COVID-19

 

The social and economic impact of COVID-19 is unprecedented, and government and industry have taken a number of actions to ensure resilience across the downstream oil sector. UKPIA has compiled a series of links to official sources with information relevant to customers, employees and contractors across the downstream oil industry.

 

This includes:

1. Advice regarding downstream oil sector training schemes

2. Advice for people working in the downstream oil sector

3. Advice on regulatory changes relevant to the downstream oil sector

4. Advice on financial facilities relevant to the downstream oil sector

1. Advice regarding downstream oil sector training schemes

Safe Loading Pass Scheme (SLPS) Amendments

Recognised by members of UKPIA and the Tank Storage Association (TSA), the Safe Loading Pass Scheme (SLPS) aims to identify vehicles and trailers that have been deemed to meet specified safety standards for admittance to fuel loading terminals. The following link sets out amendments to the scheme with advice for hauliers and terminals:

 

COVID-19: amendments to the SLPS
Extension of all Safety Pass Alliance accredited passport schemes

UKPIA and our members have been involved in a number of industry-led safety schemes operated by the Safety Pass Alliance (SPA), such as the UKPIA Forecourt Contractor Safety Passport Scheme. As a result of COVID-19, SPA agreed to grant a 3 month grace period for renewals to their passport scheme, which began in March. Training is now beginning again, all details at the SPA website:

COVID-19: SPA Passport scheme
Petroleum Driver Passport (PDP) Scheme

The Downstream Oil Distribution Forum (DODF) have reviewed the PDP Scheme in the light of the COVID-19 pandemic, taking into account UK Government guidance. The attachment contained at the link below details an extension of PDP cards (that expire between 1st March - 1st November) until 30th November 2020 as well as a relaxing rules on annual refresher training:

COVID-19: PDP scheme amendments

2. Advice for people working in the downstream oil sector

General Guidance for Employers, Employees and Businesses

The following blue link contains general advice for employees, employers and businesses regardless of sector, with information on what to do as a result of COVID-19. There is also specific information for Northern Ireland, Scotland and Wales

COVID-19: guidance for businesses
Apprenticeship Programme Guidance

The following link sets out guidance from the Department for Education (DfE) for apprentices, employers, training providers and assessment organisations in response to the impact of coronavirus (England only):

COVID-19: apprenticeship programme response
Essential Worker Definitions

Following the decision to close schools, colleges and other educational provision as a result of COVID-19, the UK Government and Devolved Administrations have identified essential workers to ensure they can continue working by sending their children to school. The following link contains definitions of what constitutes an essential worker:

COVID-19: guidance on maintaining educational provision
Driver Welfare Arrangements

There have been reports that some drivers, such as petroleum tanker drivers, are not being allowed to use welfare facilities when making deliveries. Preventing access is against the law and is not sensible. Those who already provide reasonable access to toilets and handwashing facilities should continue to do so. The following link provides further information from the HSE:

COVID-19: HSE advice for driver welfare arrangements
Annual Leave Carry Over for Key Industries

The UK Government has announced that workers in key industries who have not taken all of their statutory annual leave entitlement due to COVID-19 will now be able to carry it over into the next 2 leave years. The following link contains further information:

COVID-19: carry over leave for key industries
Social distancing during in-work activities

Social distancing is one of the key measures announced by public health authorities in how to tackle the transmission of COVID-19. The following link offers advice from the HSE for people currently in work - such as essential workers at petrol stations, fuel terminals and refineries - on how to maintain social distancing requirements in your place of work:

COVID-19: HSE advice for social distancing at work
Key Worker Testing

Testing for people in England and Northern Ireland who have coronavirus-like symptoms to see if they currently have the virus has been extended to include all those defined as Key Workers, including those in the oil and gas sectors. Separate guidance is available for Scotland and Wales. The following link contains guidance on who can be tested, how to arrange a test and the testing process:

COVID-19: key worker testing
Test and Trace

The NHS test and trace service:

  • ensures that anyone who develops symptoms of coronavirus (COVID-19) can quickly be tested to find out if they have the virus, and also includes targeted asymptomatic testing of NHS and social care staff and care home residents
  • helps trace close recent contacts of anyone who tests positive for coronavirus and, if necessary, notifies them that they must self-isolate at home to help stop the spread of the virus
NHS Test and Trace Advice
Government rules that have been relaxed to respond to COVID-19

The Government is continuing to update the wider public about changes to their policies in response to the COVID-19 pandemic, whilst not all of them are relevant to the Downstream Oil Sector, there is some useful information. They have put together a list of the rules that have been temporarily relaxed to make it easier for businesses to continue working through the disruption caused by coronavirus (COVID-19). 

Rules that have been relaxed to help businesses
Guidance on International Arrivals

In order to slow the spread of COVID-19, the Government has implemented a process of staying in a single location for 14 days from the day of your arrival, unless you are granted an exemption. In very limited circumstances, if travelling for a work related matter, your company can apply for an exemption. 

Travellers exempt from border rules in the UK

3. Advice on regulatory changes relevant to the downstream oil sector

MOTs for Heavy Vehicles Suspended

As well as many other businesses, downstream oil sector companies and supply chain contractors use heavy goods vehicles. The following link contains information for businesses and individuals, not just limited to the downstream oil sector, following the government's decision to suspend MOTs for heavy vehicles for up to 3 months to help tackle COVID-19:

23/07/2020 - UPDATE:

You can book a lorry, bus or trailer annual test (MOT) from 4 July 2020 - the deadline to get the test done depends on when the MOT was originally due.

 

COVID-19: MOTs for lorries, buses and trailers
MOTs for Vehicles needing a Dangerous Goods (ADR) Test

Deliveries of dangerous goods under the ADR regime are not captured in the same way as MOTs for other heavy vehicles and the changes for COVID are also different. DfT has provided Authorisation 945 which allows for an annual inspection waiver so tanker operators can “continue using such vehicles whilst DVSA are unable to carry out annual roadworthiness tests and annual ADR technical inspections”. In order to continue using these vehicles, operators will need to apply to the DVSA and guidance at the link below informs how this needs to be done:

COVID-19: MOTs for vehicles needing an ADR test
Hand Sanitser Production

Given the increase in hand washing and use of hand sanitiser as advised by Public Health Authorities, the HSE has provided advice on the production of hand sanitiser, relaxation of who can provide the components as well as derogations from product authorisation requirements.

COVID-19: manufacture of hand sanitiser
Temporary Relaxation of Drivers' Hours

Across the downstream oil sector, such as for tanker delivery personnel, drivers' working hours are being changed as a result of COVID-19. The following link contains information for businesses and individuals, not just limited to the downstream oil sector, on how these rules are being temporarily relaxed:

 

UPDATE: 14 June 2020 - The Temporary Relaxation of Drivers Hours was withdrawn.

COVID-19: relaxation of enforcement of drivers' hours rules
Exemption for Petrol Stations from Premises Closures

Petrol stations are listed as exempt from the UK Government's instruction to close all retail sites trading in non-essential goods. The following link provides guidance on the closure of all retailers that sell non-essential goods and other non-essential premises, as part of further social distancing measures:

COVID-19: guidance for businesses and premises to close
Health and safety regulation

Health and safety remains the top priority for the downstream oil sector, especially under the additional challenges posed by COVID-19. Guidance available via the following link explains how the HSE will continue its regulatory oversight of sites who remain the legal duty holders during the COVID-19 pandemic:

COVID-19: regulating occupational health and safety
Driver CPC training changes

Most professional lorry and bus drivers - including those in the downstream oil sector - must complete 35 hours periodic training every 5 years to maintain a Driver CPC card (sometimes called a ‘driver qualification card’ or ‘DQC’). During COVID-19 it may be difficult for drivers to complete the required training. The following link explains temporary changes put in place by the Department for Transport in professional driver qualification requirements:

COVID-19: driver CPC changes
Lifting and pressure equipment testing

COVID-19 means there may be potential challenges when carrying out legal requirements for thorough examination and testing (TE&T) of plant and equipment, however, the law for Lifting Operations and Lifting Equipment Regulations (LOLER) and Pressure Systems Safety Regulations (PSSR) remain in place. The following link from the HSE explains how dutyholders can ensure that their work plant and equipment remain safe to use and how TE&T requirements can still be met:

COVID-19: lifting and pressure equipment testing
Environmental Monitoring Regulations

The Environment Agency has published a Regulatory Position Statement (RPS) titled ‘Monitoring emissions from installations, radioactive substances and waste sites’. This RPS explains when operators of sites in England can delay and reschedule some emissions to air and water monitoring and other environmental monitoring up to 30th June 2020 because of COVID-19 restrictions:

COVID-19: environmental monitoring regulation
Driver Medical Relaxation

The Department for Transport has issued a temporary relaxation of the requirement for bus and lorry drivers to provide a doctor’s medical report in order to renew their licence. This temporary change will only apply to those drivers whose licences are due to expire or have expired since 1st January 2020. Use the following link to find out more:

COVID-19: driver medical relaxation
COMAH Notification Requirements

The HSE has published a new position statement agreed by the COMAH Competent Authority covering COMAH notifications during COVID-19. Use the link for guidance for businesses normally out of scope entering COMAH through coronavirus, advice for re-notification requirements for existing COMAH sites, enforcement considerations, safety reports for COMAH upper tier sites and hazardous substances consent:

COVID-19: COMAH notification requirements
Regulation of Chemicals

The HSE has made some administrative changes to their services for regulating chemicals during COVID-19.

The following link sets out each chemical regime with their updated details, including REACH and CLP:

 

COVID-19: REACH and CLP regulation

4. Advice on financial facilities relevant to the downstream oil sector

Job Retention Scheme

Use the following link to find out if your business is eligible for the Coronavirus Job Retention Scheme and how much you can claim to cover wages for employees on temporary leave (“furlough”) due to COVID-19:

COVID-19: job retention scheme
Financial Support for Businesses

A full range of business support measures have been made available to UK businesses, including SMEs and large businesses. The following link help businesses find out how to access the support that has been made available, who is eligible, when the schemes open and how to apply:

COVID-19: financial support for business
Environment Agency regulatory response to coronavirus

The Environmental Agency has said:

We recognise the difficulties you are facing as a result of coronavirus (COVID-19). We expect you to take all reasonable steps to comply with regulatory requirements, using contingency plans to help you comply.

However, if requirements are unable to be met, then firms must meet certain criteria. For an overview please click the link below.

Environment Agency regulatory response to coronavirus
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