Environmental Report 1999 Index

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The Way Forward As we said earlier, UKOOA has established a set of principles which will guide our discussions as the Government establishes a new regulatory regime. In the present economic climate, we consider it vitally important that environmental regulation should be cost-effective, recognise that each facility is different, and offer flexibility in the way that environmental impacts are controlled. Continual improvement of the industry's environmental performance depends on considering each facility's emission streams holistically. Such an approach provides a way of achieving a superior environmental performance while minimising the costs to industry. At the same time, it would minimise the Government's administrative costs and protect jobs and the revenue the industry pays to the Exchequer. We believe that improved environmental performance can best be achieved through comprehensive environmental management systems and long term goal setting, instead of the more traditional 'command and control' approach to regulation. One of the strengths of the goal-setting, risk-based approach, is that it can be adapted to specific circumstances. Flexibility is particularly important in environmental management because science is constantly evolving and new technologies are being developed. Sound scientific analysis should be used to assess environmental risks and impacts for each facility, since different installations have different emission and discharge characteristics and are located in different environments. Environmental performance objectives and targets should be based on the potential environmental risks likely to arise over short, medium and long terms from normal, abnormal and accidental events, whilst delivering a continual improvement in pursuing excellence in standards or operation. In their day-to-day operations, offshore operators already use Safety Management Systems that are based on the goal-setting health and safety regime introduced following Lord Cullen's report into the Piper Alpha disaster. Many of these systems also encompass environmental issues. The new legislative proposals provide an unmissable opportunity to align offshore environmental regulation with a health and safety system that has worked effectively over a period of years. Our member companies welcome the opportunity to demonstrate how their Environmental Management Systems work in practice, and to show how the environmental criteria relating to a development are applied throughout its lifetime. In summary, we believe that: environmental protection goals should be clear and measurable; methods for achieving environmental goals should be flexible and promote innovation; the regulatory process should be transparent and include consultation with stakeholders; the tasks of understanding the environment, assessing risks, advancing technology, and identifying and monitoring environmental impacts should be firmly based on sound scientific methods. We have a duty to assist the public's understanding of the science that underlies environmental issues; a balance should be struck between the achievement of environmental goals, technological feasibility and the ability of our industry to continue to contribute benefits to society.