BP 2015 Annual Report Download - page 239

• The Maritime Transportation Security Act, the DOT Hazardous
Materials (HAZMAT) and the Chemical Facility Anti-Terrorism Standard
regulations impose security compliance regulations on around 15 BP
facilities.
• OPA 90 is implemented through regulations issued by the EPA, the
US Coast Guard, the DOT, OSHA, the Bureau of Safety and
Environmental Enforcement and various states. Alaska and the West
Coast states currently have the most demanding state requirements.
• The Outer Continental Shelf Land Act and other statutes give the
Department of Interior (DOI) and the Bureau of Land Management
(BLM) authority to regulate operations and air emissions on offshore
and onshore operations on federal lands subject to DOI authority. New
stricter regulations on operational practices, equipment and testing
have been imposed on our operations in the Gulf of Mexico and
elsewhere following the Deepwater Horizon oil spill.
European Union
• In October 2014, the European Council agreed on new climate and
energy targets for the period up to 2030. Specifically, Member States
have agreed to a 40% reduction in GHG emissions below 1990 levels
and to a 27% share of renewable energy in final energy consumption.
Specific EU legislation and agreements required to achieve these goals
are not yet in place.
• The 2008 EU Climate and Energy Package is expected to remain in
place until 2020 and includes an updated EU Emissions Trading
System (EU ETS) Directive (see Greenhouse gas regulation below), the
EU Fuel Quality Directive and the Renewable Energy Directive.
• The EU Fuel Quality Directive affects our production and marketing of
transport fuels. Revisions adopted in 2009 mandate reductions in the
life cycle GHG emissions per unit of energy and tighter environmental
fuel quality standards for petrol and diesel.
• The Renewable Energy Directive requires Member States to have 10%
(by energy content) of final transportation fuel to be derived from
renewable energy, such as biofuels and renewable electricity. This
target must be met by the end of 2020.
• The Energy Efficiency Directive (EED) was adopted in 2012. It requires
EU Member States to implement an indicative 2020 energy saving
target and apply a framework of measures as part of a national energy
efficiency programme, including mandatory industrial energy efficiency
surveys. This directive has been implemented in the UK by the Energy
Savings Opportunity Scheme Regulations 2014, which affects our
offshore and onshore assets. The ISO50001 standard is being
implemented by organizations in some EU states to meet some
elements of the Energy Efficiency Directive.
• The Industrial Emissions Directive (IED) 2010 provides the framework
for granting permits for major industrial sites. It lays down rules on
integrated prevention and control of air, water and soil pollution arising
from industrial activities. This may result in requirements for BP to
further reduce its emissions, particularly its air and water emissions. As
part of the IED framework, additional emission limit values are
informed by the sector specific and cross-sector Best Available
Technology (BAT) Conclusions, such as the BAT Conclusions for the
refining sector and for combustion.
• The National Emission Ceiling Directive 2001 is currently being revised
and subsequent source-control measures by Member States may be
required to meet national emissions targets. These may result in
further emission reduction requirements.
• The EU regulation on ozone depleting substances (ODS) 2009 requires
BP to reduce the use of ODS and phase out use of certain ODSs. BP
continues to replace ODS in refrigerants and/or equipment in the EU
and elsewhere, in accordance with the Montreal Protocol and related
legislation. In addition, the EU regulation on fluorinated greenhouse
gases with high global warming potential (the F-gas Regulations) came
into force on 1 January 2015. The F-gas Regulations require a phase-
out of certain hydrofluorocarbons, based on global warming potential.
• European regulations also establish passenger car performance
standards for CO2tailpipe emissions (European Regulation (EC) No
443/2009). From 2020 onwards, the European passenger fleet
emissions target is 95 grams of CO2per kilometre. This target will be
achieved by manufacturing fuel efficient vehicles and vehicles using
alternative, low carbon fuels such as hydrogen and electricity. In
addition, vehicle emission test cycles and vehicle type approval
procedures are being updated to improve accuracy of emission and
efficiency measurements. Consequently, product mix and overall levels
of demand will be impacted.
• European vehicle CO2emission regulations also impact the fuel
efficiency of vans. By 2020, the EU fleet of newly registered vans must
meet a target of 147 grams of CO2per kilometre, which is 19% below
the 2012 fleet average.
• The EU Registration, Evaluation Authorization and Restriction of
Chemicals (REACH) Regulation requires registration of chemical
substances manufactured in or imported into the EU, together with the
submission of relevant hazard and risk data. REACH affects our
refining, petrochemicals, exploration and production, biofuels,
lubricants and other manufacturing or trading/import operations. In
accordance with the required phase-in timetable, BP completed
registration of all substances in tonnage bands equal to or greater than
100 tonnes per annum/legal entity, and is in the process of preparing
registration dossiers for substances manufactured or imported in
amounts in the range 1-100 tonnes per annum/legal entity that are
currently due to be submitted before 31 May 2018 or checking that BP
imports are covered by the registrations of non-EU suppliers’ only
representatives. BP continues to maintain compliance by submitting
registrations to cover new manufactured and imported substances,
and to update previously submitted registrations as required. Some
substances registered previously, including substances supplied to us
by third parties for our use, are now subject to evaluation and review
for potential authorization or restriction procedures, and possible
banning, by the European Chemicals Agency and EU Member State
authorities.
• In addition, the EU implemented the UN’s Globally Harmonized
System of Classification and Labelling of Chemicals (GHS) through the
Classification Labelling and Packaging (CLP) Regulation. This requires
BP to reassess the hazards of all our chemicals and products against
the new GHS criteria as adopted or modified by the EU and to update
warning labels and safety data sheets accordingly. From 1 June 2015,
the CLP Regulation applies in full to mixtures (e.g. lubricants) that are
placed on the market. A separate EU regulation on export and import
of hazardous chemicals requires warning labels and safety data sheets
accompanying EU exports to be compliant with relevant CLP and
REACH requirements (unless this conflicts with requirements in the
importing country) and, as far as practicable, in the official or one or
more principal languages of the intended area of use. Safety data
sheets for the EU market have been updated to include both REACH
and CLP information.
• The EU Offshore Safety Directive was adopted in 2013. Its purpose is
to introduce a harmonized regime aimed at reducing the potential
environmental, health and safety impacts of the offshore oil and gas
industry throughout EU waters. The Directive has been implemented in
the UK primarily through the Offshore Installations (Offshore Safety
Directive) (Safety Case etc.) Regulations 2015.
• The implementation of the Water Framework Directive 2000 and the
Environmental Quality Standards Directive 2008 may mean that BP has
to take further steps to manage freshwater withdrawals and
discharges from its EU operations.
Regulations governing the discharge of treated water have also been
developed in countries outside of the US and EU. This includes
regulations in Trinidad and Angola. In Trinidad, BP has been working with
the regulators to apply water discharge rules arising from the Certificate
of Environmental Clearance (CEC) Regulations 2001, and associated
Water Pollution Rules 2007. In Angola, BP has been upgrading produced
water treatment systems to meet revised Oil in Water limits for produced
water discharge under Executive Decree ED 97-14 (superseded ED 12/05
on 1 January 2016).
Additional disclosures
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