The instances of regulatory enforcement action in the last year remind us of the challenges and importance of sustaining high standards of risk management in our major accident hazard energy industries.

In a concerted drive to effectively control enduring major accident hazard risks, and emerging risks, against an evolving risk landscape, the Health and Safety Executive’s (HSE) Energy Division has outlined its key focus areas.

For offshore oil and gas operations, key inspection priorities include:

  • Process Safety Leadership
  • Maintenance Backlog Management
  • Asset Integrity Management
  • Late Life Operations and Decommissioning

More broadly, the HSE will also focus on:

  • Cyber Security
  • Policy Development for the Renewables and Energy Transition Sector

Within this context, it is essential that operators have strong management processes to understand and mitigate risk, and be able to communicate the current risk status to leaders and the workforce.

Taking time to reflect and challenge your thinking on how well your organisation controls these risks will help to improve risk management and better prepare your organisation for an HSE inspection.

Process Safety Leadership

The HSE initiated inspections against the eight Principles of Process Safety Leadership in 2021. The Process Safety Leadership program will continue throughout 2024 as it strives to embed principles that promote a culture of process safety within the industry.

Scapa Energy has been privileged to work with a number of clients to assess and support operators build Process Safety Leadership capability. This year, we shared the results of our own engagement with more than 130 people across seven operators to outline common themes in process safety leadership performance within the energy industry. For example, one key theme was the requirement to strengthen process safety leadership improvement programmes . You can read more about Scapa Energy’s process safety leadership performance analysis here .

Key questions to reflect on Process Safety Leadership are:

  • What key learnings have been identified from your assessment against the eight Principles of Process Safety Leadership?
  • Have you implemented a Process Safety Improvement Plan in your organisation?
  • How will you test the effectiveness of improvements you have committed to?

Maintenance Backlog

Improvements have been made in safety-critical (SECE) maintenance backlog management, however, they remain similar to pre-pandemic levels. There is an increased concern with non-SECE maintenance, where this can have a cumulative risk impact, such as a failure in utility systems affecting the performance of safety-critical systems.

HSE inspections have also identified risks with un-measured backlog. A typical example is overdue or unmeasured manhours associated with fabric maintenance activities.

The HSE intend to include maintenance backlog management in the majority of inspection activity in 2024.

Key questions for operators to reflect on are:

  • Is the cumulative risk of SECE and non SECE maintenance backlog understood?
  • Is the measured backlog reflective of actual backlog, including fabric maintenance manhours?
  • What plans and strategies are in place to control backlog and related risks to an acceptable level?

Asset Integrity Management

The population of ageing infrastructure in the UK North Sea is significant. Lower production and higher operating costs create tension and it can be a challenge to stay on top of asset integrity risks. Innovative technologies such as geospatial software for remote inspection have been very successful, however, in many cases, there is no substitute for effective implementation of risk-based inspection activities.

Key questions to reflect on Asset Integrity status include:

  • Are the top 10 key integrity threats known, mitigated, and action plans in place to resolve?
  • Have there been significant changes to process conditions that may create new integrity threats?
  • How many aged Defined Life Repairs are there, and when will permanent repairs be implemented?

Decommissioning and Dismantlement

With a sizeable volume of ageing offshore assets requiring decommissioning and dismantlement in the North Sea, this will continue to be an area of regulatory focus. Late life assets, or installations that have ceased production do have a lower risk profile, however, they can still create major accident scenarios, such as connections to live pipelines, or significant stored inventory of hydrocarbons. Changing operatorship models has also resulted in an increase in new entrant late-life contract operators during decommissioning and dismantlement.

These factors should be carefully assessed to ensure licensees are assured these late life risks are controlled.

Cyber Security

The National Cyber Security Centre (NCSC) has indicated increased threat levels to cyber security within the UK’s major hazard industries. Trial inspections covering a range of operators found large gaps in order to reach compliance.

In response, the HSE will continue to raise operators’ focus on cyber security through a programme of targeted inspections at major accident hazard sites, particularly those that may impact industrial automation and control systems (IACS), ensuring the resilience of critical infrastructure against cyber threats.

These IACS are commonly programmable and may, therefore, be vulnerable to cyber threats, potentially leading to undetected faults, failure, downtime, and ultimately an increased risk of major incidents.

Risk Management in Renewables

With innovation pivotal to building a more sustainable energy industry, the HSE plays a vital role in diligently controlling risk throughout evolving energy production activity. The HSE’s priorities in 2024 will include supporting the safe development of hydrogen generation and carbon capture under the Department for Energy Security and Net Zero (DESNZ), ensuring that the right organisational structures are in place to reduce risk as these new forms of activity continue to scale.

The role of HSE is to ensure operators are complying with their legal duties, however, it is the role of leadership to set expectations, provide the right tools and make the right resources available to control risk. In turn this achieves effective MAH risk management and high performing teams.

For support in addressing any of these areas of risk, get in touch with our team today at