With the launch of the UK's carbon capture, usage and storage vision, progress being made on the Acorn project, and the announcement earlier this year that contractors have been selected for the East Coast Cluster project, the CCS market in the UK is picking up pace. The idea of operational CCS projects will (reasonably) soon become a reality.
As we move from the theory to practice of CCS, one of the key questions for the energy industry is how the health and safety aspects of CCS operations will be regulated. Will it be an extension of the existing, very familiar regime, or will new regulations be brought in to address the specific risks associated with CCS operations?
Given its relative infancy, the answer to that question will change as the CCS industry matures and the HSE and Government adapt their approach. For the moment, the regulatory regime that will apply to CCS operations is exactly the same as currently applies for all other offshore (and onshore) activities.
There are undoubtedly risks associated with the capture, transportation and storage of carbon dioxide, and it is already listed as a hazardous substance under the COSHH Regulations. In higher concentrations it can cause confusion, dizziness and a loss of consciousness, and in confined spaces it can displace oxygen resulting in asphyxiation. So, it is a direct risk to human health, but it can also cause symptoms which themselves are a known cause of workplace accidents.
The risks of leaks during transportation, whether by pipeline, road or rail, and long-term storage will need to be addressed. Even a minor leak could have catastrophic consequences if it affected the driver of a tanker transporting CO2. These risks will be particularly acute onshore, where there will be a greater risk of other road users, or nearby residential and industrial areas being affected.
Similarly, the initial transfer of the gas into storage facilities will present particular risks. At that point the CO2 will be at very high pressures, where the HSE recognises that it has major accident hazard potential. The HSE's current guidance makes it clear that further research is needed in order to understand (i) how CO2 behaves when released and how it disperses (presumably in both air and water), (ii) safe separation distances between pipelines or storage facilities, and other residential, commercial or industrial areas, and (iii) the appropriate design and construction standards for pipelines.
That need for further research and our very early stage in the life of CCS means that the existing suite of UK Health and Safety regulations have not been amended to specifically address carbon dioxide or CCS operations. CO2 is not (yet) listed as a dangerous substance under the Control of Major Accident Hazards Regulations, or as a dangerous fluid in terms of the Pipeline Safety Regulations. The Offshore Installations (Safety Case) Regulations will only apply if extended oil recovery is being undertaken alongside CCS operations.
However, even without specific regulations being introduced in the future, there are still very significant health and safety duties incumbent on those constructing, and in due course operating, CCS projects. The overarching duties under Sections 2 and 3 of the Health and Safety at Work etc. Act 1974, to take all reasonably practicable steps to protect the health and safety of employees and those who might be affected, will apply to CCS operations as much as any other.
The good news for those in the energy supply chain looking to transition into the CCS market is that the well-established, robust procedures already in place for ensuring the safety of those working with hydrocarbons offshore, will likely be more than sufficient to meet any new duties which come to apply as the CCS industry, and the regime to regulate the safety of it, matures.
As first published in OGV Energy Magazine.
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