notifying and reporting incidents - health and safety … and reporting incidents - mar obligation...

Health and Safety Executive

Industry Briefing Event:

Notifying and Reporting

Incidents

OSDR Industry Briefing – March 2016 1

Welcome & Introduction

• Reporting Law & Overlapping Legal Requirements

• The EU Implementing Regulation in Detail

– Relevant Guidance on Incident Reporting

– Events A to J

• Report of an Oil & Gas Incident (ROGI form)

– Introduction

– Detail of the form

• Wells & Pipelines

• Case Studies, Scenarios

• Questions & Answers



Reporting Law:

GB and EU

Overlapping Requirements


Incident Reporting – Relevant Legislation

• RIDDOR

• DCR Reg 9

• MAR Regs 21A, 21B, 21C and 21H

• SCR2015 Reg 29

• SCR2015 Reg 33

• Supplementary Reporting of HCRs

• Petroleum Operations Notices

• EU Commission Implementing Regulation



• RIDDOR

• DCR Reg 9


• SCR2015 Reg 29

• SCR2015 Reg 33





RIDDOR

• If you are still using the L73

document then get up to date!

• A revision to RIDDOR came into

force in October 2013.

• RIDDOR was further amended

by SCR2015, because of the

requirements of the European

Offshore Directive

• Guidance to RIDDOR is

available online


RIDDOR – Work Offshore

• Offshore workers are normally accommodated

offshore in between their work shifts.

• RIDDOR Regulation 2(3) provides that injuries to

workers while off-shift when offshore are reportable

in the same way as injuries during work shifts.

• For the purposes of the Regulations a person at an

offshore workplace is deemed to be at work at all

times when the person is there in connection with

his/her work

• Includes being on other installations when travelling


RIDDOR – Who Reports

• Reg 3 - ‘Responsible Person’ must report

• The Responsible Person (RP) is normally the

employer

• Except at an offshore installation when it is the duty

holder for everything other than:

– Occupational diseases, exposure to carcinogens,

mutagens & biological agents; diseases

• And except for dangerous occurrences at:

– a pipeline (the pipeline operator is the RP)

– a well (the well operator is the RP)


RIDDOR - Notifying and Reporting Deadlines

• RIDDOR (and several other statutory provisions)

requires that the responsible person notifies by the

quickest practicable means; for example, in the

event of:

– any major injuries & fatal accidents and;

– incidents with the potential to be, or escalate to, a

major incident.

• In practice, the quickest practicable means is to

notify by phone (and the legislative guidance says

so – eg L154 paras 318 and 334)



• RIDDOR Reg 13 requires that, in the event of a fatal

accident, major injury;

– the place where the incident happened must not

be disturbed, or anything tampered with

– for three days after notification of the incident or

the place has been visited by an inspector

• Reg 13 does not prohibit any person doing things

with the consent of an Inspector, and allows for

action necessary to secure the safety or integrity of

the workplace or of any person, plant, vessel or well.



• A written report must be made of:

• Offshore deaths and major injuries within 10 days.

• Other offshore reportable incidents within 10

working days.

• A working day means any day other than a Saturday,

Sunday, Christmas Day, Good Friday, or a bank

holiday under the Banking and Financial Dealings

Act 1971 in any part of Great Britain).


RIDDOR – Responsible Person Must Report

• Non fatal injuries to workers (Reg 4)

• Non fatal injuries to non-workers (Reg 5)

• Work related fatalities (Reg 6)

• Dangerous occurrences (Reg 7)

• Occupational diseases (Reg 8)

– Diseases offshore (Reg 10)

• Exposure to carcinogens, mutagens and biological

agents (Reg 9)


RIDDOR – Injuries and Incapacitation

Non fatal injuries - Regs 4(1) & 5

• Where a person suffers a defined accident at work

the responsible person must report it. The

regulations define the reportable accidents.

Person incapacitated for routine work - Reg 4(2)

• Where person is incapacitated for routine work for

more than seven consecutive days, the responsible

person must send a report as soon as practicable

and in any event within 15 days of the accident.


RIDDOR – Dangerous Occurrences Offshore

HCRs - Schedule 2 Pt 6 Para 75.

The unintentional release of petroleum hydrocarbon on

or from an offshore installation which

(a) results in

(i) a fire or explosion; or

(ii) the taking of action to prevent or limit the

consequences of a potential fire or explosion; or

(b)could cause a specified injury to, or the death of,

any person.



Fire or Explosion - Schedule 2 Pt 6 Para 76.

Any fire or explosion at an offshore installation, other

than one caused by the release of petroleum

hydrocarbon, which results in the stoppage of plant or

the suspension of normal work



Release of Dangerous Substance - Schedule 2 Pt 6

Para 77.

The unintentional or uncontrolled release or escape of

any substance (other than petroleum hydrocarbon) on

or from an offshore installation which could cause a

significant risk of personal injury to any person.



Schedule 2 Pt 6 – Offshore Dangerous

Occurrences

• Para 78 Unintended collapses that threaten integrity

• 79 Failure of station keeping equipment

• 80 Dropped objects that could cause injury

• 81 Weather damage that could cause injury

• 82 Vessel or aircraft collisions, or 83 potential

collisions



Schedule 2 Pt 6 – Offshore Dangerous

Occurrences

• Para 84 Seabed subsidence that threatens integrity

• 85 Loss of stability or buoyancy, any incident

• 86 Partial or complete evacuation of installation

• 87 Person falling into the water


RIDDOR – Dangerous Occurrences

Wells and Pipelines

• Para 20 Wells

• Applies onshore and offshore

• Reportable by the well operator

• Some overlap with HCR reporting

• Para 21 Pipelines

• Applies onshore and offshore

• Reportable by the pipeline operator

• Again, some overlap with HCR reporting if in the

500m zone



• RIDDOR

• DCR Reg 9


• SCR2015 Reg 29

• SCR2015 Reg 33





DCR – Danger to an Installation

• Reg 9(1) The duty holder shall ensure that, within 10

working days after the appearance of evidence of a

significant threat to the integrity of an installation, a

report is made to the Executive in writing identifying

such threat and specifying any action taken or to be

taken to avert it.

• DCR 9(2) Paragraph (1) shall not apply to anything

of which the Reporting of Injuries, Diseases and

Dangerous Occurrences Regulations 1995(1) require

a report to be made.



• RIDDOR

• DCR Reg 9


• SCR2015 Reg 29

• SCR2015 Reg 33





MAR – Notifying Death or Loss of a Person

Reg 21 - a return of death in the form set out in

Schedule 3 must be made when any person:

• dies on an offshore installation or;

• is lost from the installation or;

• dies in or on a lifeboat, life raft or other emergency

survival craft belonging to an offshore installation or;

• is lost from any of those places; or otherwise dies or

is lost in the neighbourhood of an offshore

installation while engaged in any operation

connected with the installationOSDR Industry Briefing – March 2016 23

MAR – Notifying Death or Loss of a Person

Regulation 21B

• The OIM completes Part 1 of the form and sends it to

the duty holder “as soon as is practicable and in any

event within ten days”

• Within 10 days from receipt, the duty holder

completes Part 2 of the form and sends it to the

Registrar General of Merchant Shipping & Seamen

• HSE Form OIR8 is the form, but it is planned to

integrate this in the ROGI form and withdraw OIR8


Notifying and Reporting Incidents - MAR

Obligation to notify death or loss of person

Regulation 21C

• Within 48 hours of first becoming aware of the death

or loss of the person, the duty holder must

• Notify the next of kin if the duty holder was the

employer or;

• Notify the person’s employer if the duty holder is not

the employer.

• Liaise with the Police over this in practice.



• RIDDOR

• DCR Reg 9


• SCR2015 Reg 29

• SCR2015 Reg 33






Regulation 21H - Safety Zone Infringement

• Certain types of vessels are prohibited from entering

or remaining in a safety zone except with the consent

of HSE; or consent given by the duty holder.

• A contravention of regulations means the vessel

owner and master are potentially guilty of an offence

and liable on conviction to a fine and/or

imprisonment.

• Safety Zone infringements are reported using HSE

form OIR13. Not changed by the ROGI form



• RIDDOR

• DCR Reg 9


• SCR2015 Reg 29

• SCR2015 Reg 33





Notifying and Reporting Incidents – SCR15

SCR 2015 Notification of major accident etc

• Reg 33 - duty on the operator, well operator or owner

(as applicable) to notify the competent authority

without delay of a major accident or a situation where

there is an immediate risk of a major accident.

• The notification should provide as much detail as

necessary to give a reasonable understanding of the

event.

• Almost inevitably RIDDOR plus other reporting

provisions will require a subsequent report.



SCR 2015 Regulation 29 - Duty to Control Risk

• Reg 29 - The competent authority must be notified

without delay where:

• a dutyholder takes suitable measures to reduce the

risk from an activity which significantly increases the

risk of a major accident

• Reg 29 itself requires no written report to be

submitted later, but it is possible a written report will

be required (eg under RIDDOR)



SCR 2015 Reg 29 Potential Examples

• Cumulative Risk resulting in a decision to shut down

production.

• Suspected flooded member resulted in decision to

ballast up and shut down production (Semi-sub

Floating Production Unit).

• Flexible riser defect sited underneath temporary

refuge resulted in decision to shut down field.



• RIDDOR

• DCR Reg 9


• SCR2015 Reg 29

• SCR2015 Reg 33





Reporting – HCR Supplementary Info.

• Lord Cullen’s recommendation (No.39) after the

Piper Alpha disaster;

• “The regulatory body should be responsible for

maintaining a database with regard to hydrocarbon

leaks, spills and ignitions in the industry and for the

benefit of the industry.”

• OIR12 is the form used, but it is planned to integrate

this in the ROGI form and withdraw OIR12

• Hydrocarbon Release Database maintained by HSE



• RIDDOR

• DCR Reg 9


• SCR2015 Reg 29

• SCR2015 Reg 33





Notifying and Reporting Incidents - PONs

Petroleum Operations Notices – Separate

Reporting Scheme – Remains Unchanged

• PON1 - Reporting oil and chemical releases and

permitted discharge notifications from offshore

installations and pipelines

• PON2 - Loss or dumping of materials at sea from

offshore oil and gas installations (dropped object)

• PON10 – Failure to provide lights, signals or other

aids to navigation (SECE)



• RIDDOR

• DCR Reg 9


• SCR2015 Reg 29

• SCR2015 Reg 33





Notifying and Reporting Incidents – EU Reg

EU Implementing Regulation

• Associated with the Directive and SCR2015 is EU

Commission Implementing Regulation No 1112/2014

[the Implementing Regulation].

• Acts directly on EU member states and specifies a

common reporting format for the sharing of

information on major hazard indicators by operators

and owners of offshore oil and gas installations.

• The Implementing Regulation is really a series of

forms for reporting various types of incident.



• EU Regulation requires reporting of events in a

number of categories:

A. Unintended release of gas, oil or dangerous substance.

B. Loss of well control.

C. Failure of a SECE.

D. Loss of structural integrity / loss of station keeping.

E. Vessel collision / potential collision.

F. Helicopter collision / potential collision.

G. Fatal accidents.

H. Serious injuries to 5 or more persons.

I. Evacuation of personnel.

J. Major environmental incident.



EU Implementing Regulation Overlap with GB Law

• Many of the EU reporting requirements are in

addition to, or overlap with, existing, relevant GB law,

for example:

• RIDDOR

• DCR Reg 9

• MAR Reg 21B

• Parts of the Supplementary HCR Scheme

• Parts of the PON Scheme




GB Existing Law EU Implementing Regulation

RIDDOR – Death or Injury

MAR – Death Notification

Category G, H

RIDDOR – Dangerous Occurrence (HCR)

& Cullen Recommendations Parts of Supplementary Scheme

Category A, B, C

RIDDOR – Dangerous Occurrence (Collisions) Category E, F

RIDDOR – Dangerous Occurrence - Evacuations Category I

DCR – Reg 9 – Loss of Integrity Category D, C

Parts of Petroleum Operations Notifications Category A, C, J

The ‘trigger’ creating a requirement to report is not always the same in GB law as in EU law (eg the Implementing Regulation qualifies an HCR for reporting by quantity, not its capacity to cause danger).

Notifying and Reporting Incidents

OSDR Industry Briefing – March 2016

PON 2

PON 10

PON 1

RIDDOROIR12

EUImplementingRegulation

DCRMAR

41

Notifying and Reporting Incidents – ROGI

Report of an Oil & Gas Incident – ROGI Form

• A single tool to use for reporting under the various

relevant pieces of legislation.

• Avoids duplication of reporting/reporting regimes,

and yet more forms to complete. Thus minimises the

burden on industry

• Tool also covers the reporting of incidents associated

with onshore borehole sites and all diving operations

• ROGI will replace HSE forms OIR8, OIR9B and

OIR12.OSDR Industry Briefing – March 2016 42


• Legally an installation needs to report incidents

under the EU Regulation after it has transitioned to

the 2015 regulations

• This may lead to situation where a Duty Holder has

different reporting regimes for different installations

at different times.

• The ROGI form gets round all that

• OGUK Board is content for the whole industry to start

reporting using the new ROGI form from January

2016



Reporting Law:

The EU Implementing

Regulation in Detail


Reporting Guidance Available

• EU guidance document on Commission Implementing

Regulation No. 1112/2014

• OSDR guidance on reporting offshore hydrocarbon releases

(how to complete the ROGI form for event A)

– Both documents available via links from OSDR website

www.hse.gov.uk/osdr/reporting/incidents-to-osdr.htm

• Operations Notice 30

– www.hse.gov.uk/osdr/assets/docs/operations-notice-30-

reporting-oil-gas-incidents.pdf

• L154 Guidance to the 2015 Safety Case Regulations

• O&GUK Supplementary guidance on reporting of HCRs rev 3


Event A : Releases

1. Any unintentional release of ignited gas or oil on or from an

offshore installation;

2. The unintentional release on or from an offshore installation

of:

a. not ignited natural gas or evaporated associated gas if

mass released ≥ 1kg;

b. not ignited liquid of petroleum hydrocarbon if mass

released ≥ 60 kg;

3. The unintentional release or escape of any hazardous

substance, for which the major accident risk has been assessed

in the report on major hazards, on or from an offshore

installation, including wells and returns of drilling additives.


Event A : Hydrocarbon Releases (HCRs)

• REPORTING OF HCRs NOT QUALIFIED BY

NEEDING TO HAVE THE POTENTIAL FOR DEATH

OR A SPECIFIED INJURY LIKE RIDDOR


Event A : Fugitive Emissions

• EU Guidance introduced the concept of fugitive emissions

which are not reportable.

• Definition of fugitive emission from EU Guidance:

– Fugitive emissions arise from loss of tightness from

hydrocarbon containment equipment such as valves,

flanges and other connections, pressure relief devices,

process drains, open-ended valves, pump and compressor

seal systems, agitator seals, and access door seals.

• Does not include releases due to degradation such as

corrosion pinholes or cracks in process containment systems:

– O&GUK Supplementary Guidance uses the term ‘non-

fugitive emissions’ for these scenarios.


Event A : Fugitive Emissions (cont.)

• EU Guidance defines reportability limits for fugitive

gas releases:

– 3 kg/h or a 20% LEL at 50 cm

– Consistent with old O&GUK supplementary guidance

• No limits were set by the EU for liquid releases.

• O&GUK supplementary guidance has included

‘fugitive equivalent’ limits for liquids:

– 100 kg/h (except methanol which is 80 kg/h)

– Taken from old O&GUK supplementary guidance


Event A : Fluids to be reported

• All hydrocarbon releases to be reportable.

• Includes hydrocarbon derivatives:– Diesel

– Fuel Oil

– Hydraulic oil

– Helifuel

– Lube oil

– Methanol

– Glycol

– Heat transfer oil

– Seal oil

– Oil based muds


Event A : Intentional Gas Releases

• From EU Guidance

– Where an intentional gas release, which is

considered a safe operation, escalates to the

extent where immediate actions in addition to the

arrangements for safe operation result either

automatically, or are required by manual

intervention, to reduce risks then this release

should be reportable.


Event A : Release of Dangerous Substances

• Releases of dangerous substances are reportable if:

- They have been identified as a potential major accident hazard in the safety case and;

- The release had the potential to cause death or serious personal injury.


Event A : Non-HCR Fires

• Section A2 of the form is used to report any non-

HCR fires:

• Was there a non-hydrocarbon fire (e.g. electrical)

with a significant potential to cause a major

accident?

• This section IS qualified by needing a significant

potential to cause a major accident.


Event B : Well Incidents

• Same reportability criteria as RIDDOR except for:

– Detection of H2S at a well not reportable to EU.

• Additional information is required for the EU.

• Minor releases from wells do not need to be

reported:

– Both RIDDOR and EU guidance is unclear on what constitutes a ‘minor release’.

– The reportability limits for event A HCRs will be used to determine whether a release is minor.


Event C : Failure of a SECE

• Failure of a SECE needs to be reported only if:

– The SECE fails during a major accident or;

– The SECE is reported by the independent verifier as lost or unavailable and requires immediate remedial action.

• The SECE is considered to be lost or unavailable if it

fails to meet its performance standard.

• SECEs would need to be unavailable on a system

level (e.g. a single gas head failure is not reportable,

but loss of a whole area would be).


Event C : SCR15 Definition of Major Accident

(a) an event involving a fire, explosion, loss of well control or the release of a

dangerous substance causing, or with a significant potential to cause, death or

serious personal injury to persons on the installation or engaged in an activity on

or in connection with it;

(b) an event involving major damage to the structure of the installation or

plant affixed to it or any loss in the stability of the installation causing, or with a

significant potential to cause, death or serious personal injury to persons on the

installation or engaged in an activity on or in connection with it;

(c) the failure of life support systems for diving operations in connection with

the installation, the detachment of a diving bell used for such operations or the

trapping of a diver in a diving bell or other subsea chamber used for such

operations;

(d) any other event arising from a work activity involving death or serious

personal injury to five or more persons on the installation or engaged in an activity

on or in connection with it; or

(e) any major environmental incident resulting from any event referred to in

paragraph (a), (b) or (d),


Event C : Failure of a SECE

• Failures associated with diving are not reportable to the EU, because it was not included in the definition of major accident in the EU Directive.


Event D : Loss of Integrity / Station Keeping

• EU Regulation requires reporting for:– Significant loss of structural integrity;– Loss of protection against the effects of fire or

explosion;– Loss of station keeping.

• However, loss of protection against the effects of fire

or explosion is to be reported under event C (from

EU Guidance).

• Incident reportable only if it requires immediate

remedial action.

• Not reportable under event D if it is already reported

under event C (failure of a SECE).OSDR Industry Briefing – March 2016 58

Event D : Loss of Integrity / Station Keeping

• Requirement to report overlaps with both RIDDOR

and DCR regulation 9.

• Very similar reporting criteria, and the EU guidance

has largely been based upon existing guidance from

RIDDOR and DCR.

• There has been no format for reporting under DCR in

the past, but section D of the ROGI form shall be

used going forward.


Event E : Vessel Collisions

• Requires reporting of actual collisions and potential

collisions which could jeopardise overall structural

integrity.

• Similar reporting requirements as RIDDOR.


Event F : Helicopter Accidents

• Requires reporting of actual collisions (similar to

RIDDOR), but also potential collisions.

• Will also be reported under CAA regulations

separately.


Event G & H : Fatal accidents / injuries

• Requires reporting of:

– Any fatal accident (Event G)

– Serious injuries to 5 or more persons (Event H)

• Was already reportable under the requirements of

EU Directive 92/91/EEC, and is already implemented

via RIDDOR.

• Section K of the ROGI form for RIDDOR incidents

used to report such accidents.


Event I : Evacuation of Personnel

• Any unplanned emergency evacuation of part of or

all personnel as a result of, or where there is a

significant risk of a major accident.

• Similar to the requirements in RIDDOR.

• No requirement to report:

– Exercises or precautionary evacuation due to welfare

issues.

– Transfer of personnel to avoid weather delays.

– Where evacuation is part of a Duty Holder’s safety

management system due to forecasted bad weather.


Event J : Major Environmental Incident

• Any major environmental incident as defined in

Article 2.1.d and Article 2.37 of Directive 2013/30/EU



The ROGI Form

Report of an Oil and Gas

Incident


What is the ROGI Form

• The ROGI form is a multi-part incident reporting tool

• It enables compliance with the reporting

requirements imposed by:

– SCR2015

– RIDDOR

– EU Implementing Regulation

– DCR

– MAR

– Supplementary HCR reporting



• The ROGI does NOT cover:

– Petroleum Operations Notices (PON)

– Infringement of a Safety Zone (OIR13)

• The ROGI form will replace forms OIR8, OIR9B, and

OIR12. Scheduled to be withdrawn in mid 2016

• The ROGI form scales according to the incident.

– In general, the worse the event, the more of it has

to be completed.



• The ROGI form was introduced in July 2015

• Currently a 45 page MS Word document

– ‘Helpfully long’ because it includes all the

regulatory criteria needed to decide if something is

reportable.

– No need to refer to separate documents

• ROGI will move to a different format to provide a

better end-user experience.

• Development work has begun.



ROGI gives a facility to submit:

• an initial report within the regulatory deadline

• updates, when more information is known eg

– to correct facts

– to provide information not available initially

– To submit supplementary HCR information when

calculated


ROGI Form Detail

Run through of form highlighting common mistakes /

issues.



Incident Reporting

Considerations Specific to

Wells, Pipelines


Wells and Pipelines Specifics

• Responsibility for reporting well and pipeline

incidents lies with the well operator or pipeline

operator respectively:

– Maintains consistency with RIDDOR reporting.

• Subsea wells connected to an installation are

considered part of the installation.

– Definition of the boundary of the well is defined in

the L84 guidance to well aspects of DCR.


Boundary of EU Reporting Regulation


500m

ZoneEU

ReportableEU

Reportable

Wellhead

Final

valve on

wellhead


Incident Reporting

Case Studies & Scenarios.

Discussion, Questions and

Answers


Case Study 1 : HCR Release

• Gas HCR from valve stem:

– 0.8kg released

– Release rate 3.5 kg/h

• RIDDOR reportable

• Not EU Reportable

• Fill in section A of the ROGI form


Case Study 2 : HCR Release

• Oil release from corroded pipework on topsides:

– 150kg released

– Release rate 200 kg/h

• EU and RIDDOR reportable

• Fill in section A (HCR) AND section C (failure of a

SECE) of the ROGI form


Case Study 3 : HCR Release (real example!)

• Pinhole corrosion oil leak from topsides pipework:

– 279kg released over 26 days

– Release rate 2ml / minute

• Not RIDDOR reportable

• EU Reportable

• Fill in section A of the ROGI form

• No need to fill in section C (failure of a SECE)

because there was no potential for a major accident


Case Study 4 : Release from pipeline in 500m

• Oil release from subsea corroded pipeline inside the

500m zone, pipeline shut down:

– 700kg released


• RIDDOR reportable under paragraph 21.

• EU Reportable under event A.

• Fill in section A of the ROGI form.

• May need to fill in section C (failure of a SECE)

depending upon the potential risks to persons.


Case Study 5 : Pipeline release outside 500m

• Oil release from subsea corroded pipeline outside

the 500m zone, pipeline shut down:

– 700kg released


• RIDDOR reportable under paragraph 21.

• Not EU Reportable.

• Fill in section K for RIDDOR events of the ROGI

form.


Case Study 6 : Failure of a SECE

• Lifeboat fails during ICP tests, and is taken out of

service.

• Immediate partial evacuation to reduce POB due to

unavailability of emergency response arrangements.

• EU Reportable as a failure of a SECE, and

evacuation of personnel.

• RIDDOR reportable due to evacuation of personnel.

• Fill in section C (failure of a SECE) AND section I

(evacuation of personnel).


Case Study 7 : Failure of a SECE (2)

• ESDV fails to close in accordance with the

performance standard during normal maintenance.

• RIDDOR reportable (under paragraph 21).

• Not EU reportable.

• Fill in section K for RIDDOR events of the form.


Case Study 8 : Loss of Structural Integrity

• Legs and jacking mechanism severely damaged

during jacking operations on a mobile rig. Rig

immediately returns to port for repairs.

• Reportable under DCR regulation 9.

• EU reportable : event D.

• On first glance it looks like section D should be

completed.


Case Study 8 : Loss of Structural Integrity (2)

• However, the event could be considered to be a major accident, as it had the potential to cause death or serious injury.

• If so, event C (failure of a SECE) should be completed.

• No requirement to also report as an event D for the EU.

• However, still need to report under DCR (which is included in event D).

• Complete both sections C and D of ROGI form:

– But tick the correct the boxes for event categorisation (event C for the EU, event D for DCR).


Case Study 9 : Macondo type scenario

• Would clearly be RIDDOR and EU reportable.

• Would need to fill in sections:– A : HCRs

– B : Well Incident

– C : Failure of a SECE

– G & H : Fatalities and serious injuries (but would use

section K of the form)

– I : Evacuation of personnel

– J : Major environmental incident

– L : Death of loss of a person

• No need for section D (loss of integrity or stability) because it

is covered by section C.


Questions / Discussion


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