Reporting of well incidents - titleholders' performance
Article published in the Regulator | Issue 2: 2017
Following consultation with industry, the Offshore Petroleum and Greenhouse Gas Storage (Resource Management and Administration) Regulations 2011 were amended in 2016 to include a list of reportable incidents for a well in a title area, to align more closely with global process safety and leading methods for reporting indicators. The regulations also now specify the requirement for titleholders to notify and report to NOPSEMA, and keep copies of reports, for all reportable incidents in relation to a well in a title area (regulations 5.26, 5.26A and 5.26B).
NOPSEMA believes there is scope for further improvement in notification and reporting of these types of incidents. We would like to remind titleholders of their responsibilities under the regulations and provide information that may assist them in fulfilling these requirements.
Under regulation 5.26, titleholders are required to provide NOPSEMA with verbal notification as soon as practicable after the first occurrence of the reportable incident. If the incident was not detected by the titleholder at the time of the first occurrence, then the titleholder must give verbal notification as soon as it becomes aware of the incident. Please call NOPSEMA’s dedicated notification phone number (08 6461 7090) to notify us of reportable incidents. This line is monitored by NOPSEMA inspectors continuously.
It is important to remember that the responsibility to notify NOPSEMA rests with the titleholder and not the facility operator (unless the operator is also the titleholder). In the past, drilling contractors have attempted to make notifications instead of or on behalf of a titleholder; this is not appropriate.
Similarly, under regulation 5.26A, titleholders are required to provide NOPSEMA with a written report for a reportable incident no later than three days after the first occurrence of the incident. If the incident was not detected by the titleholder at the time of the first occurrence, then the report should be provided no later than three days after the time the titleholder becomes aware of the incident.
The report must contain all material facts and circumstances concerning the incident that the titleholder knows or is able to find out, and any action taken (or proposed to be taken) to stop, control or remedy the reportable incident and prevent re-occurrence of a similar incident. To make sure titleholders include all the required information, NOPSEMA has developed a reporting template, available on our website at www.nopsema.gov.au/well-integrity/notification-and-reporting. All written reports should be sent to firstname.lastname@example.org. Please note that regulation 5.26B requires titleholders to keep a copy of the written report provided to NOPSEMA for five years.
If a titleholder needs more time to provide all of the information required, it may request an extension via email to email@example.com. A clear statement indicating the reasons for the request must be included. NOPSEMA reviews requests on a case-by-case basis and will notify the titleholder when we’ve made a decision. Failure to meet the requirements of the regulations is an offence of strict liability and varying penalties apply. NOPSEMA will consider taking enforcement action in accordance with our compliance strategy, available on our website at www.nopsema.gov.au/about-us/compliance-strategy.
For more information see our Reportable incidents in relation to a well in a title area — Notification, reports and records guidance note (GN1636), at www.nopsema.gov.au/well-integrity.