Offshore renewable energy – accidental deposit of an object at sea: form and guidance

Guidance on the process for handling an accidental deposit of an object in the Scottish marine area and the Scottish offshore region from the offshore renewable energy industry.


Objects accidentally dropped at sea or debris can be a significant hazard to other sea users and the marine environment. Those responsible for dropping objects at sea or debris from the offshore renewable energy industry are responsible for reporting and, where appropriate and safe to do so, retrieval of the object.

In this guidance, a dropped object is considered to be an object or debris accidentally deposited in the Scottish marine area or the Scottish offshore region. The object could be from:

  • a vehicle
  • vessel
  • aircraft
  • marine structure
  • container floating in the sea

Objects deposited in the sea or on the seabed, or materials placed at sea, in accordance with marine licences or subject to exemptions are not considered to be dropped objects.

The person responsible (the Responsible Person) for the accidental deposit of an object should report any such object if they are unsure of the hazard it might cause.

No material should be intentionally discarded at sea, except under conditions of force majeure. Force majeure only applies if the dumping is necessary to secure the safety of the vessel, installation or crew. Objects deposited under force majeure must be reported to the Licensing Authority.

Steps to be taken

The Responsible Person must report the details of an accidental deposit of an object at sea to the list of organisations set out in the ‘accidental deposit of an object at sea form’.

In the event of an immediate risk of debris or an accidental deposit of an object at sea being a danger or hazard to navigation, immediate notification (as soon as reasonably possible, but no later than six hours after the event) must be made to the relevant HM Coastguard rescue coordination centre by telephone, and the UK Hydrographic Office (navwarnings@ukho.gov.uk).  Any maritime safety equipment (e.g. life rafts, life rings, life jackets etc) lost at sea must be reported to minimise the likelihood of unnecessary response mobilisation.

For all accidental deposits of an object at sea or debris, an ‘accidental deposit of an object at sea reporting form’ must be submitted electronically to the organisations listed in the form. This must be done as soon as possible and no later than 24 hours after the event takes place. Where required, updates should be provided.

Where necessary, the Responsible Person must undertake a side scan sonar or remote operated vehicle (ROV) survey in grid lines (within operational and safety constraints) to locate the object(s). If the Marine Directorate is of the view that any accidentally deposited objects are present, then the object(s) must be removed by the Responsible Person. This must be done as soon as where reasonably practicable following the review by the Marine Directorate. The Responsible Person must also bear the cost of updating any relevant charts.

The Responsible Person must ensure that any person involved in construction/maintenance work on their behalf, is made aware of and adheres to the requirements of the accidental deposit of an object at sea process. The Responsible Person must consider the following when deciding whether or not to report materials dropped at sea:

  • materials that are particularly resistant to rot can foul vessel propellers and present a very real hazard to divers, marine life and submersibles
  • plastic sheeting, bags and containers can block the cooling water intakes of vessels and be a significant hazard to marine life
  • materials that may represent a hazard to vessels and/or interfere with navigation
  • materials that may snag and damage fishing nets (e.g. a broken drill component, resulting in lost fishing time) or threaten the safety of a fishing vessel
  • materials lost or discarded at sea may be moved considerable distances by currents, and may have a significant impact not anticipated at the ‘dropped’ location
  • an assessment of the health and safety risk, or risk to the environment, must be carried out to inform whether the object(s) can be retrieved, the retrieval of the object(s) should be discussed with the Licensing Authority
  • any maritime safety equipment (e.g. life rafts, life rings, life jackets) lost at sea must be reported to minimise the likelihood of unnecessary response mobilisation

Submitting the accidental deposit of an object at sea form

The form must be submitted to the organisations listed on the form no later than 24 hours after the event takes place.

Retrieval

Organisations that have been notified of the accidental deposit of an object at sea must be updated of the successful retrieval of the object by the responsible person within 24 hours of the retrieval.

Enforcement provisions

Where it appears to the Marine Directorate that an object presents a risk, remedial action may be required. Marine Directorate may issue a remediation notice to the Responsible Person. The Responsible Person may be required to take such steps or to pay to the Scottish Ministers any sum as specified in a notice.

Related publications

Admiralty - Notices to Mariners

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