized during filling, forcing powder out through vents or rupture points not designed for continuous operation. Inadequate Dust Control Systems: Undersized or poorly maintained local exhaust ventilation (LEV) or filtration systems may not capture all airborne particles effectively, leading to their release into the external environment. Poor Work Practices: Manual handling activities like the vigorous opening and emptying of bags, or the use of compressed air for cleaning (which disperses dust), can create excessive airborne dust that overwhelms ventilation systems. Incorrect Material Flow: Problems like powder flushing (uncontrolled, rapid flow like a liquid) can lead to the overfilling of vessels, causing powder to be ejected through vents. Failure to follow operational procedures: Procedures should be in place to minimise venting, if these procedures are not followed, inadequate or not in place, this can give rise to an excessive vent. 25 APPENDIX K: Definitions CEFAS OCNS Centre for Environment, Fisheries and Aquaculture Science Offshore Chemical Notification Scheme The Department Offshore Petroleum Regulator for Environment and Decommissioning HM Coastguard Her Majesty’s Coastguard Licensee See section 3.4 MCA NPI Marine and Coastguard Agency Non-Production Installation NPI Owner See section 3.5 OCR OPEP OPPC The Offshore Chemicals Regulations 2002 (as amended) Oil Pollution Emergency Plan The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (as amended) Oil and Offshore Chemical Defined in Appendix C Offshore installation See section 1 Offshore Oil and Gas Activities This definition of oil and gas activities is derived from terminology used in OPPC and OCR as applied to discharges and releases of oil and offshore chemicals. Offshore oil and gas activities are those activities carried out at or from an offshore installation in relation to: The exploration for or exploitation of mineral a) resources activities associated with gas storage, loading and b) unloading c) conveyancing by pipeline 26 the decommissioning of any offshore installation or d) pipeline the provision of accommodation on an offshore e) installation related to the above activities OPRED Offshore Petroleum Regulator for Environment and Decommissioning. Permit Holder See section 3.5 Pipeline Operator Production Installation Operator See section 3.5 See section 3.5 ROV Remotely Operated Vehicle Secretary of State Means the Secretary of State for Business, Energy and Industrial Strategy, or, in the event of a change of the name of the department, their successor Secretary of State with responsibility for the environmental regulation of offshore oil and gas activities. SOPEP Shipboard Oil Pollution Emergency Plan Vessels A vessel is an offshore installation in the circumstances set out in Appendix H Well Operator See section 3.5 This publication is available from: www.gov.uk/guidance/oil-and-gas-offshore-environmental- legislation 27 This publication is available from: www.gov.uk/guidance/oil-and-gas-offshore-environmental- legislation If you need a version of this document in a more accessible format, please email opred@energysecurity.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use. --- Integrated Reporting Service Guidance © Crown copyright 2021 This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk. Where we have identified any third-party copyright information you will need to obtain permission from the copyright holders concerned. Any enquiries regarding this publication should be sent to us at: OPRED@energysecurity.gov.uk Integrated Reporting Service Guidance Purpose This document provides guidance on how and when to submit non-compliance notifications and notices to OPRED/DESNZ (the Department) to report breaches of environmental legislation and/or conditions associated with environmental permits, consents and licences during offshore oil and gas activities via the Integrated Reporting Service (IRS). Integrated Reporting Service Guidance Amendment Record While every effort has been made to ensure the accuracy and completeness of this Guidance it is acknowledged that information may become out of date or may on occasion include errors, for example, links to Department and Third-Party websites can fail as a result of website changes. Please contact the Department for clarification on any aspects of the guidance. The Department will update / correct any information identified as outdated or erroneous at the time of the next revision of this Guidance. Any amendments/enquires relating to this document should be addressed, in the first instance to the Department’s Offshore Environmental Inspectorate Team. No Amendment (summary) 1 First Issue 1.1 Section 6.4 - Corrected reporting timeframe for OPPCNCN submission from 48 hours to 2 working days. Additional guidance on identification of maximum load breaches included. Section 7.4 - Corrected reporting timeframe for OCRNCN submission from 48 hours to 2 working days. 1.2 Branding of document updated from BEIS to DESNZ Section 2.1 updated to indicate where multiple non- compliances/incidents Reviewed / amended by Approved by E Leslie and D MacDonald A Taylor D MacDonald A Taylor Position Date September 2021 November 2021 Offshore Inspectorate Technical Lead Offshore Inspectorate Technical Lead D MacDonald A Taylor September 2024 Offshore Inspectorate Technical Lead Integrated Reporting Service Guidance can be reported on the same notification. Section 3.6 included to provide guidance on end of year PON1 reports. Section 5.3 table 2 includes updated text relating to fog signal range. Section 6.3 table 4, section 7.3 table 8 and section 8.3 table 10 updated to make clear only the non-compliant portion of the discharge/emission requires to be reported and not the total discharge / emission. Section 8. Additional tables added to account for potential permit non compliances for installations that are Large Combustion Plant, Medium Combustion plant and non Large or Medium Combustion Plant. Section 8.4 amended to include timeframe for reporting a breach of PPC permit conditions. Section 11. New section added to include abbreviations used throughout the document. Integrated Reporting Service Guidance Contents Purpose __________________________________________________________________ 3 Amendment Record _________________________________________________________ 4 1.0 Introduction ____________________________________________________________ 8 2.0 Reporting ______________________________________________________________ 9 2.1 Reporting Obligations ___________________________________________________ 9 3.0 PON1 ________________________________________________________________ 10 3.1 Legislative Background _________________________________________________ 10 3.2 PON1 Guidance ______________________________________________________ 10 3.3 Application of the PON1 regime __________________________________________ 10 3.4 Timeframe for PON1 submissions ________________________________________ 11 IRS PON1 submissions__________________________________________________ 11 Telephone Notifications__________________________________________________ 11 3.5 Ongoing PON1s ______________________________________________________ 11 3.6 End of Year Reports ___________________________________________________ 12 4.0 PON2 ________________________________________________________________ 13 4.1 Legislative Background _________________________________________________ 13 4.2 PON2 Guidance ______________________________________________________ 13 4.3 Requirement for PON2 submission _______________________________________ 13 4.4 Timeframe for PON2 submissions ________________________________________ 14 4.5 Ongoing PON2 _______________________________________________________ 14 5.0 PON10 _______________________________________________________________ 15 5.1 Legislative Background _________________________________________________ 15 5.2 PON10 Guidance _____________________________________________________ 15 5.3 Requirement for PON10 submission ______________________________________ 15 Carrying out activity without a consent to locate _______________________________ 21 5.4 Timeframe for PON10 submissions _______________________________________ 21 5.5 Ongoing PON10 ______________________________________________________ 22 Integrated Reporting Service Guidance 5.6 Navigation Light Range ________________________________________________ 22 6.0 OPPC NCN ___________________________________________________________ 22 6.1 Legislative Background _________________________________________________ 22 6.2 OPPC Guidance ______________________________________________________ 23 6.3 Requirement for an OPPC NCN __________________________________________ 23 6.4 Timescale for OPPCNCN submissions _____________________________________ 30 6.5 OPPCNCN requirements for ongoing incidents ______________________________ 30 7.0 OCR NCN ____________________________________________________________ 32 7.1 Legislative Background _________________________________________________ 32 7.2 OCR Guidance _______________________________________________________ 32 7.3 Requirement for an OCR NCN submission _________________________________ 32 7.4 Timeframe for OCRNCN submissions _____________________________________ 36 7.5 Ongoing OCRNCN ____________________________________________________ 36 8.0 PPC NCN _____________________________________________________________ 37 8.1 Legislative Background _________________________________________________ 37 8.2 PPC Guidance _______________________________________________________ 37 8.3 Requirement for an PPC NCN submission __________________________________ 37 8.4 Timeframe for PPC submissions _________________________________________ 55 8.5 Ongoing PPC NCN ____________________________________________________ 55 9.0 F-Gas/ODS NCN _______________________________________________________ 56 9.1 Legislative Background _________________________________________________ 56 9.2 F-Gas/ODS Guidance __________________________________________________ 56 9.3 Requirement for a F-Gas/ODS NCN submission _____________________________ 57 9.4 Timeframe for F-Gas/ODS NCN submissions _______________________________ 59 9.5 Ongoing F-Gas/ODS NCN ______________________________________________ 59 10.0 General NCN _________________________________________________________ 60 10.1 Legislative Background ________________________________________________ 60 10.2 Guidance __________________________________________________________ 60 10.3 Requirement for a General NCN submission _______________________________ 60 10.4 Timeframe for a General NCN submissions ________________________________ 60 10.5 Ongoing General NCN ________________________________________________ 60 11.0 Abbreviations _________________________________________________________ 61 Integrated Reporting Service Guidance 1.0 Introduction IRS is a service hosted within the United Kingdom Energy Portal. IRS is used to report the following to the Department; • PON1 – Releases to sea of oil or offshore chemicals • PON2 - Loss of deposition of materials to sea • PON10 – Non-compliance with Part 4A of the Energy Act/Consent to Locate (including Standard Marking Schedule) • OPPC NCN – Non-compliance with the OPPC Regulations / an OPPC Permit • OCR NCN – Non-compliance with the OCR Regulations / an OCR Permit • PPC NCN – Non-compliance with the PPC Regulations / a PPC Permit • F-Gas/ODS NCN – Non-compliance with the F-Gas / ODS Regulations • General Regulatory NCN – Any breach / non-compliance with Regulations not listed above, for example a breach associated with the conditions of a Geological Survey or Marine Licence. Readers of these guidance notes may find it useful to consult OPREDs offshore environmental legislation page for information on environmental regulations and guidance on offshore oil and gas exploration and production, offshore gas unloading and storage and offshore carbon dioxide storage activities. To access the IRS users must first register for an Energy Portal Login Account (https://itportal.ogauthority.co.uk/eng/fox). Thereafter to access the IRS users must be given the appropriate permissions by their organisations IRS administrator. Access to IRS is through the same link (https://itportal.ogauthority.co.uk/eng/fox). IRS has been designed to allow any installation operating in the UKCS, be that a fixed installation, mobile drilling unit, diving support vessel, flotel etc which may require to make a notification through IRS. If you require an IRS installation account to be set up contact OPRED@energysecruity.gov.uk IRS has been designed in line with the Government Digital Services (GDS) guidelines and has been designed to be intuitive to use. On-screen guidance has been provided within IRS screens to assist the reporter in completing each IRS submission. Consequently, this guidance does not focus on providing instruction on how to use IRS (with the exception of some specific examples), rather the document focuses on reporting requirements including reporting timescales. In the event there are any issues relating to the functionality of IRS contact ukop@ogauthority.co.uk or 0300 067 1682. Integrated Reporting Service Guidance 2.0 Reporting 2.1 Reporting Obligations During offshore oil and gas activities the responsibility for ensuring any required non- compliance notification or notice is reported to the Department rests with the relevant environmental permit holder. If there is no permit holder reporting responsibility rests with the Production Installation Operator, Well Operator, NPI Owner or Pipeline Operator dependent on the nature and scope of the offshore oil and gas activities being undertaken at the time the incident occurred. All non-compliance notifications and notices are to be made electronically to the Department via IRS. In certain circumstances additional telephone notifications are also required. This requirement is highlighted within applicable IRS screens and is also detailed within this guidance document. When reporting numerous non-compliances that are related/have a common theme the Department would expect these to be reported on a single NCN. Examples include; F-Gas. Failure to undertake leak testing; Where leak testing has not been undertaken, for example a leak testing campaign did not occur, the Department does not expect a non- compliance to be submitted for each piece of equipment that was not leak tested, rather a single non-compliance detailing the pieces of equipment that have not been leak tested is required. PON2. If during an ‘event’ numerous pieces of equipment are lost to sea, these pieces of equipment can be reported on a single PON2 as opposed to a PON2 submitted for each piece of equipment lost to sea. PON10. Where there is the simultaneous impairment of navigation aids with a common theme these can be reported on the same PON10 as opposed to submitting a PON10 for each navigation aid that is impaired. This approach is only to be taken when reporting issues that are related/have a common theme. For example, if there has been a breach of an OPPC permit limit which coincides with the loss of a produced water meter, as these events are not related, they must be reported on separate NCNs. Integrated Reporting Service Guidance 3.0 PON1 3.1 Legislative Background A Petroleum Operations Notice 1 (PON1) is the notice used to report all releases to sea of oil and offshore chemicals that occur during offshore oil and gas activities. The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulations 2005 (OPPC) and the Offshore Chemical Regulations 2002 (OCR) include provisions which require the permit holder or, if there is no permit holder, the operator to provide details of the following: • Any Incident resulting in a release • Any other incident involving oil/offshore chemicals where there has been or may be any significant effect on the environment by means of pollution OPPC and OCR also require that a person who releases oil or offshore chemicals must provide the Secretary of State with such information as they may reasonably require for the purpose of performing their functions under the Regulations. In addition to the requirements of the Regulations, the terms and conditions attached to OPPC and OCR permits require that the permit holders must report all releases of oil and/or offshore chemicals to the Department by means of a PON1 notification. 3.2 PON1 Guidance The PON1 Guidance (including Directions issued by the Secretary of State under regulation 11A(2) of OPPC and regulation 15(1A) of OCR as to the form and manner of reports) requiring the provision of information in relation to releases to sea of oil or offshore chemicals during offshore oil and gas activities can be found here https://www.gov.uk/guidance/oil-and-gas- environmental-alerts-and-incident-reporting 3.3 Application of the PON1 regime A PON1 must be submitted following any release to sea of oil or offshore chemical during offshore oil and gas activities, regardless of quantity. The PON1 guidance (including all appendices) provides detailed instructions as to the circumstances when a PON1 is required, the information required on a PON1 submission and directions from the Secretary of State as to the form and manner in which this information is to be provided. Integrated Reporting Service Guidance 3.4 Timeframe for PON1 submissions IRS PON1 submissions A PON1 must be submitted without delay and within six hours in accordance with the terms and conditions of the approved OPPC/OCR permit i.e. within six hours of becoming aware of the release. Where no permit is in force, the PON1 must be submitted without delay and the Department expects this will be within six hours. This means that a PON1 must be submitted via IRS within six hours of the permit holder/operator becoming aware of the release. Note – if a PON1 cannot be submitted via IRS then this should be done by emailing a copy of a completed PON1 proforma to OPRED@energysecurity.gov.uk A copy of the proforma can be found here Telephone Notifications The Department and HM Coastguard must also be notified by telephone, without delay and within one hour of becoming aware of the release, where the release meets any of the following criteria: • exceeds 1 tonne (including when an update to an ongoing PON1 first exceeds 1 tonne) • is within 40 kilometres of the coast • exceeds any specific telephone reporting threshold detailed within a relevant OPEP • is the first report for an ongoing release (telephone notification to HM Coastguard only) Contact telephone numbers for the Department and HM Coastguard are in the relevant Oil Pollution Emergency Plan (OPEP). 3.5 Ongoing PON1s The Department considers any continuous or intermittent release from the same source to be “ongoing”. PON1s which detail ongoing releases must be updated in IRS on a 24-hourly basis unless otherwise agreed with the Department. Each PON1 notification which reports an “ongoing” release requires the submitter to confirm whether the ongoing release rate has “increased”, “decreased” or there has been “no change”. For continuous releases this refers to the rate of emission from the release point. For intermittent releases this refers to the rate of emission from the release point during each intermittent release event. It does not refer to the number of intermittent