The Offshore Installations (Safety Zones) Order 2026
Abstract
The Offshore Installations (Safety Zones) Order 2026 (SI 2026 No. 635) establishes 500-metre radius safety zones around three specific subsea installations – Global Producer III, Solan, and Wenlock – located in UK waters. Made under section 22 of the Petroleum Act 1987, this Order is crucial for maintaining safety during the ongoing dismantlement phases of these installations, replicating the protection that would typically apply automatically to surface installations. It also concurrently revokes safety zones for installations that are no longer present or require such protection. The Order reinforces the UK's robust offshore safety regime, impacting maritime operations, environmental protection, and the legal obligations of vessel operators navigating the UK Continental Shelf.
Introduction
The United Kingdom's offshore energy sector operates under a stringent regulatory framework designed to ensure safety, protect the marine environment, and manage maritime traffic effectively. A recent development in this framework is the promulgation of The Offshore Installations (Safety Zones) Order 2026 (SI 2026 No. 635), which came into force 21 days after its making on 15 June 2026. This Statutory Instrument specifically designates 500-metre safety zones around three critical subsea installations: Global Producer III, Solan, and Wenlock.
This Order is not merely a routine administrative update; it represents a targeted application of established safety principles to evolving offshore infrastructure. Its primary purpose is to ensure continuous protection during the complex and inherently risky dismantlement phases of these subsea installations, thereby replicating the 'automatic' safety zones that would typically apply to installations projecting above the sea surface. For legal practitioners, understanding the nuances of this Order is vital, as it directly impacts compliance requirements for maritime operators, liability considerations, and the broader regulatory landscape governing activities on the UK Continental Shelf.
This article will delve into the statutory basis, practical implications, and broader context of the 2026 Order, highlighting its significance for attorneys advising clients involved in offshore energy, shipping, and marine operations. It will explore how this specific instrument fits within the UK's comprehensive offshore safety regime and what practitioners need to consider regarding its enforcement and potential future developments.
Background
The establishment of safety zones around offshore installations in the United Kingdom is primarily governed by the Petroleum Act 1987 (c. 12). Section 21 of the Act provides for the automatic establishment of 500-metre safety zones around installations that project above the sea surface at any state of the tide, where certain activities (such as exploitation, exploration, storage of gas, or accommodation) are carried out or where the installation is being assembled or dismantled. However, for subsea installations, which do not project above the surface, safety zones are not automatically established and require specific statutory instruments, such as the Order under review, to be created by the Secretary of State.
The authority for the Secretary of State to establish such zones by order is derived from section 22(1) of the Petroleum Act 1987. These zones apply to waters to which section 21(7) of the Act applies, encompassing both territorial waters and areas designated under section 1(7) of the Continental Shelf Act 1964 (c. 29). The Continental Shelf Act 1964 itself extended the UK's jurisdiction over the seabed and subsoil and their natural resources beyond territorial waters, allowing for the designation of areas where the UK exercises sovereign rights. The 500-metre radius for safety zones is an internationally recognised standard, supported by Article 60 of the United Nations Convention on the Law of the Sea (UNCLOS) 1982, which permits coastal states to establish such exclusion zones.
Historically, these safety zones have been a cornerstone of offshore safety policy, designed to protect personnel working on installations, safeguard the installations themselves from damage, and reduce the risk of collisions for mariners. The Health and Safety Executive (HSE) plays a pivotal role in this regime, often proposing the establishment of such zones and granting consents for entry under specific circumstances. The broader regulatory landscape also includes the Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015, which mandate safety cases for offshore installations, further embedding a comprehensive approach to major accident hazard control.
Analysis
The Offshore Installations (Safety Zones) Order 2026, through Article 2, precisely defines the new safety zones with a 500-metre radius from specified points around the Global Producer III, Solan, and Wenlock installations, using World Geodetic System 1984 (WGS 84) coordinates. A critical aspect highlighted by the Explanatory Note is that these zones are established specifically to maintain protection during the ongoing dismantlement phases of these installations, which are subsea. This is a crucial distinction, as installations that project above the sea surface benefit from 'automatic' safety zones under section 21 of the Petroleum Act 1987, whereas subsea installations require a specific statutory instrument. The Order thus ensures that the safety provisions remain in effect even as the installations transition out of active production.
The legal implications of these safety zones are significant. Section 23(1) of the Petroleum Act 1987 explicitly prohibits vessels, including hovercraft, submersible apparatus, and installations in transit, from entering or remaining within a safety zone without the consent of the Health and Safety Executive (HSE) or in accordance with specific regulations. Infringement of a safety zone is a criminal offence, carrying potential penalties of imprisonment for up to two years, an unlimited fine, or both, upon conviction on indictment. This strict enforcement mechanism underscores the importance placed on these zones for safety and environmental protection. Exceptions to this prohibition are narrowly defined and include circumstances such as saving life or property, distress, bad weather, or specific authorised activities like laying or repairing submarine cables or pipelines, or providing services to the installation.
For maritime operators, the establishment of these zones necessitates diligent adherence to navigation warnings and updated charts. The UK Hydrographic Office (UKHO) publishes nautical charts and Admiralty Notices to Mariners, and radio navigation warnings are broadcast to inform mariners of the existence and location of these safety zones. The reliance on external documentation places a continuous burden on vessel operators to maintain up-to-date navigation data. The Order also concurrently amends previous orders by removing safety zones related to the Thames Bure Wellhead, Thames Yare Wellhead, and the Victoria Subsea Production Well, indicating a dynamic regulatory approach that adapts to the lifecycle of offshore infrastructure. This demonstrates a commitment to ensuring that safety zones are both effective and relevant, avoiding unnecessary restrictions where installations are no longer present or pose a risk.
The focus on subsea installations undergoing dismantlement highlights a particular area of risk management. Unlike visible surface installations, subsea infrastructure can be less apparent to passing vessels, increasing the potential for accidental interference or damage. The statutory instrument mechanism for subsea zones, therefore, provides a critical layer of protection for these vulnerable assets and the personnel involved in their decommissioning. The process for establishing such zones typically involves consultation, including with fishermen's organisations, to balance safety needs with other legitimate sea uses.
Conclusion
The Offshore Installations (Safety Zones) Order 2026 is a targeted yet significant piece of legislation that reinforces the UK's commitment to safety and environmental stewardship in its offshore waters. By establishing statutory safety zones around specific subsea installations undergoing dismantlement, the Order ensures that critical protections remain in place during a high-risk phase of their lifecycle. This proactive approach safeguards personnel, prevents damage to infrastructure, and mitigates potential environmental hazards, aligning with both national legislation and international maritime conventions.
For legal practitioners, this Order underscores the ongoing need for vigilance and comprehensive advice to clients operating in the UK Continental Shelf. Operators of vessels, particularly those engaged in fishing, shipping, or other offshore activities, must be acutely aware of these newly designated zones and the strict prohibitions on entry. Failure to comply carries substantial legal and financial risks. Practitioners should advise on the importance of consulting updated nautical charts, notices to mariners, and maintaining a continuous listening watch on VHF channel 16 when navigating in areas of offshore activity. As the UK's offshore energy landscape continues to evolve, with increasing focus on decommissioning and new energy technologies, similar statutory instruments are likely to emerge, requiring continuous monitoring and proactive compliance strategies.
Citations
- 1.The Offshore Installations (Safety Zones) Order 2026, SI 2026/635.
- 2.Petroleum Act 1987, c. 12.
- 3.Continental Shelf Act 1964, c. 29.
- 4.The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015, SI 2015/398.
- 5.United Nations Convention on the Law of the Sea (UNCLOS) 1982, Article 60.
