commission for energy regulation report on safety 2012...figure 3 carbon monoxide awareness week...
TRANSCRIPT
Commission For EnErgy rEgulationRepoRt on Safety 2012to the minister
Commission for Energy Regulation
an Coimisiún um rialáil Fuinnimh
ii
iii
Contents
Table of figures IV
Table of Tables V
foreword 01
eXeCuTiVe suMMarY 02
Natural gas safety regulatory framework 02
gas safety supervision 02
electrical safety 03
Petroleum safety framework 03
iNTroduCTioN 04
structure of the report 04
ParT 1 NaTural gas safeTY fraMework 05
fraMework oVerView 05
regulated Natural gas undertakings 08
what is a safety Case? 08
Material Changes to Safety Cases 09
The gas safety framework reporting regime 09
Incident Reports 09
Quarterly Performance Reports 09
Annual Report 09
Audit and Inspection Reports 09
The gas safety supervisory body (gssb) 10
Cer gas safety Team 10
deVeloPMeNT of fraMework 11
developments in framework in 2012 11
developments in 2013 11
MoNiToriNg of The fraMework 12
Proactive Monitoring 13
Audit Programme 13
Transmission and Distribution System
Operator Audits 2012 13
Audit of Shippers/Suppliers 13
Audit of the RGII (GSSB) 13
Inspection Programme 14
Inspections carried out by RGII (GSSB) 15
Safety Case Management Programme 15
Emergency Response Programme 16
reactive Monitoring 16
Incident Reporting Summary 2012 17
key performance indicators - reporting & Trending 18
other monitoring activities 18
Reporting to the Commission 18
Stakeholder Management & Governance 18
Gas Safety Promotion and
Public Awareness (PAPA) 19
Outcomes of Incident Review 21
PerforMaNCe of The fraMework 23
Performance against safety objectives: 2012 23
Key Safety Objective 1:
Minimising the Loss of Containment 23
Key Safety Objective 2:
Maintaining Safe System Operating Pressure 25
Key Safety Objective 3:
Minimising the risk of injecting gas
of non-conforming quality 26
Key Safety Objective 4:
Providing an Efficient and Coordinated
Response to Gas Emergencies 27
Key Safety Objective 5:
Minimising the Safety Risks Associated with the
Utilisation of Gas 27
Key Safety Objective 6:
Promoting Public Awareness of Gas Safety 29
CoNClusioN 31
ParT 2 eleCTriCal safeTY suPerVisioN 32
iNTroduCTioN 32
overview 32
background 32
safety supervisory bodies 32
regulaTorY PerforMaNCe 32
registered electrical Contractors 32
Certification 33
inspections 33
Public awareness 33
restricted works 34
CoNClusioN 34
glossarY of TerMs 35
aPPeNdiX i work-PlaN 2013 36
gas and electricity safety 36
Petroleum safety framework 36
aPPeNdiX ii iNforMaTioN oN CarboN MoNoXide 37
Carbon Monoxide 37
What is Carbon Monoxide (CO)? 37
The risks associated with CO? 37
The Physiological Effects of Carbon Monoxide. 37
Avoiding Carbon Monoxide 37
iv
Figure 1 Overview of Natural Gas Safety Framework 07
Figure 2 Gas Safety Team Organisation Chart 10
Figure 3 Carbon Monoxide Awareness Week Logo 2012 20
Figure 4 Public Reported Gas Escape Frequencies for 2009 to 2012 24
Figure 5 Third party Damage Frequencies by Supply Type 2010 to 2012 24
Figure 6 Gas in Buildings Events and Evacuations 2009 to 2012 24
Figure 7 Works detected near pipelines 2009 to 2012 25
Figure 8 Number of Cathodic Protection points where the voltage is outside criteria for 6 months or longer 25
Figure 9 Unplanned Distribution Outages 2009 to 2012 26
Figure 10 Frequency of system pressure drops on the distribution system 2009 to 2012 26
Figure 11 Total number of planned and completed odour tests carried out from 2009 to 2012 26
Figure 12 Gas Escape Response Efficiency by quarter 2009 to 2012 27
Figure 13 Registered Gas Installers by Class of Membership 2009 to 2012 27
Figure 14 Registered Gas Installers certificate sales 2009 to 2012 28
Figure 15 Numbers of tampered meters identified 2009 to 2012 28
Figure 16 Numbers of meter leaks or faults identified during 2009 to 2012 as part of meter replacement programme 28
Figure 17 Number of customer requested safety checks performed 2009 to 2012 29
Figure 18 BGN Safety Disconnections at the meter 2009 to 2012 29
Figure 19 Frequency of enquiries to the BGN emergency number vs actual reported escapes 2010 to 2012 20
Figure 20 Number of Carbon Monoxide enquiries 2010 to 2012 20
Figure 21 Plant location enquiries to the Dial Before You Dig number 2009 to 2012 20
Figure 22 Unique visitors to the website www.rgii.ie in 2012 20
Figure 23 Electrical Safety Team Organisational Chart 32
Figure 24 Total number of Registered Electrical Contractors 32
Figure 25 Safety Supervisory Bodies quarterly certificate sales 33
Figure 26 Types of certificates sold 33
Figure 27 Inspections completed on Registered Electrical Contractors 33
Figure 28 Safe Electric logo 34
table of figures
v
Table 1 Accepted Gas Safety Cases 08
Table 2 Audit and Inspection Monitoring process 12
Table 3 Overview of Audits carried out in 2012 13
Table 4 Overview of Inspections carried out on Transmission System Operator 14
Table 5 Overview of Inspections carried out on Distribution System Operator 15
Table 6 Material Change Submissions 15
Table 7 Incidents and Safety Investigations in 2012 16
Table 8 Gas Safety Promotion and Public Awareness Group - Stakeholders 19
Table 9 Physiological Effects of Carbon Monoxide Exposure over time 37
table of tables
01
Chairperson Dermot nolan Commissioner garrett blaney Commissioner Paul Mcgowan
the safe operation of energy infrastructure in ireland is critical both to the economy and the general public. this report for the Minister sets out how we in Cer have discharged our legislative role, with respect to regulating energy safety in 2012 and highlights developments during this time.
This year, for the first time, this report provides information on CER’s remit in relation to regulating electrical safety in addition to gas safety. in future years, Cer will through this report inform the Minister on the safety performance of petroleum undertakings in ireland.
in 2012, our responsibilities for safety continued to increase as Cer were given new legal powers for regulating Liquefied Petroleum gas (lPg) safety. Cer also continued to progress during the year the project to establish Cer as the regulator for petroleum safety. in addition there was further expansion in the supervisory regime which Cer regulates, governing electrical and gas contractors. in 2012, CER’s powers with regard to enforcing its statutory duties were also strengthened.
safety performance of the natural gas industry is measured by the Cer through a set of Key Performance indicators (KPis)1. Continued positive progress in KPis in 2012 is welcomed, including reduced gas escapes and less third party pipe damage.
We are pleased that there were no fatal natural gas incidents during 2012 but there was one injury where the person required hospitalisation.
the Cer safety regime, covering both gas and electrical safety, comprises an annual programme of audits and inspection of regulated entities which is complemented by an enforcement regime where action is required.
the Cer has completed three successful prosecutions with regards to individuals carrying out illegal gas Works since the registered gas installer2 scheme commenced.
Cer engages with all relevant stakeholders in relation to its statutory remit with respect to safety to deliver its strategic objective of safe supply of electricity and gas to consumers.
Cer remains focused on continued and evolving improvements in its regulatory safety regime going forward and in 2013 will be prioritising establishing Cer as regulator for petroleum safety; revising the existing gas safety framework to regulate lPg undertakings and expanding the safety regime which exists for electrical and gas contractors to ensure that those undertaking work in a domestic environment must be registered by law.
1. Key Performance Indicators (KPIs) are used to measure performance of the Framework against its objectives.
2. CER appointed Registered Gas Installers Ireland (RGII) to perform the function of the Gas Safety Supervisory Body (GSSB).
foreWorD
02
this Cer safety report details developments in gas and electrical safety during 2012, while outlining priorities for 2013.
Natural Gas Safety Regulatory Frameworkan annual report on the performance of the framework is required by the Minister in accordance with the electricity regulation act 1999 (as amended).
Cer regulates 17 natural gas undertakings with respect to safety; these include overseeing the safety of the bord gáis networks (bgn)3 transmission and distribution network, and 16 suppliers and shippers of natural gas. all undertakings are required to comply with the framework and are required to submit safety cases in line with the safety Case guidelines (Cer/07/226).
there were no fatal incidents involving natural gas during 2012 and one injury which required hospitalisation. this incident is subject to an on-going investigation.
the Cer also completed in 2012 a programme of audits and inspections of natural gas undertakings (ngus)4, to ascertain compliance with the prevailing safety case regulatory regime. this included 39 inspections of Distribution and transmission related assets and 3 audits of the transmission and Distribution operator. Cer also conducted 12 audits of natural gas shippers and Suppliers. The findings of these audits and inspections are used to inform continued improvements with respect to safety among all undertakings regulated by the CER, in the interests of final customers.
Cer has legislative responsibilities for promoting on-going safety awareness with respect to gas issues among the general public. this work continued as a priority in 2012 through a variety of campaigns. For the first time in Ireland a nationwide Carbon Monoxide Awareness Week was held in september 2012 which was regarded as a major success. the campaign focused on key messages to the public including how to prevent carbon monoxide related incidents and on the dangers associated with Carbon Monoxide. Cer cooperated with a wide range of stakeholders on this campaign including; bord Gáis Networks BGN, Natural Gas suppliers, Liquefied Petroleum gas (lPg) suppliers, national standards authority of ireland (nsai), the Department of Communications, energy and natural resources (DCenr), Department of environment, Community and local
government (DeClg), Health services executive (Hse) and the Health and safety authority (Hsa). the week was launched by persons affected by Carbon Monoxide (Co) incidents and the Minister for Communications, energy and natural resources, Mr Pat rabbitte. the awareness Week is due to be held again in september 2013.
related to this campaign during 2012, the Department of environment Community and local government (DeClg) supported by the Cer and the gas industry updated Part J the building regulations to make installation of Carbon Monoxide alarms mandatory in all new houses.
Cer uses a range of Key Performance indicators (KPis) to monitor safety performance amongst licensed gas undertakings on a continuous basis. Whilst there are positive trends in the majority of the Key Performance indicators, some deterioration was also noted by Cer which were addressed through audit, inspection and discussion with bgn and the relevant undertakings.
a summary of the performance levels for 2012 Key Performance Indicators when compared to the corresponding figures in 2011 are as follows:
✔ Distribution system operator (Dso) Public reported escape levels down by 7.3%.
✔ Pipeline third party encroachments down by 14.3%.✔ external gas escapes down by 15.7%. ✔ third party pipe damage was down by 16.2%.✔ rgi membership up by 4.4%.✔ 99.9% of public reported escapes were responded to within 1hr.✔ Carbon Monoxide website hits remains relatively high compared
to previous years.✘ number of long term Cathodic Protection system faults increased
by 25% in 20125.✘ Level of unclassified leaks6 highlighted as an issue in terms of their
proportion of the overall level of leaks.✘ Transmission System Operator (TSO) Reported Escapes’
increased from 2 in 2011 to 9 in 20127.✘ network outages increased from 1 in 2011 to 2 in 2012 affecting
242 customer properties.✘ safety Disconnections increased by 1% from 2011.
Developments in 2013 with respect to gas safety will include the incorporation of lPg safety functions within the existing gas safety framework to include:
• Cer licensing lPg undertakings with respect to safety. • Cer putting in place reporting requirements for lPg incidents.• Cer giving effect to wider enforcement powers in line with
legislation.
3. Bord Gáis Networks (BGN) is a division of Bord Gais Eireann (Bord Gáis Group). BGN operate independently of other Bord Gáis divisions as required
under EU and National legislation. BGN own, build, operate and maintain the natural gas network in Ireland. BGN carry out these activities on behalf of
Gaslink, Irelands licensed independent system operator of the natural gas network.
4. A natural gas undertaking” means a person engaged in the transmission, distribution, supply or storage of natural gas, including any holder of a licence
or a consent under this Act, or any person who has been granted a licence or given a consent under the Gas Acts, 1976 to 2002.
5. Cathodic Protection is used on both the Transmission and Distribution Systems to prevent corrosion of steel pipework. This is discussed in more detail
later in the report under performance of the Framework.
6. The majority of unclassified leaks are occurring at meter installations.
7. In 2012 reported escapes on the transmission system were reported by BGN employees and Contractors as well as by the public, which may have led to
higher levels of reported escapes.
exeCutive suMMary
03
Gas Safety SupervisionCer has legislative responsibility for the regulation of gas installers with respect to safety. rgii are the body appointed by Cer to undertake the day to day regulation of gas installers including maintaining a register of gas installers, inspecting each gas installer annually, and investigating complaints against registered gas installers. the number of RGI’s in the scheme increased in 2012 from 2931 to 2969. the Cer completed two successful prosecutions of individuals that completed gas Works but were not registered with rgii, bringing the total number of successful prosecutions to three. in 2013 Cer will introduce on-going assessments for gas installers and focus on putting in place arrangements for ensuring that those undertaking work in a commercial setting must also be registered.
Electrical SafetyCer has legislative responsibility for the regulation of electrical contractors with respect to safety. reCi and eCssai are the bodies appointed by Cer to undertake the day to day regulation of contractors including maintaining a register of electrical contractors, inspecting each registered electrical Contractor (reC) annually and investigating complaints. A total of 3994 inspections of REC’s were carried out by reCi and eCssai in 2012.
the trend in the number of registered electrical Contractors (reCs) in the electrical safety supervision scheme continued to decline in 2012 dropping from 4,264 in 2011 to 4,022, but certificate sales grew strongly with sub-system, minor and periodic inspection report type certificates in particular boosting figures.
the Cer completed a programme of technical audits and inspections in 2012 on reCi and eCssai.
From June 2012 it became mandatory for Qualified Certifiers to complete a Testing, Certification and Verification course every three years. this requirement was enhanced further as from the 30th of June 2013, Qualified Certifiers must complete an accredited assessment every five years. Other work will include on- going preparation for re-designation of safety supervisory bodies (reCi and eCssai), audits and inspections of reCi and eCssai by Cer.
Developments in 2013 will include the introduction of a statutory instrument which will ensure that only registered electrical Contractors can complete significant electrical work in a domestic setting, with the exception of some minor works such as replacement of a light fitting. This will be known as Restricted Electrical Works and will be implemented from 1st october 2013.
Petroleum Safety Frameworkfinally with respect to safety during 2012 Cer continued to devote resources to establishing itself as the regulator of safety with respect to oil and gas exploration and extraction both onshore and offshore. the new Petroleum safety framework is expected to go live on november 30th 2013 when the Cer will assume legislative responsibility for this area.
04
the report comprises two parts, with Part 1 covering the Natural Gas Safety Regulatory Framework and Part 2 covering Electrical Safety Supervision.
the purpose of Part 1 of the report is to provide a summary of the safety performance of the gas industry in ireland with respect to the framework in 2012 generally and through use of Key Performance indicators (KPis). this includes outlining the principal objectives of the framework and describing regulatory developments designed to enhance the safety performance of regulated undertakings.
The purpose of Part 2 of the report is to outline CER’s remit with regards to electrical safety supervision. this part of the report also examines regulatory performance in this area as illustrated by Key Performance indicators (KPis).
Structure of the ReportPart 1 is structured into 5 sections; as follows:
• Framework Overview: provides a summary of who the framework applies to in the irish gas market
• Development of the Framework: outlines any legislative and operational changes to the framework that occurred in 2012.
• Monitoring of the Framework: outlines the processes used to monitor performance of the framework by Cer including KPis
• Performance of the Framework: provides an overview of the performance of the natural gas undertakings and the gas safety supervisory body (gssb)
• Conclusion
Part 2 is structured into 3 sections; as follows:
• Introduction: provides an overview of the Cers electrical safety responsibilities, how Cer undertakes this role, and a background on the safety supervisory bodies.
• Regulatory Performance: outlines regulatory performance of the electrical safety function under the CERs remit using KPI’s.
• Conclusion
introDuCtion
05
Framework overviewthe Cer regulates the safety performance of the downstream irish natural gas industry in accordance with its duties under the electricity regulation act, 1999 (the 1999 act), as amended. the scope of the relevant legislation includes the safety regulation of all natural gas undertakings (ngu), including: storage; transmission; distribution; supply; and shipping. Promoting the safe utilisation of natural gas by domestic customers is also a responsibility of Cer under this legislation. regulation is achieved through active and responsive measures as described in this report.
in 2007 the Cer published the natural gas safety regulatory Framework (‘the Framework’) following a public consultation. A detailed outline of the framework is illustrated in figure 1. the framework is based on a philosophy of continuous improvement to safety performance of undertakings in the interests of the public and is therefore evolving. This ensures that the Framework reflects the current gas market, and legal & regulatory requirements. the intent of the Framework is to ensure that the Natural Gas industry’s safety requirements are fulfilled competently, and also to promote and develop public understanding with respect to gas safety. the goal of the framework can is summarised as:
“to ensure that adequate measures are taken to protect life and property from the dangers associated with natural gas by ensuring that gas related activities within the scope of the Commission’s responsibilities are carried out in a safe manner, which takes account of and mitigates against the risks associated with the storage, transportation, supply and use of gas.”
in practical terms, the framework establishes a series of high level safety objectives so that this goal can be achieved.
these Key objectives are as follows:
Key Objective 1: Minimising the Risk of Loss of Containmentgas undertakings are required to demonstrate that they have suitable management systems and procedures in place for managing the risks that could lead to, or arise from, loss of gas containment events.
Key Objective 2: Maintaining Safe System Operating Pressure gas undertakings are required to demonstrate that they have suitable management systems in place for managing the risks that can result in dangerously high or low gas operating pressure in the pipeline system(s).
Key Objective 3: Minimising the Risk of Injecting Gas of Non-Conforming Qualitygas emergency incidents can arise due to gas of inappropriate quality being injected into the system and, as such, gas undertakings are required to demonstrate that they have suitable management systems in place for gas quality monitoring and for managing the risks associated with the quality of gas that is injected into the system. Key Objective 4: Providing an Efficient and Coordinated Response to Gas Emergenciesgas emergency events can and do occur for a variety of reasons including the actions of third parties. the network asset owner (bgn) and the network system operator (bgn on behalf of gaslink) are required to demonstrate that they have suitable arrangements in place for: (i) managing the response to ‘localised’ gas emergencies; and (ii) undertaking the role of network emergency Manager (neM)8
during ‘network’ gas emergencies. Additionally, all gas undertakings are required to demonstrate that they have suitable arrangements in place for responding to the requirements of the network emergency Manager in the event of large-scale ‘network’ gas emergencies being declared by the network emergency Manager.
operators of major accident hazard facilities such as lng terminals and gas storage facilities have responsibility for the on-site management of gas emergencies within the confines of their own facility. the role of the neM in this situation is to manage any potential impacts on the transmission and distribution networks.
8. BGN currently perform the role of Networks Emergency Manager.
Part 1 natural gas safety fraMeWorK
06
Key Objective 5: Minimising the Safety Risks Associated with the Utilisation of Gasthe framework provides for a comprehensive regime relating to the regulation of gas installers. the key aim of this regime is that all categories of ‘Gas Works’ designated by the CER are only undertaken by competent gas installers who are registered, and subject to on-going regulation and inspection by the rgii appointed by the Cer as the gssb. the safe connection and re-connection of customers’ installations to the gas supply network and the servicing of such installations is a priority for Cer. Customer education and safety awareness is addressed in key objective 6 although there is some overlap with this objective.
Key Objective 6: Promoting Public Awareness of Gas Safety increasing the level of gas safety awareness amongst gas customers and the public generally and, in particular, educating on the dangers of carbon monoxide is an important aspect of the CER’s overall objective of promoting the safety of customers and the general public in respect of the use of gas. it is also important that owners/occupiers of premises are aware of their responsibilities regarding the maintenance of gas fittings downstream of the meter. To this end, the framework places duties and obligations on both individual gas undertakings and the industry generally for the promotion of gas safety awareness. this involves a combination of both individual and co-ordinated safety promotional activities by undertakings.
these key objectives above provided the foundation for developing the components of the existing regulatory framework. the component parts of the Framework are described in figure 1.
a Gas Safety Case regime is applied to licenced undertakings, which encompasses a risk and outcomes based approach to the management of gas safety risks. levels of risk should be managed to a level that is as low as reasonably practicable.
a Gas Safety Supervision regime for the registration of gas installers that carry out works on domestic installations. the regime also includes an on-going inspection and assessment of registered installers by the register of gas installers of ireland (rgii).
a Gas Safety Promotion and Public Awareness regime that is designed to increase the overall level of gas safety awareness amongst customers and the general public. Promotional activities are coordinated by Cer and run by individual undertakings.
an Incident Reporting and Investigation regime that fulfils obligations for the reporting and investigation of incidents by bgn, the reporting on the outcomes of incident investigations to the Cer, independent Cer investigations and subsequent reports by the Cer to the Minister. this also includes incident reporting and investigation requirements by the operators of major accident hazard facilities – e.g. Liquefied Natural Gas (LNG) and gas storage operators.
an Audit and Inspections regime that the Cer uses to gain assurance that the various undertakings are operating in compliance with the gas safety management and emergency response arrangements as submitted and described in their respective safety cases as agreed, and the gas safety supervisory body (rgii) in accordance with its terms and Conditions of appointment; and
a Gas Safety Reporting Framework that utilises a suite of gas safety performance indicators to monitor trends and provide assurance that the intended outcomes of the framework continue to be achieved.
07
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089. BGN perform the System Operator functions on behalf of Gaslink.
Regulated Natural Gas UndertakingsAs stated, under the provisions of the 1999 Act, as amended, the CER has the responsibility to regulate the activities of NGU’s with respect to safety.
each ngu is required to submit a safety case to the Cer for its review, assessment and acceptance. to assist the undertakings in the development of their respective safety cases, the Cer published the natural gas safety regulatory framework safety Case guidelines (Cer/07/226) in 2007.
in table 1 below a list is provided of entities who have submitted safety cases that have subsequently been accepted by the Cer.
Undertaking/Licence Transmission Distribution Gas Storage Shipper/Supplier
BGN9 ✔ ✔
PSE Kinsale Energy ✔
Bord Gáis Energy ✔
Gazprom ✔
ESB PowerGen ✔
Manx Electricity Auth. ✔
Energia ✔
Flogas ✔
Airtricity ✔
Tynagh ✔
Aughinish Alumina ✔
Huntstown ✔
Phoenix Energy ✔
Vayu ✔
ESB Independent Energy ✔
Electric Ireland ✔
Statoil ✔
TABLE 1 aCCePteD gas safety Cases
no new safety cases were submitted to Cer in 2012 for assessment. Monitoring compliance with existing safety cases and industry best practice includes a requirement for undertakings to complete an independent audit of their safety Case every 3 years (triennial reviews), or where the CER deems it appropriate to do so. The submission of the first Safety Case triennial review reports under the Framework occurred in 2012. Additional Undertakings are due to complete the Triennial Review process in 2013. The complete first cycle of Triennial Reviews will be completed during 2014.
What is a Safety Case? as referred to above a safety case is a dynamic document that details operations carried out by the undertaking, the associated risks and the control measures put in place to manage these risks.
the Cer has developed and implemented a safety case regime (see safety Case guidelines Cer07226) that is based on an assessment of risk and outcomes but flexible in the approach to the management of ‘lifecycle gas safety’ and not driven by prescriptive regulation. Although the safety
09
related responsibilities and activities for different gas undertakings vary according to the nature of the business, the differing safety information requirements are accommodated within a generic safety case structure that comprises the following key sections:
• a facility description: including a description of the business and it’s activities
• a formal risk assessment• a safety management system• emergency procedures
the Cer assesses the content of a submitted safety Case in accordance with a process and criteria outlined in the published safety Case Assessment Manual (CER08044). When the CER is satisfied that the submission fulfils the criteria and that risk management to ALARP levels (‘As Low As Reasonably Practicable’) is demonstrated by the ngu, the Cer formally accepts the safety Case.
Material Changes to safety Casesa material change is where an undertaking is of the view that the nature of a proposed change to its safety arrangements will increase the inherent risk and therefore they are required to submit a report of the proposed change along with an impact and risk assessment to the Cer for assessment before the change can occur. the material change process is detailed in the safety Case guidelines (Cer/07/226) and the purpose of the Material Change process is to ensure that changes within an organisation are planned and controlled appropriately with safety as a priority. Planning changes includes the need to determine the scale of a proposed change and all potential impacts. Where impacts are identified they must be reviewed, a risk analysis is performed. Significant changes to the business, or situations where risk levels need to be reviewed or adjusted, can lead to the proposed changed being deemed material to the safety Case. all Material Changes must be notified to CER in advance of the change being implemented and approval granted by the Cer before the change can be effected. the Cer will only accept a material change where the undertaking has demonstrated that the risks continue to be controlled to alarP (‘as Low As Reasonably Practicable’) levels.
The Gas Safety Framework Reporting Regimethe reporting regime required under the framework is comprised of three core elements:
• incident reporting• Quarterly Performance reports to the Commission• annual report to the Minister on the operation of the natural gas
safety regulatory framework
this data facilitates the Cer in assessing the on-going performance and effectiveness of the framework and thereafter to make positive interventions to amend the framework where necessary.
incident reportsunder legislation bgn must report incidents arising from gas assets to the Cer. the incidents are categorised into types depending on the outcome of the incident. Currently there are 3 “types” defined: type a (incident resulting in a fatality), type b (incident resulting in hospitalisation) and type C (incident resulting in property damage). under Cer guidelines, bgn also report incidents to the Cer that may be valuable in identifying issues that can be addressed to prevent an incident occurring.
incidents are also investigated by the Cer to determine causes and therefore identify corrective and preventative actions that need to be carried out to ensure similar incidents do not happen. outcomes of investigations can also be used with other performance indicators to form a broader view for Cer of gas industry risks. this view also informs planned audit and inspection activity for subsequent periods. the outcomes of investigation can also form the basis of corrective and enforcement actions undertaken by Cer in respect of undertakings.
Quarterly Performance reportsbgn is required to report to the Cer on a quarterly basis regarding the safety performance of the transmission and Distribution system. all reports were received in 2012. an overview of the data and trends is presented in the section ‘Performance of the Framework’ in this report. gas safety reports are developed every quarter by Cer energy safety Division utilising the data from the bgn reports, and formally presented to the Commission. Incident data, KPI’s, audit findings and inspection details are reviewed continually within the Cer energy safety Division. Pertinent issues are also discussed at the industry gas safety Committee10 or with the rgii, as relevant. all of the data is utilised to inform future safety campaign initiatives and Cer audit or inspection activities. this has resulted in a range of safety campaigns and improvements being implemented. notable initiatives during 2012 included a high profile Carbon Monoxide Awareness Week in september and targeted domestic meter installation inspections following emergence of a safety issue in this area. these initiatives are explained further in later sections of the report.
annual reportthe annual report on safety to the Minister summarises the performance of the industry on a yearly basis and allows trends between reporting periods to be presented. Where necessary any issues of concern or positive safety outcomes can also be highlighted.
audit and inspection reportsadditionally, the framework encompasses an audit and inspection regime, comprising planned visits or reactive visits to undertakings by Cer inspectors. these audits and inspections themselves provide information on the overall picture of risk management among undertakings. all data is monitored and reviewed by Cer on a systematic basis to coincide with undertakings’ reporting frequencies.
10. CER, BGN Gaslink and DCENR meet quarterly to discuss gas related incidents and issues, to discuss learning outcomes and to determine
corrective and preventative actions.
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The Gas Safety Supervisory Body (GSSB)as stated, the Cer has appointed the register of gas installers of ireland (rgii) as the gas safety supervisory body. its main function is to maintain a list of registered gas installers (rgis). other key functions of the rgii are outlined below: • receive, process and evaluate applications for registration from
installers; • register installers and publish the register of installers; • Monitor, inspect and audit installers; • investigate gas safety related complaints; • Discipline installers as required; • Administer the gas safety certification process; • Administer a “Notification of Hazard” (NohZ) process; • Perform promotion and awareness functions; and • Communicate and liaise with relevant bodies e.g. Health and
safety authority (Hsa), national standards authority of ireland (NSAI), Quality and Qualifications Ireland (QQI) etc.;
it is a legal requirement that any party carrying out domestic natural gas or domestic liquid Petroleum gas (lPg) works be registered. the requirements came into effect for natural gas and lPg on the 26th of June 2009 and 27th of June 2011, respectively. the Cer has completed three prosecutions of unregistered parties that carried out gas works. Details are provided later in this report.in order for any party to become a registered installer they must meet minimum criteria (relating to qualifications and insurance) as set out in the CER‘Criteria Document’ (CER/08/130).
the rgii reports to the Cer on a quarterly basis regarding the performance of the scheme. all reports were received in 2012. an overview of the data and trends is presented in the section ‘Performance of the Framework’ in this report.
CER Gas Safety Teamthe operation of the framework is monitored and managed by technical, safety, legal and regulatory personnel based within the Cer energy safety division who report to the Commission. the structure of the gas safety team is as follows:
Commission
Director of Energy Safety
Chief TechnicalAdvisor Gas Safety
Technical Avisory Panel
Senior InspectorTransmission
Assets
Senior InspectorDistribution/LPG
Assets/Installations
Outsourced Independent Auditors for Storage, LNGTransmission, Distribution, Shipper/Supply
TechnicalAnalyst
TechnicalAnalyst
TechnicalAnalyst
TechnicalAnalyst
Outsourced IndependentAuditors for GSSB
SafetyAnalyst
ManagerGas Safety Regulatory
Framework
ManagerGas Safety Supervision
Figure 2: GAS SAFETY TEAM ORGANISATION CHART
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as previously indicated the natural gas safety regulatory framework is a dynamic and evolving framework, outlining the safety regulation of the natural gas industry in ireland. expansion and amendments occur as a response to legislative changes, such as Cers new responsibilities for lPg in 2012, entry of new undertakings to the market and following Cer review or update of the various operational components of the framework.
Developments in Framework in 2012the energy (Miscellaneous Provisions) act 2012 (the 2012 act) was enacted during april 2012 with sections 17, 18 and 19 relating to lPg Distribution networks commenced in January 2013.this legislation gives the Cer powers to regulate and licence lPg undertakings, issue safety permits to these undertakings, and requires lPg undertakings to report incidents to Cer. Cer was also given additional responsibilities with respect to promotion of safety awareness with respect to lPg and greater safety enforcement powers overall.
Developments in 2013
Cer is committed to advancing a project during 2013 to give full effect to its new responsibilities as outlined above within a revised framework. the framework will be revised to include the expanded functions under electricity regulation act, 1999, as amended by the energy (Miscellaneous Provisions) act, 2012 (the 2012 act).
Specifically regarding LPG, the CER will have a remit in relation to:
• licensing of lPg undertakings.• investigation of all lPg incidents• Promotion and Public awareness of risks associated with lPg
additionally, the enforcement powers of the Cer regarding both natural gas and lPg are expanded under the 2012 act. these will also be incorporated into the Framework and act to significantly reinforce and strengthen the CER’s role and powers as Energy Safety regulator. the new enforcement powers provided include;
• the right to issue a natural gas or lPg undertaking with a request for an improvement plan;
• an improvement notice;• a prohibition notice; and, • to prosecute in relation to specific offences carried out under
the act.
the gas safety framework Consultation Paper (Cer/13/029) published in January 2013 begins the process of integrating new lPg and enforcement powers into the framework.
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DeveloPMent of fraMeWorK
12
Kinsale
Kells
Tipperary Town
Macroom
Bandon
Primarily, three main categories of monitoring are undertaken by Cer as part of the framework, which assists in informing a view on its effective operation. the types of monitoring comprise proactive and reactive monitoring and compilation of KPI’s both reporting and examining trends. Proactive monitoring through measures such as planned audit and inspection of undertakings seeks to identify any safety issues, in advance of any associated incidents arising. this allows controls to be implemented that eliminate issues in advance of occurrence. reactive monitoring happens following the occurrence of an incident or other similar event and subsequent Cer investigation leading to a course of action. the main purpose is to ensure that appropriate and required follow up actions happen, including the identification of ways to prevent recurrence and to ascertain any improvements required to the framework in the future.
KPI measurement includes identified indicators that are both proactive (leading indicators) and indicators that are reactive (lagging indicators) with associated performance targets. Performance and trending against these targets allows a view regarding on-going maintenance of safety performance levels to be reached by those undertakings regulated through the framework.
the following table outlines the elements within each category of monitoring and provides an overview of the means by which Cer executes the relevant activity.
CATEGORY ELEMENT OVERVIEW
Proactive Monitoring I. Audit Programme
II. Inspection Programme
III. Safety Case Management Programme
IV. Emergency Response Programme
Audit NGUs versus their Safety Case.
Inspect DSO and TSO activity.Inspect RGIs.
Assess and accept new Safety Cases.Assess and accept Material Change submissions.
Monitor the emergency response programme of NGUs.
reactive Monitoring I. Incident Reporting Regime
II. Energy Customer Complaints
Investigate incidentsReview reports and outcomes
Enforcement actions associated with Illegal gasworks
kPi Monitoring KPI Reporting Regime BGN report on a suite of leading and lagging safety performance indicators
TABLe 2 AUDIT AND INSPECTION MONITORING PROCESS
Monitoring of tHe fraMeWorK
Kinsale
Kells
Tipperary Town
Macroom
Bandon
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Proactive Monitoringaudit Programmeannually the Cer agrees as part of its work programme a schedule of audits to complete which includes audits of all ngus, (including gas shippers and suppliers) and also audits of the rgii.
eighteen audits in total were conducted in 2012. this included 3 audits of bgn (performing functions of transmission system operator (tso) on behalf of gaslink), 3 audits of bgn (performing functions of Distribution system operator (Dso) on behalf of gaslink) and 12 shipper/supplier audits. three shipper/supplier audits were deferred to Q1 2013 due to the timing of the undertakings triennial reviews. as the triennial review is a comprehensive audit undertaken by a third party of the undertaking, the Cer determined that carrying out a second audit of the undertaking at a time so close to the triennial audit would not be a productive use of time and resources.
Audit Programme
CoMPleteD auDits 2012
Q1 Q2 Q3 Q4
scheduled audits
natural gas undertakings
bgn tso ✔ ✔ ✔
bgn Dso ✔ ✔ ✔
bord gais energy Deferred to Q1 2013
flogas ✔
airtricity ✔
Phoenix Deferred to Q1 2013
vayu ✔
tynagh ✔
gazprom ✔
Manx ✔
esbie ✔
esb Powergen ✔
energia Deferred to Q1 2013
aughinish alumina ✔
Huntstown ✔
electric ireland ✔
statoil ✔
Pse Kinsale energy Deferred11
TABLE 3 OVERVIEW OF AUDITS CARRIED OUT IN 2012
transmission and Distribution system operator audits 2012 Management of Change – August 2012the aim of this audit was to establish that bgn have adequate internal methods, processes and procedures to manage and evaluate safety and technical change. the audit investigated how emergent issues are identified within BGN, which may have a positive or negative safety impact on the undertaking. the audit found that BGN have significant resources employed in a range of scenarios to monitor for any risks to safety that may emerge due to changes. recommendations were made regarding overall policy documents, consistency regarding managing change across all business areas and recording positive change where necessary.
Risk Assessment - October 2012the audit sought to establish that bgn have adequate internal methods, processes and procedures to manage and evaluate safety risks. the audit also covered how risks are managed and monitored to ensure the business meets its strategic objectives. recommendations include review of policy documents to ensure suitability, records management and the better utilisation of records and data for risk reviews.
Natural Gas Emergency Plan – December 2012the audit sought to determine that the current exercises, training and plans employed meet the requirements of the september 2011 natural gas emergency Plan (ngeP). the principle document which provided the basis for this audit was the natural gas emergency Plan version 2.0 dated september 2011. a number of recommendations were made regarding better utilisation of the gas emergency Planning group, document control, emergency triggers, training and internal audit plans.
audit of shippers/supplierstwelve of the 16 shipper/ supplier audits were carried out during 2012. three were deferred due to the timing of their triennial reviews. the purpose of these audits is to ensure compliance with the submitted Safety Case. General findings included the need for formal document control procedures to ensure that the Safety Case is live and reflects the business at all times.
audit of the rgii (gssb)While an audit took place in 2011, the Cer did not carry out an audit of rgii in 2012. the Cer is in the process of engaging independent auditors to conduct an audit of the rgii in 2013 to provide assurances regarding its compliance with the published Criteria Document (Cer/08/130) which governs and describes rgii role as gas safety supervisory body (gssb). recommendations will be discussed with the rgii and implemented as necessary in 2013.
11. Audit of PSE Kinsale Energy planned in 2014 under the Petroleum Safety Framework.
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inspection Programmeannually the Cer agrees as part of its work programme a schedule of inspections to be carried out on, both the transmission and Distribution systems operated by bgn. the inspection programme will be based on areas identified in the risk assessment in the undertakings Safety Cases. Issues identified through quarterly reports and incidents may also contribute to the development of the annual inspection programme.
Inspections of Transmission System Operatorin 2012 a detailed risk based inspection programme for the transmission network was developed and commenced. The first 3 inspections from this programme were carried out in 2012, these were:
• Landowner Liaison – examining how well bgn liaise and communicate with landowners where transmission pipelines are routed through.
• Aerial Marker Posts – ensuring posts marking the route of transmission pipelines are in position and maintained as required.
• Cathodic Protection – ensuring the anti-corrosion protection system is operating as required to prevent degradation of transmission pipelines due to corrosion.
the recommendations from the 2012 inspections included such items as the installation of additional marker posts, rectification of cathodic protection issues and changes to regular communications with landowners. all items were submitted to bgn and are being progressed to completion by bgn.
year location area of inspection inspection type
2012 national Cathodic Protectiontransmission
inspection
2012 regional aerial Marker poststransmission
inspection
2012 regional landowner liaisontransmission
inspectionTABLE 4 OVERVIEW OF INSPECTIONS CARRIED OUT ON TRANSMISSION SYSTEM OPERATOR
in 2013 12 inspections are planned. further inspections may be carried out based on emerging issues or to avail of specific opportunities as they arise, such as construction projects and online inspection activities that do not occur frequently.
Inspections of the Distribution System Operatorgas Distribution inspections for 2012 focused on key areas of concern highlighted within the Safety Case or identified during previous audits conducted by the Cer. there were 36 in total and these included and focus on:
• Meter installations – examining the location and the correct support of installations.
• Utility damage - investigating causes of damage to gas distribution pipework such as third party strikes.
• Safe digging practices – inspecting bgns processes and procedures for digging around gas pipelines.
• Polyethylene welding - focusing on procedures and practices for gas pipe welding preparation and cooling times.
• Emergency stores - examining bgn emergency stores located around the country where equipment and materials are stored to allow efficient fixing of leaks.
of the total of 36 inspections which took place (see table below for detail) at various locations on the gas network, 12 of these inspections were planned with the remaining inspections associated with issues arising.
year: location: area of inspection: no. inspection type:
2012 CorkDomestic gas
service installation6
Distribution inspection
2012Co.
WicklowDistribution gas Meter installation
1Distribution inspection
2012 DublinDistribution gas (low Pressure)
Meter installation16
Distribution inspection
2012 regional emergency stores 4Distribution inspection
2012 galwayPolyethylene
Welding Procedures1
Distribution inspection
2012 regionalsafe Digging
Practices8
Distribution inspection
TABLE 5 overvieW of insPeCtions CarrieD out on Distribution systeM oPerator
there are 12 gas Distribution inspections planned for 2013. again this may be supplemented due to additional work projects or areas of concern raised outside of the inspection process (e.g. trends noted in the quarterly KPi reports).
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inspections carried out by rgii (gssb)the rgii is required by the Cer to monitor and inspect rgis. it schedules inspections in line with the requirements of the published Criteria Document (Cer/08/130). the target is to inspect each member on an annual basis (2,969 registered gas installers at the end of 2012).
During 2012 the rgii planned to execute 2,995 routine inspections of RGIs. A final routine inspection figure of 2,859 was achieved, 4.5% below plan. installers not inspected in 2012 will be concentrated on in 2013.
in 2013 all installers will receive a minimum of one inspection per year however this will be increased to two inspections for some rgis based on the outcome of previous inspections. these additional inspections will require the recruitment on an additional part time inspector in 2013. the appointment of the part time inspector will facilitate the introduction of unscheduled inspections of rgis by the rgii.
in 2013, it is envisaged that the rgii will carry out 3,358 inspections.
safety Case Management ProgrammeMaterial Change Submissionsno new safety cases were received for assessment by Cer during the reporting period. one material change submission on emergency standby rota was received from bgn by the Cer in 2012, for evaluation as detailed in table 6 below. two material change submissions received in 2011 were accepted in Q1 2012 and a submission received in 2011 continued through assessment in 2012 see table 6 below.
area of change received from:
Date of first notification of
intended change
Date accepted
networks services Works
Contract (nsWC)
bgn January 2011 february 2012
Change of ownership
(Marathon oil to Petronas)
Kinsale energy
april 2011 March 2012
leak survey Policy
bgn July 2011 assessment on-going
emergency response rota
bgn february 2012 assessment on-going
TABLE 6 Material Change submissions
a summary of the changes is presented below. assessment of a material change is completed by Cer in accordance with the safety Case assessment Manual (Cer08044).
I. Networks Services Works Contract (NSWC) – January 2011in January 2011 bgn proposed changes to its nsWC. the plan involved the amalgamation of 19 individual contracts into 1 contract and also extending the duration of the period contract from 5 to 10 years. following a formal submission by bgn, the Cer determined the change to be material to the Safety Case in October 2011. In the first quarter of 2012 the CER received and accepted the finalised material change report applicable to the nsWC prior to the mobilisation of the contract. Extensive verification was carried out involving a number of follow up meetings and correspondence to ensure all relevant safety controls were in place and effective during the transition.
II. Storage Safety Case (SSC) – April 2011following a change of ownership from Marathon oil to Pse Kinsale energy in 2009, a revised safety case was submitted in april 2011 for the Kinsale facility. Consultants were engaged by Cer to assess the material change and the Cer reviewed and accepted the safety Case in March 2012.
III. Leak Survey Policy – July 2011in July 2011 bgn outlined proposed changes to its leak survey policy. the proposal was to move from frequency based surveys to risk based. an impact assessment and associated risk assessment were submitted for consideration in september 2011. a number of further submissions were made during 2012 for evaluation. this is expected to be finalised in 2013.
IV. Emergency Response Rota – February 2012in february 2012 bgn outlined proposed changes to its emergencyresponse rota to Cer. the proposal was to remove obsoleteroles and also to reflect structural changes due to the Networkstransformation Programme (ntP) project. the changes also includedeliminating the possibility of an individual being on call on multiplerotas. In April 2012 BGN made their first written submission on theproposed change. a number of revised submissions have beenmade by bgn and evaluated by the Cer. this is expected to befinalised in 2013.
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emergency response Programmethe natural gas emergency Plan (“the ngeP”) is prepared by bgn on behalf of gaslink under the direction of the Cer and in consultation with the gas industry, the electricity industry and government. the purpose of the plan is to establish procedures to be followed in the event of a natural gas emergency in ireland.
a number of emergency exercises are carried out each year, in order to test the procedures outlined in the ngeP. bgn undertook five exercises during the year 2012. One NGEP exercise included the Cer and the Department of energy Communication and natural resources (DCenr). the remainder of the exercises were bgn internal exercises.
• NGEP exercise “titan” 19th 20th september – Q3 • Crisis Management Plan (CMP) exercise – Q2• Contacts list for large Daily Metered (lDM)
consumers exercise – Q2 • sCaDa systems disaster recovery exercise – Q2 • transmission operations response (urban Dublin area).
Part of joint tso Dso exercise “Colt” - 25th september – Q3
Cer is also a member of the all-island emergency group, which reviews safety issues underpinning load shedding arrangements in both jurisdictions of the island. this committee is chaired by DCenr and members include representatives of the Cer, bgn, bgeuK, gaslink, Detini, Phoenix natural gas & Mutual energy ltd. it was agreed that the principles governing the safe operation of the systemcan and should be articulated in a streamlined manner using common terminology across both jurisdictions. issues discussed at this forum relate primarily to european regulatory requirements associated with security of supply and emergencies on the island of ireland.
in 2011 gaslink and bgn arranged a shipper-supplier forum meeting, the purpose of which is to meet and ensure that shipper and suppliers are aware of their responsibilities and role in the event of a gas supply emergency. The meeting is co-ordinated by BGN’s national gas emergency Manager (ngeM). bgn have 3 people trained to carry out the role of the national gas emergency Manager. the shipper-supplier forum did not meet in 2012 due to a delay in the planned update to the ngeP. it is anticipated that forum will meet again 2013 when an updated ngeP is ready and available for communication.
the gas emergency Planning group (gePg) Chaired by the national gas emergency Manager (ngeM) met in august to review issues such as how shippers and suppliers take instructions from the ngeM in a gas supply emergency and also to plan participation in the neC (uK) led gas supply emergency exercise (exercise “titan”) The intention of the GEPG was to ensure that maximum benefit from participation in the exercise could be gained and that it also involved all relevant participants.
Reactive MonitoringCer also monitors undertakings performance with regard to safety through its reactive investigations of incidents which informs the evolution of the framework.
incident reporting summary 2012the criteria for natural gas incident reporting have been established and operational for a number of years, which requires bgn to report certain incidents to Cer. reporting requirements and incident categories are set out in legislation; s.i. no. 196/2003 — gas (amendment) act 1987 (section 2) (Distribution) order 2003.
the Cer also has criteria for ‘reportable under guidelines12’ (RUG) gas incidents where, in the interests of learning, less significant gas incidents are analysed and reviewed. in previous reports, such incidents were referred to as “non-reportable” incidents. a brief summary of the reportable incidents during 2012 and others investigated by, or of interest to, the Cer are outlined below.
* Denotes incident type: • a – involves a fatality; • b – injury requiring hospitalisation; • C – property damage in excess of €6,350 • (RUG) Reportable Under Guidelines as defined in procedures
issued annually by the Cer to undertakings.
incident investigations:
Incident Location Date Type*
leixlip, Co. Kildare. 14/01/2012 b
boot road, Dublin 22. 16/01/2012 rug
Kent station, Cork. 24/02/2012 rug
Church rd, Mulhuddart, 17/10/2012 rug
forbes street, Dublin 2. 13/12/2012 rug
safety investigations:
Portabello Wharf, Dublin. 25/05/2012 rug
iona road, glasnevin, 31/07/2012 rug
TABLE 7 INCIDENTS AND SAFETY INVESTIGATIONS IN 2012
12. The CER provides guidance to BGN in a documented procedure to be followed by BGN for Reporting & Investigation of Gas Safety
Incidents to the CER. This document gives detailed guidance on what may constitute Reportable Under Guidelines (RUG).
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Reportable IncidentsIncidents Upstream of the Meterthere was 1 reportable incident reported to the Cer in 2012 as indicated by the type b incident in table 7. the incident is summarised in the following section.
Incidents Downstream of the MeterDuring 2012 there were no incidents downstream of the meter.
I. Leixlip, Co Kildare – January 2012a gas explosion occurred at a domestic premises in leixlip on the 14th January 2012. the dwelling was a semi-detached house. three houses were evacuated following the explosion and two people were taken to hospital with serious burn injuries. the incident was reported on various national media. the house and adjoining house were damaged. the investigation of the incident by Cer who are working with Hsa in this regard is on-going.
Reportable Under Guidelinesthere were also 4 ”reportable under guidelines” incidents reported to the Cer safety Division. these are summarised as follows;
I. Boot Road Dublin 22 – January 2012third Party Damage incident occurred that was caused by a directional drilling operation by a telecoms company. a 125mm Polyethylene 4 bar main was damaged when the contractor failed to correctly identify the location of the gas main before starting to drill. this led to the closure of boot road (old naas road) Clondalkin Dublin 22 for a number of hours during the repair. low levels of gas were detected in a Hotel that required ventilation and monitoring but not evacuation of the hotel.
II. Kent Station Cork – February 2012on the 24th of february contractors carrying out repairs to the roof of Kent station drilled through a 40mm diameter track pipe downstream of the meter which was supplying two wall mounted blow heaters. this led to a gas leak on the downstream pipe work and subsequently to the evacuation of the train station by the fire crews and station management.
III. Church Road, Mulhuddart – October 2012on the 17th of october 2012, a third party strike of a steel gas main occurred during excavation works. there was a large release of gas in the Mulhuddart/ tyrrellstown area of Dublin 15 over a period of 9 hours. approximately 550m of the 200mm diameter steel 4 bar gas main was isolated resulting in a loss of gas supply to 157 properties. these properties remained off gas overnight whilst a steel pipe repair crew and materials completed the repair.
IV. Forbes Street Dublin 2 – December 2012a leak was reported on a valve on the transmission system outside forbes street agi on the 13th of December 2012. the leak was minor and the repair was completed that evening.
Safety InvestigationsDuring 2012 the Cer also investigated 2 technical issues that were not associated directly with natural gas incidents.
I. Portabello Wharf, Dublin – May 2012The CER was first made aware of the gas appliance flue installation issues at this property on friday 25th May 2012. an inspection was carried out on May 25th to review the installation of flues and a number of natural gas boilers within the apartment complex. the Cer inspected the site again on tuesday 29th of May. in order for gas supply to be restored to the affected apartments changes were made to the flues and boiler installations.
II. Iona Road Glasnevin – July/August 2012a property owner contacted the Cer concerned about the safe installation of the gas meter at her property. an inspection of the installation took place on 2nd august 2012 with the property owners. the property was made safe and refresher training provided to the installer. the Cer carried out a number of inspections of similar properties in the area which flagged other customer installation issues. BGN and the CER have reviewed the findings and as a result coordinated a meter installation working group to examine issues related to meter installations. this work will continue in 2013.
Enforcementsthere were no enforcement actions with respect to the operation of the framework in 2012. this would be enforcement actions relating to issues upstream of the gas meter.
enforcement actions by Cer with respect to the gas installer regime are outlined in the paragraph below.
in order to complete gas works legally relating to a domestic appliance, it is a legal requirement to be registered with the rgii. unregistered parties that complete gas works relating to a domestic appliance may be fined €15,000 or imprisoned for up to 3 years or both. The CER appoints Gas Safety Officers to investigate cases where gas works may have been completed by unregistered parties.
in 2012, 38 cases relating to non-registered parties carrying out gas works were investigated by Gas Safety Officers. Of these cases, 25 were closed due to insufficient evidence, 10 were closed as the installer was registered, and three remain open for investigation. these investigations are actively being progressed and may result in the prosecution of individual parties in 2013.
Prior to 2012, 61 cases relating to non-registered parties carrying out gas works were investigated by Gas Safety Officers. Of these cases, 55 were closed due to insufficient evidence or the installer being registered, three resulted in successful prosecutions, and three remain open for investigation.
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in 2012 the Cer completed two successful prosecutions for illegal gas works pertaining to investigations from 2011. these prosecutions were against persons carrying out gas works in Cork and limerick while not being registered as a gas installer.
Prior to 2012, there was one prosecution for illegal gas works. this prosecution was against an individual carrying out gas works in Kildare on the 15th november 2010 while not being registered as a gas installer.
Prior to 2012, the CER had appointed one Gas Safety Officer for the purpose of investigating alleged offences by unregistered installers. in an effort to devote resources to the area of illegal gas works, an additional Gas Safety Officer was appointed in 2012. Both are RGII staff members/contractors.
in addition, the rgii has engaged a private surveillance specialist to assist in monitoring of installers who have been removed from the register. this monitoring commenced in early 2013.
the energy (Miscellaneous Provisions) act 2012 (the 2012 act) commenced in 2012 gives the Cer extended powers in relation to regulation of lPg undertakings and greater enforcement powers with regards to natural gas and lPg undertakings. as previously stated in this report, the consultation paper gas safety regulatory framework for ireland Cer/13/029 published in January 2013 begins the process of amending the framework to give effect to these new powers. advancing this work is a priority for Cer in 2013.
Key performance indicators - Reporting & Trendingin order to measure the extent to which the objectives of the framework are being achieved, the Cer has developed a suite of key safety performance indicators (KPI)’s for each of the Key Objectives.
as previously stated, the main components of the framework are monitored using this set of defined leading and lagging performance indicators. results are provided quarterly by the gas network system operators (both tso and Dso) and the safety supervisory body (rgii). review, analysis and trending of this data is completed by Cer in order to determine the extent to which the Key objectives are being met. Detailed data for the reporting year can be found in the section “Performance of the framework”.
During 2012 the on-going review of trends, incidents and operational issues highlighted the need for clarity with regard to data on external leaks and outstanding cathodic protection faults on the network. this resulted in an inspection on cathodic protection and clarifications were sought regarding external leaks not classified. These issues are being addressed by bgn and continue to be monitored through KPi reporting.
a summary of the performance levels for 2012 Key Performance Indicators when compared to the corresponding figures in 2011 are as follows:
✔ Dso Public reported escape levels down by 7.3%.✔ Pipeline third party encroachment down by 14.3%.✔ external gas escapes down by 15.7%. ✔ third party pipe damage was down by 16.2%.✔ rgi membership up by 4.4%.✔ 99.9% of public reported escapes were responded to within 1hr.✔ Carbon Monoxide website hits remained relatively high compared
to previous years.✘ number of long term Cathodic Protection system faults increased
in 201213. ✘ Level of unclassified leaks14. These are leaks not classified as
occurring on gas mains or service pipes.✘ Transmission System Operator (TSO) Reported Escapes’
increased from 2 in 2011 to 9 in 2012 .✘ network outages increased from 1 in 2011 to 2 in 2012 affecting
242 customer properties15.✘ safety Disconnections increased by 1% from 2011.
a full summary of the performance data is incorporated in the section entitled “Performance of the framework: Performance against safety objectives: 2012”. the Cer response to addressing any trends is also outlined in this section.
13. Cathodic Protection is used on both the Transmission and Distribution Systems to prevent corrosion of steel pipework. This is discussed in more
detail later in the report under performance of the Framework.
14. The majority of unclassified leaks are occurring at meter installations.
15. In 2012 reported escapes on the transmission system were reported by BGN employees and Contractors as well as by the public, which may have led
to higher levels of reported escapes.
19
Other monitoring activitiesreporting to the Commissionas stated Quarterly Performance reports are prepared by the Cer energy safety Division and formally presented to the Commission. these reports provide an overview of the performance of the framework and the gas safety supervisory body/rgii scheme. the compilation of this information provides the basis for this annual report and allows comparison with preceding years. the overall picture regarding the performance of the framework arises from these reviews.
stakeholder Management & governance regular meetings are held to discuss natural gas safety issues on an on-going basis with all relevant stakeholders including bgn, gaslink, shippers / suppliers, rgii and the DCenr. Wider industry stakeholders such as the national standards authority of ireland (nsai), the Health and safety authority (Hsa), Consumer groups and associations are also involved in communications on safety with Cer as required.
the Cer is supported in its work by a number of safety governance groups. the gas safety Committee (gsC) attended by Cer, bgn, gaslink and DeCnr, which meets 3 - 4 times a year to discuss gas related incidents and issues, to discuss learning outcomes and to determine corrective and preventative actions. the tso Dso interface group is attended by Cer, gaslink and bgn on a quarterly basis to discuss progress on all major safety related work items and safety related operational issues. items also discussed at these groups involve on-going management of safety cases,infrastructure campaigns such as the meter replacement programme, ridge tile campaign etc. international and domestic incidents, review of material change submissions, audit and inspection updates and promotion and public awareness campaigns.
gas safety Promotion and Public awareness (PaPa)increasing gas safety awareness is an integral part of the framework objectives as the Cer has gas safety promotion and public awareness statutory obligations under the 1999 act, as amended.
the Cer energy safety Division in conjunction with an industry group the gas safety Promotion and Public awareness group (PaPa), chairs and oversees the development and review of national gas safety promotion and public awareness activities. the members o the group are outlined below.
Key Stakeholders
bord gais networks
registered gas installers of ireland
(rgii)
electric ireland
Calor
flogas airtricity bord gais
energy
irish Liquefied Petroleum
gas association
(ilPga)
national standards authority of ireland
(nsai)
Commission for energy regulation
(Cer)TABLE 8 gas safety ProMotion anD PubliC aWareness grouP - staKeHolDers
the activities of this group include discussion and decisions on all related media promotions, safety surveys, public awareness initiatives and promotions external to the industry.
the scope of activities in 2012 included areas such as:• Register of Gas Installers – promoting the use of an rgi in
domestic environment when having appliances replaced, repaired or serviced.
• Gas escape awareness – promoting the reporting of gas escapes to the 1850205050 emergency number.
• Safe use of gas – highlighted through tv, radio and national press.
• Utility damage prevention – the “Dial before you dig” campaign communicates the need for third parties to locate utilities and exercise great care before starting any excavation or digging work. this campaign aims to prevent both personal injury and damage to gas services and mains.
• Carbon Monoxide – raise awareness of the dangers associated with Carbon Monoxide poisoning and communicate preventative measures.
the key objective of the overall PaPa Programme is to achieve thefollowing 5 outcomes:• increased levels of general public awareness of gas safety issues;• greater willingness among the general public to take preventative
actions with respect to gas safety;• greater willingness among the general public to take positive
actions with respect to gas safety; • High levels of awareness of, and confidence in, the Register of Gas
installers amongst the general public and the installer industry; and
• Raised levels of general awareness of the Commission’s role as the regulatory authority for gas safety matters in ireland.
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2012 Programme of Promotion Campaignsthe 2012 programme continued with the existing advertising activity as outlined and also continued focus on developing awareness among general public of the registered gas installers (rgi) scheme and Carbon Monoxide (Co) safety. one of the highlights of the 2012 campaign was the Carbon Monoxide awareness Week held in september, which is detailed later in the report.
the programme of campaigns used a range of mediums to develop public awareness and generally includes on an on-going basis:
• Carbon Monoxide awareness Week.• gas escapes awareness through tv, radio and national press.• Carbon Monoxide awareness and prevention with tv, radio,
leaflets, posters, national and local press.• Promotion of the rgi scheme and the need to use a registered
gas installer through tv (as part of the Carbon Monoxide advert) radio, national press and identifiers for registered installers vans (rgi logo).
• increased vigilance when working in the vicinity of buried gas apparatus through national and local press and trade journals.
• advertising of emergency details, advice and contact information in journals and the golden pages.
• instructions to landowners with gas pipelines on their property through on site advice, liaison and instruction leaflets.
• Gas safety leaflets circulated with gas bills.
Carbon Monoxide Awareness WeekThe year saw the first Carbon Monoxide Awareness Week occurring the last week in september. the week was organised and supported by a wide range of industry and regulatory participants and featured people affected by Carbon Monoxide. a logo and 3 key messages were designed and developed to create awareness of the main dangers of Carbon Monoxide.
FIGURE 3 Carbon MonoxiDe aWareness WeeK logo 2012
• remember the causes: Carbon Monoxide can be produced when any fuel is burnt, including oil, gas, wood and coal
• remember to service: to prevent Carbon Monoxide, have appliances serviced annually and keep vents, flues and chimneys clear
• remember the alarm: Carbon Monoxide is odourless and colourless so for added protection install an audible Carbon Monoxide alarm.
the awareness Week was formally launched by the Minister for Communications, energy and natural resources Pat rabbitte, Cer Commissioner, Paul Mcgowan and Cathal Hughes whose son Padraig sadly died from Carbon Monoxide poisoning at their home in rosbeg near Westport on Christmas Day, December 25th, 2008. also present at the launch were representatives from all participating companies and members of the press. the week continued with radio and tv interviews with technical experts and people affected by Carbon Monoxide delivering the key messages and relaying their experiences with Carbon Monoxide. TV interviews on TV3’s Ireland AM and the Midday programme formed an integral part of the awareness week. radio and newspaper adverts were also used to promote the key messages. all participating companies ran initiatives for the week to highlight issues to their employees and work colleagues, e.g. email signatures on internal and external mails.
the week greatly increased awareness of the dangers, symptoms, and preventative measures, while website hits did not reach the highs of Q1 2011 (experienced following the trident incident16), significant increases in the number of people logging onto the website were noted. such an increase has only previously been experienced following a fatality. this has been viewed by the awareness group as an indicator of success in raising awareness through a proactive campaign. it is intended that the awareness week will become an annual safety promotion event.
Other Carbon Monoxide InitiativesDuring 2012 Department of environment Community and local government (DeClg) supported by Cer and in consultation with the nsai and gas undertakings reviewed and updated Part J of the building regulations making Co alarm installation mandatory in all new houses.
additionally, bgn provided formal training to 514 rgis on Co alarm installation and also included a roll out of free alarms to trainees. the programme sought to ensure that Co alarms are installed correctly by competent persons and that alarms selected are compliant with the SWIFT 8 specification.
the campaign for the medical profession was continued in 2012. BGN provided leaflet and poster awareness adverts in GP surgeries, healthcare institutions and pharmacies. further information is available on the www.carbonmonoxide.ie website for download.
16. An incident in January 2011 at the Trident hotel in Kinsale Co Cork led to a fatality caused by Carbon Monoxide poisoning.
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Outcomes of the Overall Campaignbgn carry out an annual safety survey on behalf of Cer to determine the effectiveness of the on-going programmes and also provide comparison data for previous years. the annual survey for 2012 provided a body of information which was presented to the PaPa group in Q4 2012. there were a number of positive outcomes such as; more than half (53% - an increase of 8% on 2011)) of respondents are now aware of the register of gas installers of ireland (rgii). 95% of respondents are aware of the dangers of Carbon Monoxide (up 11% on 2004). Any learning’s from this survey will be addressed by the Cer and bgn in the 2013 promotion & public awareness campaigns.
2013 Programme2013 will continue to see an evidence based approach being applied to measure the outcomes of safety awareness campaigns through examining outcomes of campaigns and surveys in terms of increasing awareness. this includes the review of all messages by the PaPa group to ensure that they are effective and delivered appropriately Mini marketing surveys are also planned in addition to, or as replacement for, the current annual survey.
the topics and areas that were focused upon in previous years i.e. use an rgi for natural gas and lPg works in your home, gas escape awareness, utility damage protection, safe use of gas and Carbon Monoxide, will all be incorporated and addressed in the 2013 safety awareness campaign.
Meetings between the Cer and industry stakeholders will also be held at CER offices throughout the year to discuss the continued effectiveness and outcomes of the various awareness campaigns.
Carbon Monoxide awareness campaigns and messages 2013 the 2013 Co awareness Week will continue to create awareness of the dangers associated with carbon monoxide poisoning and communicate the preventative measures that the public should take. the dangers apply to all forms of fossil fuel use and so are not restricted solely to natural gas users. the primary message from the Cer remains the correct installation, servicing and maintenance of all appliances is critical to assure on-going safety and protection against Co.
outcomes of incident reviewas stated previously incidents and learning outcomes are reviewed by the industry gas safety Committee (gsC) with a view to ensuring that repeat incidents do not occur and safety framework continues to evolve and improve as needed. as a result, a number of campaigns and initiatives have been identified to prevent recurrence. initiatives are typically short duration single work activities whereas campaigns are typically extensive programmes of work that may take a number of years to complete. the following is a summary of existing campaigns and initiatives at the start of the reporting period, those closed within the period and also any new initiatives identified within the reporting year.
Campaigns: I. Campaign for the Elderly:this campaign was devised following a number of incidents associated with the elderly using gas appliances in 2010.the promotional campaign for gas safety with the elderly which was expected to run in 2011 and 2012 was revised to be a more general natural gas safety campaign with focus on the elderly. Progress was made in this area by meeting with groups such as age action ireland (aai), and the Health services executive (Hse). the 2013 media campaign will be designed to ensure greater targeted exposure to an elderly audience or their carers, through advertising using particular mediums.
II. Meter replacement (incorporating Annex E inspections):this programme being undertaken by bgn involves the replacement of an ageing population of gas meters throughout the country. Just over 32,000 meters were replaced in 2012 and this represents a significant number of replacements in the year. This programme of works is planned to be on-going in 2013. inspections have been incorporated into this work programme by bgn. the purpose of these inspections is to ensure that the installations are safe for continued operation. if faults are found, the meter installer can take the appropriate actions and issue advice to the homeowner where necessary.
III. The Ridge Tile Campaign:this campaign commenced in 2008 and relates to the safety of domestic installations which have gas boilers with operational ridge tile flues. A survey was conducted by BGN in 2010 and 2011 of over 23,000 homes. Many of the homes had updated heating systems and the ridge tile was therefore no longer in use. Where operational, concerns relate to the corrosion of the flue material which could result in a disconnection of the flue terminal from the ridge tile. Where disconnection occurs there is a risk of Carbon Monoxide (Co) entering the home. inspection and Co tests were carried out by bgn and Co alarms were installed in premises where operational ridge tiles were observed. The final phases of inspections were carried out by bgn in 2012. final communications with remaining customers will occur in 2013.
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IV. The Light Wall Pipeline Replacement Campaign:a review of light wall transmission pipelines took place in 2007 by bgn. Design factors, in particular, population density versus proximity to these pipelines were reviewed. increases in population density were highlighted as a risk by BGN and as a result identified a number of pipelines where additional protective measures or replacement were necessary to ensure on-going compliance with the relevant standards. a number of pipelines will be replaced, have had pressures reduced, or may be decommissioned as a result of this work. Specifically during 2012, replacement works were completed in Dublin 4 and replacement programmes for Waterford and also santry to east Wall projects commenced in 2012 and will be due for completion in 2013. a further replacement programme is also planned in limerick in 2013.
V. Explosive Atmospheres (ATEX)eu Directive 94/9/eC on explosive atmospheres requires relevant parties to produce an explosion protection document, and to have management systems in place with regards to atex. bgn have implemented a programme of work to ensure compliance with the legislation. bgn are in the process of conducting a full atex management system review. this will involve a number of project work elements covering both technical and organisational measures required for on-going atex compliance. a summary of the programme elements are as follows;
• revision and update of the current explosion protection document (ePD) and management system.
• full installation and maintenance compliance check for transmission and distribution assets.
the atex review programme will be monitored by the Cer during its implementation. the project is on-going into 2013.
VI. Bridge Crossings: after the incident at the Malahide estuary17, the Cer requested that bgn review bridge crossings in both Distribution/transmission networks to ensure adequate measures & controls are in force relative to a bridge risk assessment and gas safety. all bridge crossings have been identified and surveyed by BGN. A campaign of remedial works will be planned by bgn through 2013.
VII. Polyethylene (PE) Valves:following an incident in Co. Cork where a mechanical fault in a Polyethylene (Pe) valve resulted in a leak, a follow up survey was carried out by bgn to assess the full extent of the issue. as a result, an additional six leaking Pe valves were located on the network. it was decided to review all locations and in relation to these valves. these have been evaluated by bgn and a proposal to eliminate any issues was finalised. The project is on-going and due forcompletion in 2013.
VIII. Gas in porches:The Gas in porches campaign arose when BGN identified situations where external meter boxes with plastic pipe connections were enclosed in what had previously been open porches and covered entranceways. This results in an increase in the fire risk within the property. bgn have undertaken a programme of works to remove higher pressure installations from these locations. this work activity was completed during 2011. bgn developed and trialled solutions to manage the risk of lower pressure installations in similar situations in 2012. the installation of these new solutions will be approved and commenced in 2013.
IX. Copper Sulphidation: Where identified, RGIs will treat installations for copper sulphidation to prevent Copper sulphide blocking the pipework. Copper sulphide build up in the gas line can cause valve and burner blockages. in 2012, 50 installations were treated by bgn. this represents a reduction of 48% on the number of treatments (128) carried out in 2009.
Initiatives:initiatives are designed to help prevent incident reoccurrence and are usually initiated through the gas safety Committee. they are generally short in duration compared to campaigns that can continue for a year or longer.
I. RGII Technical Guidance Documentin november 2012, rgii launched their technical guidance Document for registered gas installers which outlines easy to follow steps on the installation and servicing of gas boilers. this document was distributed free to all rgis and promoted at four launch events in galway, Cork, Dublin south and Dublin north. the Cer understands that this document was well received by rgis and has contributed to the improvement of the scheme.
17. In April 2009 a bridge over Malahide estuary on the Dublin to Belfast train line collapsed just a after a train passed over it.
23
Performance against Safety Objectives: 2012
Key safety objective 1: Minimising the loss of Containment gas undertakings are required to demonstrate that they have suitable management systems and procedures in place for managing the risks that lead to loss of gas containment events occurring. Within the scope of this objective are:
• gas escapes reported by the public.• Damage to the gas transmission (high pressure) and distribution
systems (lower pressure).• gas entry into buildings.• surveillance of works near pipelines.• Corrosion protection and prevention.
Gas Escape Reports natural gas has an odorant added so that it can be readily detected by the human nose on release. gas escapes are reported by members of the public via the BGN emergency number. When a fitter responds to a call they carry out a series of checks to determine if there is a leak and also where. they may determine that there is no leak and this is recorded as “no gas detected”. Where gas is detected, the fitter identifies these as “internal” (within a property) or “external” (occurring on a service or main outside a property). if the leak is upstream of the meter the fitter will isolate at the meter and issue a notice of hazard to the householder. the leak may be isolated at the appliance in some circumstances and a notice of hazard will be issued to the householder in this case also. in these cases the
householder should then get an rgi to carry out the required repairs if the leak is an external leak at the meter installation or on upstream pipework the fitter make safe and carry out the required repairs.
Public reported escapes (Pre) levels typically peak during the colder seasons of Winter and spring. this trend was observed in 2012. this may be due, at least in part, to increased appliance usage during this time. There were 18,147 PRE’s reported on distribution assets in 2012. this represents a 7.3% decrease on 2011 levels. all Pres are investigated by bgn and in the majority of cases no leak is detected (Q4 2012 60% of cases no leak was detected) as can be seen in figure 4.The remainder of leaks are then classified as internal and external. internal leaks are those that occur inside the building. the causes of internal leaks can vary but would typically include such issues as ageing and faulty appliances. external leaks are those on mains and service pipes and around meter installations located outside the building.
Cer noted that there were 9 escapes reported on transmission assets at AGI’s in 2012. This was an increase from 2 Transmission PRE’s in 2011. It should be noted that in 2012 escapes reported on the transmission system include those reported by bgn employees and contractors, which may have led to higher levels of reported escapes. This mainly consisted of leaks on flanges at joining’s in pipework, an insulation joint, and at a pressure relief valve. all leaks were resolved and none of these were due to pipeline deterioration. this increased frequency was noted and will be closely monitored by Cer during 2013.
23
PerforManCe of tHe fraMeWorK
24
FIGURE 4 PubliC rePorteD gas esCaPe freQuenCies for 2009 to 2012
Third Party Damagethere was 1 third Party Damage incident on the gas transmission system during 2012. Pipeline coating damage occurred during excavation works for water pipeline repairs in leopardstown, County Dublin. the works were being performed on behalf of the relevant local authority. bgn reviewed the issue with them in order to minimise the potential for recurrence.
on the Distribution system, a total of 452 instances of damage to mains and services were reported. this equates to a decrease of 21% on 2011 figures. This positive trend is welcomed as Third Party Damage risks are perceived to be the highest in terms of potentialnetwork damage.
During 2012 a continued effort has been made to raise the profile of damage prevention with initiatives to share map data with other utilities and service providers, to increase awareness within plant hire companies of risks and deploy additional staff to support field operations. Along with these measures there has also been involvement from the Construction industry federation, land owners, utility companies and the on-going ‘dial before you dig’ campaign. also a transmission pipeline marker upgrade project was initiated in 2012 and is currently being rolled out across the network.
FIGURE 5 tHirD Party DaMage freQuenCies by suPPly tyPe 2010 to 2012
Gas Entry into BuildingsThe ‘gas in building’ criterion was revised during 2011 to reflect the significant impact of the completion of the mains replacement programme (Cast Iron). The new data reflects any gas in building events discovered by bgn which has initiated from a source outside of any property. there were 2 such events during Q1 2012, 1 related to the leixlip incident as described previously and 1 on boot road, Dublin due to third party damage. learning outcomes from these incidents are used to put in place corrective and preventative measures to reduce the probability of such events reoccurring.
FIGURE 6 gas in builDings events anD evaCuations 2009 to 2012
0
1000
2000
3000
4000
5000
6000
7000
8000
09 Q1
09 Q2
09 Q3
09 Q4
10 Q1
10 Q2
10 Q3
10 Q4
11 Q1
11 Q2
11 Q3
11 Q4
12Q1
12Q2
12Q3
12Q4
3638
2679
22773924
32752202
2243
4136
3764
2364
2407
3250 2357
963
3388
1526
1003738 703 906
973795 720
11801066
674 711 640
1278
937
822
1427
1262
688828
1128
1228
8931149
1423
3250 2147
866
640585
803548
1423
External No leak detected Internal
breakdown of Public reported escapes on Distribution network
10Q3
10Q4
11Q1
11Q2
11Q3
11Q4
12Q1
12Q2
12Q3
12Q4
22142
998
27108
19133
26143
1798
1685
895
13106
11118
0
30
60
90
120
150
PE-Mains PE-Services
Distribution - third Party Damages breakdown
0
1
2
3
4
20 23 00 00 02 01 00 00 11 00 00 00 00 00 0011
Number of ‘Gas in Buildings’ eventsNumber of BGN-initiated evacuations
09 Q1
09 Q2
09 Q3
09 Q4
10 Q1
10 Q2
10 Q3
10 Q4
11 Q1
11 Q2
11 Q3
11 Q4
12Q1
12Q2
12Q3
12Q4
Distribution - gas in building events & evacuations
25
Pipeline Surveillancethe high pressure gas transmission system, constructed from high quality, welded steel, has strict controls regarding third party works within close proximity to the pipeline. to avoid damage to pipelines or their protective coatings, bgn maintain a surveillance programme with foot, vehicular and aerial surveys. encroachments occur when unknown third parties carry out ground works within close proximity to transmission pipelines. bgn report in accordance with the uK onshore Pipeline operators association (uKoPa) guidelines:
• Category a: Pipeline leak or damage• Category b: Potential for damage• Category C: limited or minimal potential for damage
2012 saw a decrease of 14.3% in encroachment events. the level of surveillance in 2012 was higher than in 2011, particularly the level of ground surveillance increasing by 8%. all encroachments are followed up, as standard, with the landowner or relevant contractor. recurrent themes such as drainage and ditching work form part of the on-going programme of promotional and preventative activities. these include regular interfaces with key utilities and adding additional warning and protective measures to pipelines.
FIGURE 7 WorKs DeteCteD near PiPelines 2009 to 2012
Pipeline Corrosion Protectionbgn use Cathodic Protection (CP) systems in combination with pipeline coating systems to protect steel pipelines from corrosion. Cathodic Protection (CP) is a technique used to control the corrosion of a metal surface by making it the cathode of an electrochemical cell. a method of protection connects protected metal to a more easily corroded “sacrificial metal” to act as the anode. The sacrificial metal then corrodes instead of the protected metal. Previously CP performance was monitored manually requiring field based staff to
visit sites and take readings. a new continuous monitoring system was developed and was implemented by bgn in 2011. the new system continually monitors CP. if a fault occurs and is detected by the system an investigation into the type and extent of the fault occurs. it is important that faults are corrected in order to minimise the effect of or potential for corrosion. it is expected that bgn react with urgency to Cathodic Protection issues. the number of faults that existed for greater than 6 months increased during the course of 2012. the long term (greater than 6 months) faults are due to depleted ground beds which cannot provide sufficient protection to pipeline sections. remedial work by bgn is on-going to address items by balancing the CP potentials to bring the potentials up on sections of pipelines while not over protecting other sections.
FIGURE 8 nuMber of CatHoDiC ProteCtion Points WHere tHe voltage is outsiDe Criteria for 6 MontHs or longer
this issue triggered a detailed inspection by the Cer in Q4 2012 and an audit of bgn with regards to CP took place in Q2 2013 in order to gain assurance that the system is being appropriately managed and faults being rectified in a timely and proficient manner. An outcome of the review and inspection were that the reporting of KPI’s on CP data was changed from Q1 2013 onwards to ensure the most accurate presentation of the information is provided. the changes related to the description of the data to give more clarity and also detail was added on the length pipework related to the data. the number of long term faults remaining on the system has reduced significantly after Q2 2013.
Key safety objective 2: Maintaining safe system operating Pressuregas undertakings are required to demonstrate that they have suitable management systems in place for managing the risks that can result in dangerously high or low gas operating pressure in the pipeline system(s). Within the scope of this objective are:
• gas outages• Pressure Management and Control
Encroachments/Events - Ground Patrol
Encroachments/Events - Aerial Survey
20
16
12
8
4
009Q170
09Q260
09Q319
09Q416
10Q166
10Q28
11
10Q316
10Q402
11Q12
13
11Q226
11Q345
11Q45
12
12Q169
12Q274
12Q374
12Q414
breakdown of transmission related encroachment events 0
5
10
15
20
25
30
35
40
11 Q1 11 Q2 11 Q3 11 Q4 12 Q1 12 Q2 12 Q3 12 Q4
26
Gas Outagesthere were no gas outages on the transmission system during 2012. there were 2 reported outages on the distribution system. the outage in Q2 2012 affected 85 customers in Portmarnock due to a District regulating installation (Dri) leak. the outage in Q4 2012 in Mulhuddart affected 157 customers and was due to third party damage of a steel main. the completion of the Cast iron mains replacement programme in conjunction with a heightened awareness of pipe damage prevention (through the ‘Dial before you dig campaign), is helping to keep outages at a relatively low level.
FIGURE 9 unPlanneD Distribution outages 2009 to 2012
System Pressure Managementbgn operates a supervisory Control and Data acquisition (sCaDa) system, which monitors system pressures within defined parameters and alarms where excursions outside these limits are observed. there were no issues identified within the gas Distribution system pressure during 2012. the frequency of under pressure events has reduced to zero from1 in 2011 and 21 in 2010. As can be seen in figure 10 this marks significant improvement in this area in the last three years which is welcomed by Cer.
FIGURE 10 freQuenCy of systeM Pressure DroPs on tHe Distribution systeM 2009 to 2012
Key safety objective 3: Minimising the risk of injecting gas of non-conforming qualitygas emergency incidents can arise due to gas of inappropriate quality being injected into the system and, as such, gas undertakings are required to demonstrate that they have suitable management systems in place for gas quality monitoring and managing the risks associated with the quality of gas that is injected into the system.
the KPis for this objective are:
• odorant; and• gas Quality.
Odorant Managementin order to identify uncontrolled leaking gas, an odour is added to natural gas, which must be maintained within prescribed limits to be detected by the human nose. to ensure consistency random tests are taken and odour levels are measured. there were no reports in 2012 of non-compliant odour results. this is consistent with improvements made over the preceding 2 years.
Gas Qualityensuring gas quality remains within a prescribed range is critical to ensure that gas supply remains safe. an example would be where the heat value (Calorific Value) fluctuates causing an increased risk of Carbon Monoxide production at the appliance. there were no issues identified with gas quality during 2012. BGN monitor parameters such as the Wobbe number, water content, soot index and a number of other parameters along with Calorific Value to ensure gas entering the transmission system is within prescribed limits.
FIGURE 11 total nuMber of PlanneD anD CoMPleteD oDour tests CarrieD out froM 2009 to 2012
500
15-99100-249250+
200
000
200
200
100
000
200
000
100
000
000
6
5
4
3
2
1
009 Q1
09 Q2
09 Q3
09 Q4
10 Q1
10 Q2
10 Q3
10 Q4
11 Q1
11 Q2
11 Q3
11 Q4
000
100
000
010
12 Q1
12 Q2
12 Q3
12 Q4
90
Dist.Trans.
Freq
uenc
y of
occ
uren
ce
160
20
30
50
50
100
10
00
10
00
00
09 Q1
09 Q2
09 Q3
09 Q4
10 Q1
10 Q2
10 Q3
10 Q4
11 Q1
11 Q2
11 Q3
11 Q4
00
00
00
00
12 Q1
12Q2
12Q3
12Q4
Q1 09
Q2 09
Q3 09
Q4 09
Q1 10
Q2 10
Q3 10
Q4 10
Q1 11
Q2 11
Q3 11
Q4 11
Dist. 9 16 2 3 5 5 10 1 0 1 0 0
Trans. 0 0 0 0 0 0 0 0 0 0 0 0
0
5
10
15
20
Freq
uenc
y of
occ
uren
ce
Frequency of System Pressure Drops
20
15
10
5
0
180179
Odour tests planned Odour tests undertaken
180180
186186
180148
186185
180180
180180
180179
180180
142142
144140
144149
200180160140120100
80604020
009 Q1
09 Q2
09 Q3
09 Q4
10 Q1
10 Q2
10 Q3
10 Q4
11 Q1
11 Q2
11 Q3
11 Q4
144144
144144
144144
144144
12Q1
12Q2
12Q3
12Q4
Distribution odour tests Planned - Completed
no. of unplanned Dist. outages by no. of customers
frequency of system Pressure Drops
27
Key safety objective 4: Providing an Efficient and Coordinated Response to gas emergenciesGas emergency events occur due to insufficient supplies into the network or a transportation constraint, including the actions of third parties. bgn is required to demonstrate that it has suitable arrangements in place for: (i) managing the response to ‘localised’ gas emergencies; and (ii) undertaking the role of national gas Emergency Manager during ‘network’ gas emergencies. Additionally, all gas undertakings are required to demonstrate that they have suitable arrangements in place for responding to the requirements of the national gas emergency Manager in the event of large-scale ‘network’ gas emergencies occurring.
the KPis for this regulatory objective are:
• gas supply emergencies; and• Public reported escapes response times
Gas Supply Emergenciesthere were no gas supply emergencies during 2012 that required initiation of the natural gas emergency Plan (ngeP). the natural gas emergency Plan (“the ngeP”) is prepared by the transmission system operator (“the tso”), (bgn on behalf of gaslink), under the direction of the Cer and in consultation with the gas industry, the electricity industry and government. the purpose of the plan is to establish procedures to be followed in the event of a natural gas emergency in ireland.
Public Reported Gas Escapes Response Timesbgn intend to respond to all reported escapes of gas within 1 hour. there were 18,147 Public reported escapes in 2012 with 18 responses outside the 1 hour response criterion, resulting in an overall performance level of 99.9%. the causes of late responses were due to traffic congestion, road closure, icy roads, telecoms issues and unavailability of fitter in location. This is a relatively high compliance rate but the Cer will continue to monitor the compliance level to ensure it remains at a high level.
FIGURE 12 gas esCaPe resPonse effiCienCy by Quarter 2009 to 2012
Key safety objective 5: Minimising the safety risks associated with the utilisation of gasThe key aim of this regime is that all categories of ‘gas works’ designated by the Commission are only undertaken by competent gas installers who are registered, and subject to on-going regulation and inspection, by the gssb appointed by the Commission. the connection and re-connection of customers’ installations to the gas supply network and the servicing of such installations are important safety risk issues that will be addressed within the scope of this objective. Customer education and safety awareness is an important part of this gas safety objective as discussed in key objective 6.
the KPis for this regulatory objective are:
• registered gas installers and the regulatory scheme;• Certificates for gas works;• Meters;• Carbon Monoxide; and• Disconnections.
Registered Gas Installers and the Regulatory Schemethe number of installers registered in the scheme at the end of the third full year of operation was over 2,969. the competence of individual installers is affirmed not only at entry level to the scheme by rgii, but also through an on-going inspection process which involves each rgi undergoing a minimum of 1 inspection and audit per annum. The inspectors codify the installer’s work in light of the level of risk observed, and remedial actions are in accordance with the level of a finding.
a promotional campaign during 2012, which included national and local press, communication with industry parties and updating of existing television and radio advertisements, focused on domestic customer’s awareness of the requirement to use gas and LPG installers registered with the rgii.
FIGURE 13 registereD gas installers by Class of MeMbersHiP 2009 to 2012
100%
90%09Q1
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09Q3
09Q4
10Q1
10Q2
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10Q4
97.5%
99.9%99.9%
99.9%
99.7%
99.9%99.9% 99.9%99.8%
99.9% 99.5%100%
100%99.9%
100% 100%
11Q1
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% Public reported escapes attended < 1 Hour
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0641121
TraineeFullProvisional
Trainee Full Provisional
911834511
832043390
872229
0
852464
0
762549
0
752658
0
572676
0
572779
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4
392749
8
382797
8
12Q1
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02860
35
02906
37
02899
32
02938
31
Number of RGI’s by Membership Class
28
at the end of 2012 there were 2,969 installers (including full and trainee members) registered with the rgii, this represents a 4.4% increase on the previous year.
the rgii has a suspension and revocation Procedure in place to address issues of non-compliance with the rgii rules of registration. During 2012, 313 suspended registrations were recorded primarily as a result of expired insurance and not making gas works available for inspection. the rgii has issued revocation letters to all suspended installers outlining the time in which they must comply with the registration requirements, or face having their registration status revoked.
there is a possibility that these deregistered members are continuing to operate outside of the regulatory scheme, thus emphasising the importance of the CER’s enforcement actions against non registered and de-registered installers. in 2012 the Consumers association of ireland (Cai) completed a survey of boiler sales in ireland and noted a difference of 10,000 units between sales of boilers and the number of certificates sold by RGII in 2011, and provided this information to the Cer for their review
The CER notes that the figure for boiler sales is higher than any view the Cer has received from other industry stakeholders. the Cer intends to engage with the Central Statistics Office to determine if verifiable information on the number of gas boilers imported can be collected in future.
The discrepancy between boiler and certificates which requires investigation could be due to either unregistered installers completing work or registered installers completing work and not issuing a certificate.
regardless of the level, the Cer agrees that it is important to minimise activity by unregistered installers and to carry out enforcement as required. it is also important, and a legal requirement, that registered installers provide certificates in all cases.
the media message in relevant publicity campaigns will continue to emphasise to customers the requirement to use a registered gas installer and the importance of obtaining a certificate. The RGII has also engaged a private surveillance specialist to assist in monitoring of deregistered installers from early 2013.
Certificates for gas worksThe issuance of a Conformance Certificate is legally required for all “gas Works” currently carried out in a domestic setting. When a registered gas installer performs an item of work (new installation, replacement or servicing) a completion certificate must be provided and a copy returned to the rgii.
The sale of certificates shows the level of Gas Work being carried out by registered gas installers. The sale of Conformance Certificates decreased by 5% in 2012 compared to 2011. the rgii sold 196,642 appliance servicing certificates, 10,125 appliance replacement certificates and 6,829 new gas installation certificates.
FIGURE 14 registereD gas installers CertifiCate sales 2009 to 2012
MetersMeter performance is gauged by monitoring frequencies of faulty or tampered meters. During 2012 there were 134 reports of meter tampering. the frequency of this type of event increased by 168% during 2012. increased detection may be due to the on-going meter replacement programme (replacing the aged imperial meter population), installation of pre-payment meters, and continuing vigilance within bgn. Due to increase in this type of event Cer will focus with bgn on measures to reduce these occurrences in 2013.
FIGURE 15 nuMbers of taMPereD Meters iDentifieD 2009 to 2012
BGN identified 423 faulty meters during 2012, a decrease of 135% on 2011. this may be due to the increased focus on meters during the meter replacement programme.
FIGURE 16 nuMbers of Meter leaKs or faults iDentifieD During 2009 to 2012 as Part of Meter rePlaCeMent PrograMMe
900008000070000600005000040000300002000010000
009Q3
09Q4
10Q1
10Q2
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10Q4
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11Q3
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Installation Certs
65710
9190
5325
41240
3620
2968
37380
2890
2617
40040
2050
1787
47930
2780
2037
52660
2745
2421
55310
2615
1743
41481
1985
1434
54390
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2031
63559
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1874
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55310
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41481
1985
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3320
1874
Replacement CertsServicing Certs
0
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25
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1014
26
2 2
1517
10 8
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44
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Number of Tampered meters identified
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26
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Number of Faulty or Leaky meters identified
29
Carbon Monoxide (CO)the effectiveness of Carbon Monoxide campaigns are measured using customer surveys and customer safety enquiries.
Currently bgn provide a free Carbon Monoxide (Co) safety check service to customers who have concerns about their gas installation. 2012 saw a decrease of 29% on Co checks from 2011. a relatively high level of Co safety checks occurred in 2011 following the high profile CO incident at the Trident hotel in Kinsale in Q1 of that year. The 2012 figures subsequently decreased significantly after the incident in 2011 but are still over double the level of safety checks reported in 2010. this indicates a higher level in 2012 of awareness of the public in general in relation to Co issues, which is very encouraging and welcome.
FIGURE 17 nuMber of CustoMer reQuesteD safety CHeCKs PerforMeD 2009 to 2012
Safety Disconnectionsbgn carries out safety disconnections where an unsafe situation is identified at a customer’s gas installation. The graph below provides the number of safety related disconnections at the meter by quarter from Q1, 2009 onwards. the frequency of safety disconnections at the meter has increased slightly from 2,049 in 2010 to 2,064 in 2011 and 2,084 in 2012, a total increase of approximately 2%.
Figure 18 illustrates a significant increase in safety disconnections had occurred in Q4 2010 with the freezing conditions likely to have been a major factor as bgn had a higher level of response work (Pre & no gas) to attend. in addition, the Meter replacement Programme continued during this period. this high level of activity in customer’s premises highlighted issues with the customer’s installation pipework and appliances that caused the higher than usual safety disconnections level. in some cases customers, because of the very cold conditions used appliances such as gas fires that had not previously been used in some time, leading in some cases to disconnections at the meter.
FIGURE 18 bgn safety DisConneCtions at tHe Meter 2009 to 2012
In addition to the figures shown in Figure 18, in 2012 there were 2,685 instances where bgn disconnected an appliance for safety reasons, while leaving the supply of gas at the meter intact. this compares to a figure of 2,865 in 2011. These appliance disconnections are not included within the above graph.
Key safety objective 6: Promoting Public awareness of gas safety increasing the level of gas safety awareness amongst gas customers and the public generally and, in particular, educating on the dangers of carbon monoxide is an important aspect of the Commission’s overall objective of promoting the safety of customers and the general public in respect of the use of gas. it will also be important that owners/occupiers of premises are aware of their responsibilities in respect to the maintenance of gas fittings downstream of the meter. the proposed gas safety framework places duties and obligations on both individual gas undertakings and the industry generally for the promotion of gas safety awareness. this will involve a combination of both individual and co-ordinated safety promotional activities by undertakings.
The currently identified KPIs for this regulatory objective are:
• bgn emergency number Calls • Carbon Monoxide reports and website visits• Dial-before-you-Dig Calls• rgii website visits
Emergency Number Callsit is essential when a member of the public notices a gas escape that they can identify the correct number to call and report the escape. to monitor awareness and the effective advertising of the emergency number, all calls to the number are noted. in 2010 34% of calls to the emergency number were gas escape calls with 66% misdirected. in 2011 misdirected calls decreased to 46% and in 2012 it decreased further to 38%. this shows awareness amongst the public is increasing with regards to the purpose of the emergency number. Misdirected calls may be from people intending to call the Dial before you Dig number or the Carbon Monoxide information line.
1252
1382 1404
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1979
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21142216
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448
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386320 310
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995
396475
575618
544
538
452
550
Figure 14: Number of customer requested safety checks performed during 2009 to 2011
Figure 15: Bord Gáis Networks Safety Disconnections during 2009 to 2011
Figure 18: Plant location enquires to the dial before you dig line during 2009 to 2011
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74 59115
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number of Co safety Checks carried out by Quarter
number of safety related Disconnections by Quarter
1252
1382 1404
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21142216
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Figure 14: Number of customer requested safety checks performed during 2009 to 2011
Figure 15: Bord Gáis Networks Safety Disconnections during 2009 to 2011
Figure 18: Plant location enquires to the dial before you dig line during 2009 to 2011
09Q1
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389
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30
FIGURE 19 freQuenCy of enQuiries to tHe bgn eMergenCy nuMber vs aCtual rePorteD esCaPes 2010 to 2012
Carbon Monoxide Calls and Website ActivityCalls and website hits in 2012 remained seasonal in nature and aligned to advertising bursts. Q4 levels in 2011 had risen sharply, which can be attributed to fatalities reported in gurteen Co. sligo18. Whilst there were no Co fatalities in 2012 website activity levels rose significantly in Q3 and dropped off in Q4. This spike in Q3 is attributed to the Carbon Monoxide awareness Week held at the end of Q3 2012. Calls to the Co Helpline number remained stable in 2012 with higher levels during Q1 and Q4.
FIGURE 20 nuMber of Carbon MonoxiDe enQuiries 2010 to 2012
Dial Before You Digthe “dial before you dig” process is designed to provide third parties with safety advice before they excavate. the trend in enquiries increased in 2012.
FIGURE 21 Plant loCation enQuiries to tHe Dial before you Dig nuMber 2009 to 2012
RGII AwarenessThe RGII website is a prime mechanism for customers wishing to find a rgi and has been advertised via a range of media. the trend in visits to the rgii website throughout 2012 was encouraging. there were 169,374 visits to the website www.rgii.ie during 2012.
FIGURE 22 uniQue visitors to tHe Website WWW.rgii.ie in 2012
During 2012 the annual BGN safety survey identified an increase in the general public’s awareness to the Registered Gas Installer scheme. the overall awareness of the scheme has increased from 45% in 2011 to 53% in 2012. Specifically within the natural gas user group the survey indicated an increase in awareness of rgis from 56% in 2011 to 68% in 2012. In 2009, the equivalent figure was 38%. Continued media and advertising campaigns aim to further heighten awareness and are primed to take place in 2013.
number of safety related Disconnections by Quarter
18. On December 18th 2011 Trevor Wallwork and his and two children Kimberley and Harry died at their house near Gurteen in Co Sligo from Carbon
Monoxide poisoning caused by a blocked chimney flue.
1561543
3565269
1813421
13321614
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CO Website Visits Calls to CO Number
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Unique Visitors to www.rgii.ie
unique visitors to www.rgii.ie1 Hour
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Figure 14: Number of customer requested safety checks performed during 2009 to 2011
Figure 15: Bord Gáis Networks Safety Disconnections during 2009 to 2011
Figure 18: Plant location enquires to the dial before you dig line during 2009 to 2011
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total number of enquires to DbyD number
31
CER is satisfied that the Framework is both continuing to meet its objectives and also continuing to evolve and improve in response to outcomes from audits and inspections, incidents and legislative requirements.
as described in this report the framework itself, and all the detailed regulatory documents and procedures which stem from it, represent the standard for compliance against which each undertaking and the gssb are measured.
Specifically this includes measuring compliance with:
• the 1999 act, as amended;• the natural gas safety regulatory framework; • the safety Case guidelines, and individual safety Cases of each
undertaking; and• the terms and Conditions of appointment and the Criteria
Document for the rgii.
Compliance with the framework is largely assessed through comprehensive audit and inspection regime. this consists of a recurrent 3 year audit & inspection Programme from 2012 – 2014 which comprises of three distinct components:
1. a triennial independent in-depth audit of each individual undertaking
2. ongoing audits & inspections for each undertaking and the gssb. this component is the core of the audit & inspection Programme; and
3. ad hoc audit & inspection which are undertaken on an ‘as needed’ basis.
this was the second year where there was a full programme of collective audit, inspection and review processes carried out for gas undertakings. accordingly a wide range of best practices and recommendations for improvement were identified. These are continually managed with undertakings through regular interfaces and reviews, and the Cer has seen a positive response from undertakings to address such findings. Satisfactory management and resolution of these issues will be closely monitored by the Cer on an on-going basis. The CER is satisfied that undertakings are operating within the requirements of the gas safety regulatory framework.
the Cer has increasingly interacted with rgii and undertakings to seek to continuously improve safety standards and performance levels. the annual audit programme was completed and included audit of transmission, distribution, gas shipping and gas supply undertakings. Some significant improvements were identified and an on-going review of Key Performance indicators, incidents, findings and wider reviews indicates that generically the industry is still operating satisfactorily within the requirements of the gas safety regulatory framework in the interests of customers.
ConClusion
32
introduCtion Overviewas part of its safety functions the Cer has statutory authority to “regulate the activities of electrical contractors with respect to safety”. figure 23 the structure of the electrical safety supervision team.
FIGURE 23 eleCtriCal safety teaM organisational CHart
Backgroundthe energy (Miscellaneous Provisions) act, 2006, granted the Cer powers in relation to electrical safety. from 2006 the Cer set about developing and consulting with the general public as to how best the scheme for the regulation of electrical contractors should be operated. this process included in the publication by the Cer in 2007 of the vision Document (Cer/07/203) which set out a high leve scope with respect to the scheme. in 2008 the Cer published the Criteria Document (Cer/08/071). the Criteria Document sets out the detailed rules and obligations for participants operating within the electrical safety regulatory system. in late 2008 the Cer appointed two bodies to act as electrical safety supervisory bodies (ssbs) to carry out the day-to-day operation of the scheme.
Safety Supervisory Bodiesthe two bodies appointed to act as electrical safety supervisory bodies (ssbs) were the electrical Contractors safety & standards association ireland (eCssai) ltd and the registered electrical Contractors of Ireland (RECI) Ltd. Both SSBs were appointed to fulfil the safety function on behalf of the CER (on a not-for-profit basis) for a period of seven years from 5th January 2009, replacing the self-regulatory model operated previously. the Cer remains responsible for policy decisions regarding electrical safety and the operation of the regulatory scheme.
the ssbs are responsible for maintaining a register of registered electrical Contractor (reCs), ensuring that each reC is inspected on a regular basis to ensure that they are operating in line with the appropriate national safety standards and technical rules relating to electrical installation work at low voltage level. the ssbs are also responsible for distributing and processing certificates that a REC must issue to a customer once the electric work is complete. in addition both ssbs are responsible for dealing with queries and investigating complaints received by customers about reCs.
regulatory perFormanCeRegistered Electrical Contractorsall reCs are required to have in place insurance cover and are required to certify all electrical work completed by them in a domestic or commercial environment. each reC who is registered with one of the ssbs is required to demonstrate that they or an employee who certifies the electrical work has obtained a recognised National Craft Certificate as an electrician or another suitable electrical qualification and has insurance cover as specified by their respective SSB. A complete list of registered electrical Contractors operating in ireland is available through the safe electric website www.safeelectric.ie. figure 24 shows how the number of registered electrical Contractors (reCs) continued to decline in 2012 dropping from 4,264 in 2011 to 4,022.
FIGURE 24 total nuMber of registereD eleCtriCal ContraCtors
Commission
Director of Energy Safety
Electrical Safety Supervision Team
Electrical Safety Supervision Bodies
Manager ElectricalSafety Supervision
TechnicalAnalyst (s)
ElectricalTechnicalSpecialist
RECI ECSSAI
CO Website Visits Calls to CO Number
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50064146
44184623
45613866
42064349
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40224975
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17371
14162
15472
12518
10369
12021
12815
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11327
12419
12383
15297
15689
15926
17141
14364
SSBs’ Total Number of RECs
Part 2 eleCtriCal safety suPervision
33
Certificationthe majority of electrical works performed by reCs require certification. It is through this system that the CER and by extension the ssbs ensure that the work carried out reaches the required safety standards, so when a customer hires a reC to carry out work they can have peace of mind.
FIGURE 25 safety suPervisory boDies Quarterly CertifiCate sales
Certificate sales grew strongly from 46,929 in 2011 to 64,053 in 2012. this increase in sales is not due to domestic or industrial type certs, with other types such as sub-system, periodic inspection report, agricultural and minor type certificates being responsible. Sale of sub-system certificates were up in Q1 and Q2 of 2012 due to activity in the telecommunications area. A large part of the significant increase in sale of minor certificates in 2012 is due to the installation of pre-pay meters. Sale of domestic type completion certificates were improved in Q4 2012. sale of periodic inspection reports remained reasonably constant during 2012.
FIGURE 26 tyPes of CertifiCates solD
Inspectionsunder the Criteria Document, the ssbs are required to monitor, inspect and audit the standard of electrical work completed by reCs, with respect to safety. Consequently, the ssbs provide information quarterly on the number of inspections completed as shown in the graph below. the decreased number of inspections is due in part to the reduced number of reCs in the scheme.
FIGURE 27 insPeCtions CoMPleteD on registereD eleCtriCal ContraCtors
the Cer appointed an electrical technical specialist to monitor and inspect, through an approved audit and inspection programme, the work of the ssbs to verify that the safety performance metrics reported to the Cer are accurate by ensuring that inspection reports prepared by inspectors and submitted to the ssbs are complete and contain all relevant technical information in order to identify emergent reporting areas and to recognise any potential hazards. the safety team continued to bed in the Common Performance evaluation scheme (CPes) with both ssbs during 2012. this helps ensure a standardised approach to inspections on reCs by both ssbs.
Public awarenessin april 2010 the Commission for energy regulation (Cer) launched a safety awareness campaign, known as “safe electric”. this was ran across multiple media including tv, radio, press and outdoor. this campaign was renewed and ran again for 2011/12. it was designed to make people aware of the need to hire a registered electrical Contractor when getting any electrical work done in their home and to ask for a certificate when the work is complete. The campaigns message was that by hiring a registered electrical Contractor, people can ensure that any work carried out in their home is completed by a competent contractor who is insured and inspected as part of the Safe Electric scheme. To find a REC visit www.safeelectric.ie.
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45613866
42064349
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11Q1
11Q2
11Q3
11Q4
12Q1
12Q2
12Q3
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10000
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15297
15689
15926
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14364
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figure 28 safe eleCtriC logo
Restricted Works restricted electrical Works are electrical works which only a reC can complete.
in september 2011 the Cer published the proposed decision paper on the scope of restricted electrical Works. after receiving Ministerial consent in July 2012 to designate the scope of restricted electrical Works the Electrical Safety Team (in conjunction with the CER’s legal team) drafted a Statutory Instrument which defines restricted electrical works. this was submitted to the Department of Communications, energy and natural resources (DCenr), who will have it laid before the oireachtas by the Minister for approval.
When enacted, this will prohibit anyone but a registered electrical Contractor from carrying out electrical work in domestic premises. this does not include minor works, for example like-for-like change of a light switch. The date for this change will not be finalised until the statutory instrument has been approved by both houses of the oireachtas. this is expected to happen during 2013.
ConClusionthe Cer continued to work closely with the ssbs during 2012 in order to monitor the performance of the electrical safety regulatory scheme and also to drive improvements to different aspects of the scheme. The increase in certificate sales in the scheme during 2012 was encouraging and it is hoped that the enactment of restricted Works along with the renewal of the safe electric public awareness campaign in 2013 will help drive further improvements.
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AAI age action irelandAGI above ground installationALARP as low as reasonably practicableATEX explosive atmospheresBGN bord gáis networksCER Commission for energy regulationCMP Crisis Management PlanCO Carbon MonoxideCP Cathodic ProtectionDBYD Dial before you DigDCENR Department of Communications energy & natural resources DECLG Department of environment Community and local government DETINI Department of enterprise trade and investment in northern irelandDM Daily MeteredDSO Distribution system operatorECSSAI electrical Contractors safety and standards association irelandESBN esb networksEPD explosion Protection DocumentFETAC further education & training awards CouncilGSC gas safety CommitteeGSSB gas safety supervisory bodyGSTC gas safety technical CommitteeHSA the Health & safety authorityIAC industrial and Commercial KPI Key Performance indicatorsLDM large Daily MeteredLNG Liquefied Natural GasLPG Liquefied Petroleum GasLPGU Liquefied Petroleum Gas UndertakingMOU Memorandum of understandingMP Medium pressure NGEM national gas emergency ManagerNGEP natural gas emergency PlanNGU natural gas undertaking NSWC networks services Works ContractNSAI national standards authority of ireland NTP networks transformation Programme NohZ notice of HazardPAPA Promotion & Public awarenessPE Polyethylene (pipe)PRE Public reported (gas) escapePPM Parts Per Million REC registered electrical ContractorRECI registered electrical Contractors of irelandRGI registered gas installerRGII registered gas installers of irelandSCADA supervisory Control and Data acquisitionSSC storage safety CaseTSO transmission system operatorUKOPA uK onshore Pipeline operators association
glossary of terMs
36
the following sections describe some of the main work items the Cer are undertaking in 2013.
Gas and Electricity Safetyas part of its safety functions the Cer has statutory authority to
• Continue the development of processes associated with the expansion of the gas safety framework to include lPg undertakings/safety licence holders. additionally, learning from the review of the current framework and its implementation will be reflected in the development and implementation by the Cer of the new enforcement processes under the expanded framework;
• Complete the design, development and implementation of robust enforcement processes and procedures to give effect to the expanded enforcement powers of the Cer;
• Consult on the definition of commercial gas works, which will lead to it being illegal for anyone other than a registered gas Installer to undertake specified commercial gas work;
• legally restrict certain types of electrical works in a domestic setting (restricted electrical works) to only registered electrical Contractors;
• Promote, through national advertising campaigns to consumers, the safety messages associated with the safe use of natural gas and lPg. the campaigns will also focus on encouraging consumers to seek to use a registered gas installer or registered electrical Contractor for any gas or electrical work to be carried out;
• Pursue prosecutions for carrying out of restricted electrical Works or gas Works by non-registered electrical Contractors or non-registered gas installers, respectively; and,
• investigate natural gas and lPg incidents to determine root cause and facilitate improved safety outcomes.
Petroleum Safety Framework following the completion of the High level Design, the Detailed Design phase of the Project began in June 2012 and will continue until the end of the 2013. this phase of the project involves determining the appropriate policy/content of each of the above areas. the Cer will publish various papers on the above in a logical order to ensure that:
• Stakeholders will have sufficient opportunity to participate in the consultation process; and,
• the timelines do not place an unmanageable burden on stakeholders.
outlined below are the anticipated publication dates for consultation papers and decision papers relating to the Permissioning system, Compliance assurance system and incident investigation components of the framework:
document Consultation Paper date
decision Paper date
designated Petroleum activities regulations
Oct/Nov ‘12 Feb ‘13
alarP demonstration guidance document
Oct/Nov ‘12 Feb ‘13
safety Case guidelines Oct/Nov ‘12 Feb ‘13
safety Case Publication Policy
Jun ’13 Nov ’13
Safety Case Assessment Procedures
- May ‘13
Permissioning Process Map guidance document
- May ‘13
safety Case 5 Year Thorough review Policy
Aug ‘13 Oct ‘13
Compliance assurance Procedures
Nov ’13
Audit and Inspections July ’13
Verification - Facilities Verification
July ‘13
Verification - Well Examination
July ’13
Performance Reporting Policy Document
July ’13
Petroleum incident regulations
July ‘13 Nov ‘13
Petroleum incident investigation Procedures
- Nov ‘13
in parallel with the Detailed Design Phase, the Cer will also be working on its internal readiness which involves the Cer putting in place the people, processes and procedures to enable the effective and efficient operation and enforcement of the Framework on an on going basis.
The final phase of the Project is the Implementation Phase which involves:
• the Cer being in position to take submission of safety Cases; • Conducting assessment of safety Cases and, where appropriate,
the issuance of safety Permits to Petroleum undertakings; and subsequently,
• Monitoring and enforcing compliance by petroleum undertakings with their obligations under the act.
the Cer expects that the Petroleum safety framework will come into full effect on november 30th 2013, and the Cer will be in a position to take submission of safety Cases from that time.
aPPenDix i WorK-Plan 2013
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Carbon Monoxidethere were no fatalities reported in 2012 attributed to accidental carbon monoxide poisoning. The most recent high profile incident attributable to carbon monoxide poison was the deaths in sligo in December 2011.
What is Carbon Monoxide (Co)?Carbon Monoxide is a colourless, odourless and poisonous gas. it is produced when carbon-based fuels such as oil, gas, wood or coal do not have enough oxygen to burn completely. in most cases, people do not know that they are being exposed to Co. if there is a lack of air for the combustion process or the heating appliance is faulty, Co can be produced. When Co is inhaled into the body it combines with the blood, preventing it from absorbing oxygen.
the risks associated with Co? an average of six people in ireland die every year from accidental CO poisoning according to figures compiled by the HSE. When CO is inhaled into the body it combines with the blood, preventing it from absorbing oxygen and if a person is exposed to Co over a period, it can cause illness and even death.
the Physiological effects of Carbon MonoxideThe amount of CO which the blood absorbs depends chiefly on two things: how much Co is in the air and the length of the exposure. adverse effects of Co on humans are reduced by periods of breathing fresh air. the degree of recovery depends on the number and length of those periods. the general state of health and degree of physical activity of a person exposed to Co are other factors involved in the effects of Carbon Monoxide on the body.
Parts per Million (PPM)
Time of exposure
response
50 – Threshold limit, no apparent toxic symptoms
100 Several hours No symptoms for long periods
200 2-3 hours Possible headache
400 1-2 hours Frontal headache and nausea
800 45 minutes Headache, dizziness and nausea
800 2 hours Collapse and possible unconsciousness
1600 20 minutes Headache, dizziness and nausea
1600 2 hours Collapse, unconsciousness, possible death
3200 5-10 minutes Headache and dizziness
3200 10-15 minutes Unconsciousness and possible death
6400 1-2 minutes Headache and dizziness
6400 0-15 minutes Unconsciousness and possible death
12800 Immediate Unconsciousness
12800 1-3 minutes Danger of death
TABLE 9 PHysiologiCal effeCts of Carbon MonoxiDe exPosure over tiMe
if you or your family experience symptoms and you believe Co may be involved you should seek urgent medical advice. inform your doctor of your concerns. Co will leave the blood when you go out into the fresh air and tests for Co may be inaccurate if taken hours after the exposure has ceased.
Again, if you find a person ill or unconscious near any fuel burning appliance, be careful in case you also become a casualty. get fresh air immediately by opening windows and doors.
avoiding Carbon Monoxidethe following are some of the things that the Cer promote to help eliminate Co in the home:
• ensure your appliances are installed and serviced annually by an RGI, or a qualified service agent for your fuel type.
• Make sure room vents are not blocked and there is adequate ventilation.
• Keep flues and chimneys unblocked. If you’ve recently renovated or had builders in, ensure that these have not been adversely affected.
• Make sure all chimneys are regularly swept and kept clear.• use appliances only for the purpose for which they were
designed, e.g. do not use a cooker to heat a room.• if you suspect an appliance may be faulty, stop using it
immediately and arrange for a safety inspection.• Carbon monoxide poisoning can cause flu-like symptoms. If
you’re concerned, ask your doctor to test for carbon monoxide poisoning.
• Call 1850 79 7979 or visit www.carbonmonoxide.ie
Carbon Monoxide alarms can be used as a backup to provide a warning to householders in the event of a dangerous build up of Co. Check that the Carbon Monoxide alarm complies with the en 50291 standard and is sWift 8 compliant. remember that Carbon Monoxide alarms are not a substitute for regular inspection and maintenance of appliances, vents, flues and chimneys.
aPPenDix ii inforMation on Carbon MonoxiDe
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Commission for Energy Regulation
The Exchange, Belgard Square North,
Tallaght, Dublin 24, Ireland.
T: +353 1 4000 800 | F: +353 1 4000 850
E: [email protected] | www.cer.ie
Commission for Energy Regulation
an Coimisiún um rialáil Fuinnimh