Petroleum Safety Framework (PSF)
The CRU is the independent safety regulator for upstream (offshore and onshore) petroleum exploration and extraction activities in Ireland. In order for petroleum undertakings, operators and owners to carry out a designated petroleum activity the petroleum undertaking must first receive a safety permit from the CRU.
The Petroleum Safety Framework
The CRU regulates the industry in accordance with the Petroleum Safety Framework a collection of regulations, written regulatory documents and procedures. The underpinning legislation and key PSF documents can be accessed below, including the CRU Requirements of the Petroleum Safety Framework paper which provides an overview of the CRU safety framework:
Safety Case Guidelines
- ALARP Guidance
- Safety Case Requirements
- NSAI Petroleum Exploration and Extraction Technical Standards
- Compliance Assurance System
Further details on the individual components of the Petroleum Safety Framework and the various application and notification forms for industry use are available below.
In order to obtain a safety permit for a designated petroleum activity, the CRU must assess and accept a safety case(s) for that designated petroleum activity. These safety case(s) are submitted by the operator and owner who will carry out the work.
The table below sets out the safety case(s) that the CRU must accept in order for the related safety permit to be issued:
To assist operators and owners in developing a compliant safety case, the CRU has developed a suite of documents called the Safety Case Guidelines that all existing and prospective operators and owners should be familiar with. In addition, the CRU highly recommends that petroleum undertakings, operators and owners proposing to carry out a designated petroleum activity in Ireland engage with the Petroleum Safety team at their earliest opportunity to get further guidance on the safety case submission and assessment process.
Active Safety Permits
On the 21 July 2021, the CRU issued a Production Safety Permit (Reference: SP16A) to:
- Vermilion Exploration & Production Ireland Limited;
- Equinor Energy (Ireland) Limited;
- Vermilion Energy Ireland Limited; and
- Nephin Energy Limited.
This permit replaced the existing Production Safety Permit SP 16.
The Safety Permit was issued under Section 13P of the Electricity Regulation Act 1999, as amended, in respect of the carrying on of certain designated petroleum activities related to production under or in connection with the Petroleum Lease granted pursuant to section 13 of the Petroleum and Other Minerals Development Act 1960, as amended, dated 15 November 2001, as amended and/or assigned from time to time; the consent granted pursuant to section 5 of the Continental Shelf Act 1968, as amended, dated 15 April 2002; and the consent granted pursuant to section 40 of the Gas Act 1976, as amended, dated 25 February 2011 and 29 December 2015.
PSE Kinsale Energy Limited Decommissioning
Decommissioning Safety Permits SP 17 and SP 18 and Well Work Safety Permits SP 21 and SP22 no longer apply to the Petroleum Infrastructure of the Grantees (PSE Kinsale Energy Limited,
PSE Seven Heads Limited and Island (Seven Heads) Limited) as all Petroleum Infrastructure is hydrocarbon free and all 24 production wells have been plugged and abandoned.
Expired Safety Permits
Well Work Safety Permit – SP15 (Designated petroleum activity has concluded)
Well Work Safety Permit - SP 04 (Designated Petroleum Activity has concluded)
Well Work Safety Permit - SP 10 (Designated Petroleum Activity has concluded)
Well Work Safety Permit - SP 11 (Designated Petroleum Activity has concluded)
Well Work Safety Permit - SP12a (Designated Petroleum Activity has concluded)
Production Safety Permit- SP09B (Designated Petroleum Activity has concluded)
Production Safety Permit- SP08B (Designated Petroleum Activity has concluded)
Production Safety Permit - SP16 (Designated Petroleum Activity has concluded)
Well Work Safety Permit SP20 (Designated petroleum activity has concluded)
Well Work Safety Permit SP21 (Designated petroleum activity has concluded)
Acknowledgement of Compliance
The CRU have put in place an additional safety case assessment option specifically for non-production installations, whereby rig owners can apply to be assessed for an Acknowledgement of Compliance (AoC) for their non-production installation separate to a safety permit application. An AoC is confirmation that, at the time of the related non-production safety case assessment, the information submitted satisfied the requirements of the CRU Safety Case Guidelines. This AoC can then be submitted as part of a future safety permit application with the intent of making that assessment process more efficient for the owner.
Issued Acknowledgment of Compliance for Non-production Installations
|AoC No||Owner||Non-Production Installation||Date Issued|
|AoC-01||Helix Well Ops (UK)||Well Enhancer||28/03/2019|
|AoC-04a||Stena Drilling Ltd.||Stena IceMax||14/03/2019|
|AoC-06||Stena Drilling Ltd||Stena Spey||01/04/2021|
Levies and Safety Case Fees
The Petroleum Safety Framework is funded in two ways: an annual industry levy and safety case assessment fees. The annual levy issued to the petroleum undertakings, covers all operational costs incurred by the CRU in discharging its regulatory petroleum safety functions, such as operational inspections and incident investigations. Details on how the levy is calculated can be found in the Petroleum Safety Levy Methodology paper.
The safety case fees cover the costs associated with the CRU assessment of a safety case. The owner or operator that submits the safety case is liable for the associated safety case fee. Operators and owners pay an upfront initial safety case fee with their safety case submission and once the CRU assessment is complete the final safety case fee is calculated. Further details can be found in the Safety Case Fees Structure and Methodology paper.
Compliance and Enforcement
For further information on the CRU enforcement powers and compliance requirements under the Petroleum Safety Framework, including audits and inspections, verification, performance reporting and independent safety case reviews, please click here.
Petroleum Incidents and Confidential Reporting
The Petroleum Safety (Petroleum Incident) Regulations 2016 set out the petroleum incidents that operators and owners are required to report to the CRU. Guidance on the notification of petroleum incidents to the CRU can be found in our Guidance for Notification of Incidents paper.
Petroleum incident(s) are required to be notified to the CRU without delay and further details on the incident(s) must be submitted within 10 working days. On notification of a petroleum incident, the CRU may carry out an incident investigation.
To report a petroleum incident, please click here to access the Petroleum Incident Notification Form.
Operators and owners may also report additional incidents to the CRU under section 13S(2) of the Petroleum Safety Act 2015. To report these types of incidents, please use the Section 13S(2) Incident Notification Reporting Form.
Concerns relating to petroleum safety matters onshore and safety and environmental matters offshore that are linked to a permitted petroleum activity can be notified to the CRU by any person. This can also be done by completing the Confidential Reporting Form. Where requested, CRU will aim to follow up with such notices in a fully confidential manner. Concerns can be notified to the team via any of the CRU main contact details and marked for 'Petroleum Safety', or by sending an email to the Petroleum Safety Team: firstname.lastname@example.org, with a completed Confidential Reporting Form attached.
Further details on confidential reporting, including reporting by workers, can be found in the Requirements of the Petroleum Safety Framework paper.
Reporting to the European Commission
CRU is required to report specified incidents to the European Commission as set out in Annex IX of Directive 2013/30/EU on offshore safety. Copies of the annual incident reporting to the European Commission can be viewed below.
|Reporting Year||Link to Report||No. of reportable incidents|
*On 16 March 2018 Commission for Regulation of Utilities (CRU) was notified of a Petroleum Incident. Approximately 8 kg of unignited natural gas was released over 35 minutes during routine operational activities. This incident is not classed as a major accident hazard as there was no ignition of gas; the system depressed as designed; it occurred outdoors in a well-ventilated area and did not set off any gas detectors within that area. There were no reported injuries to personnel. However, the incident is reportable to EU Commission under 1112/2014 as the amount released was ≥1 kg.
Petroleum Safety Framework Documents
In addition to the documents linked throughout this section of the website, the CRU has published the following documents for information:
This information document provides high level indicative guidance to petroleum undertakings on the potential sequencing and interaction between the assessment of safety cases and the issuance of safety permits by the CRU and the other licenses/permits and consents issued by the other statutory authorities.
The purpose of the booklet is to assist safety representatives and offshore personnel in understanding their roles under Irish offshore legislation.
The International Regulators’ Forum (IRF), met on 4 May 2020 via teleconference to share information about the COVID-19 pandemic and discuss the IRF’s plans for the year ahead. Participants discussed issues that the pandemic has created for the offshore industry in their respective jurisdictions, which include occurrences of illness in offshore workers in some countries, the challenges associated with physical distancing, reductions in personnel on facilities, and other preventative measures in offshore operations.
During 2015 and 2016, the CRU's Petroleum Safety Team together with other members of the Health and Safety Working Group of the North Sea Offshore Authorities Forum (NSOAF), agreed a programme or work concerning the challenges related to maintaining and operating ageing installations in a lower oil price environment. The Group developed a multinational audit (MNA) on the theme of Maintaining Safe Operations with a common set of themes and questions which was then conducted by each regulator on industry in their respective countries
The resulting Report describes the audit process and summarises the findings and learnings from the MNAs. The findings are presented in the report as good or poor practices to indicate areas of improvement and potential for knowledge transfer.
The objectives of the MNA were to ensure that all relevant lessons with respect to maintenance of safety critical barriers learned by the NSOAF members from the audits, are communicated to the industry, and implemented in the North Sea. The overall goal is to evaluate the companies’ ambitions and priorities through managing major accident risk and maintaining safe operations in times of major cost reductions and massive efficiency programs.
Key findings will be shared with representatives from all parties involved in the industry.
Participating countries and organisations:
Norway: Petroleum Safety Authority, Norway
United Kingdom: Health and Safety Executive, UK
Germany: Landesamt für Bergbau, Energie und Geologie, Dienstsitz Clausthal
Ireland: Commission for Regulation of Utilities, Petroleum Safety Framework
The Netherlands: State Supervision of Mines
Denmark: Danish Working Environment Authority
NSOAF Multi-National Audit Human and Organisational Factors in Well Control 2012 – 2013
In light of the Deepwater Horizon blowout, the North Seas Offshore Authorities Forum (NSOAF) carried out a multi-national audit of the human and organisational factors associated with well control. The resultant report describes the background to the audits and the relevance of the various issues considered.
Cooperation Arrangements and International Groups
National Cooperation Arrangements
In carrying out its petroleum safety functions the CRU engages with other statutory stakeholders. To ensure open communication, good inter-agency workings and efficient operations, the CRU has developed a number of memoranda of understanding (MoU) together with these state agencies.
Petroleum Safety Framework
The following MoUs are in place specific to the CRU Petroleum Safety Framework:
The CRU Energy Safety division is responsible for the safety regulation of natural gas supply, transmission, distribution, storage and use of gas, the registration of electrical contractors and gas installers by designated bodies, and the regulation of upstream designated petroleum activities. To ensure that the CRU can carry out its regulatory remit and to facilitate co-operation and mutual assistance between statutory agencies the following MoU’s are in place:
Energy Safety and Water
The CRU and the Environmental Protection Agency have an MoU that facilitates cooperation and coordination between the two agencies in the performance of their respective roles as regards both safety and water services. These areas of cooperation are in relation to designated petroleum activities, petroleum undertakings and operators, practices involving radioactive substances, irradiating apparatus or other sources of ionising radiation and in regulating Irish Water.
The CRU is an active member of the following international petroleum safety and regulatory groups. These groups facilitate the sharing of information between regulators and promote improvements in safety standards through industry engagement. Working groups are also established to address specific topics on a regular basis. The work of these groups can include carrying out research, providing training, and conducting multi nation programmes. Further information is provided below and links to recent published reports from the groups can be found above under Relevant Publications.
The North Seas Offshore Authorities Forum
The NSOAF (North Sea Offshore Authorities Forum), founded in 1989, is a forum for co-operation between the authorities of the North Sea countries. The primary focus is on offshore safety and health. The members of the NSOAF are the following countries (with the institutions in brackets):
- Denmark (Danish Energy Agency)
- Faroe Islands (Faroe Islands Earth and Energy Directorate)
- Germany (State Authority for Mining, Energy and Geology)
- Netherlands (State Supervision of Mines)
- Ireland (The Commission for Regulation of Utilities)
- Norway (Petroleum Safety Authority)
- Sweden (Swedish Geological Survey)
- UK (Health & Safety Executive)
The work of the NSOAF is carried out through 3 active sub-groups which hold meetings as and when required. The NSOAF meets in a plenary assembly once a year to agree the mandates of the working groups and networks for the year ahead.
The CRU partakes in the following NSOAF sub groups:
- The Working Group on Health, Safety and Environment (HS & E Working Group)
This group focuses on working on issues to improve safety, health and environment on offshore installations, and the transfer of experience between regulators.
- Working Group on wells (Wells Working Group)
The working group exchanges information and co-operates on safety matters related to drilling, well operations, well integrity and blowout prevention.
- Network on EU legislative developments (EU Network)
This network exchanges views and experiences concerning EU directives and directive proposals. The NSOAF EU Network was involved in the development and implementation of the new European Offshore Directive (2013/30/EU).
The European Offshore Authorities Group
CRU is a member of the EUOAG which was set up Directive 2013/30/EU.
The EUOAG is a forum for the exchange of information and expertise between national authorities, third countries, industry associations, the European Commission and other stakeholders on all issues relating to major accident prevention and response in offshore oil and gas operations.
Under legislation, CRU must regularly exchanges knowledge, information and experience with other competent authorities. This obligation is fulfilled in part through our participation in the EUOAG.
Click on the link for further information.
International Regulators Forum
The International Regulators’ Forum (IRF) is a group of 11 countries’ regulators of health and safety in the offshore upstream oil and gas industry. It exists to drive forward improvements in health and safety in the sector through collaboration on joint programmes and information sharing.
CRU became a member of the IRF in 2019.
Further information on the IRF can be found here.