UK Offshore Renewables Operators & Developers

UK Offshore Renewables Operators & Developers - Are You Ready for the Regulatory Deep Dive?

Last week, whilst assisting a client during an HSE annual visit, an intriguing point was made that has resonated with me since, especially in the context of the renewable energy sector.

Historically, the distinction between Onshore/Inland/Inshore and the Offshore Approved Code of Practice (ACOP) was defined by an invisible line: the 12 Nautical Mile Limit. However, the landscape of diving operations, particularly those related to renewable energy structures like wind farms, is evolving rapidly, and with this evolution comes a pressing need for compliance.

The Commercial Diving Projects Offshore Diving at Work Regulations (ACOP) (L103/2014 Revision) extends its reach beyond traditional boundaries. It clearly states that the Code applies to all diving projects, including those undertaken in connection with offshore installations and energy structures, such as wind farms and emerging energy technologies. This inclusion is significant because it encapsulates operations where closed bell or saturation diving techniques are used, as well as operations from vessels maintaining station through dynamic positioning, regardless of their proximity to shore. The HSE’s emphasis on dynamic positioning (DP) based operations falling within the Offshore Code, irrespective of location, was a pivotal moment. It underscored a crucial realisation for constructors of offshore wind farms: their operations, no matter where they are situated, are enveloped within the Offshore ACOP requirements for compliance.

What does this mean for renewable operators? The current regulatory framework necessitates a rigorous and regulatory compliant diving safety management system. Ensuring alignment with HSE standards is no longer a matter of geographical demarcation but of operational scope and technique. This expanded interpretation of the regulations means that renewable energy operators, particularly in the offshore wind sector, are expected to adopt stringent subsea safety protocols akin to those in traditional offshore oil and gas projects.

The Approved Code of Practice and associated guidance (IMCA D 014) provide a framework of practical advice to ensure compliance with the Diving at Work Regulations 1997. This Code spans diving projects at sea outside the UK territorial waters adjacent to Great Britain, diving operations in UK designated areas of the continental shelf connected with offshore installations, and energy structures like wind farms. It also includes operations where closed bell or saturation diving techniques are used and those from vessels using dynamic positioning.

The implications of the 2014 Edition of the L103 ACOP are far-reaching, signalling a challenging era of regulatory compliance for the renewable energy industry. It's a critical moment for transitional energy operators to reassess their diving and subsea safety management systems, ensuring they are robust, comprehensive, and aligned with the highest standards of diving safety, as mandated by the Offshore Diving at Work Regulations 1997 and its associated ACOP. This alignment is not just about legal compliance; it's about safeguarding the lives of those who work in these challenging environments and ensuring the sustainable growth of the renewable energy sector in a conformant way.

Archer Knight is a trusted leader in commercial diving safety and technical advisory, renowned for our extensive experience and solid track record. We serve Operators, prime EPIC Contractors, and service companies, providing support for diving subcontracted services, enhanced by our specialised Diving Technical Authority (TA) ongoing support. Our commitment to safety, efficiency, and technical excellence makes us the preferred partner for complex underwater operations, ensuring reliable outcomes for our clients in the challenging maritime and subsea landscapes.

If you’re a renewables operator working in the UK and you would like to know more about how Archer Knight can assist you in ensuring your diving and subsea safety management system is fit for purpose, feel free to contact us at divingta@archerknight.com

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