§ Mr. John Greenway (Ryedale)It is difficult not to reinforce the robust and able defence of my hon. Friend the Under-Secretary of State for Health of Government policy on the health service. The part of the preceding debate that I heard showed that we are winning the arguments, as usual. I wish him well.
This afternoon, it crossed my mind to raise a point of order but, knowing how pressed we were for time, I refrained from doing so and thought that I would spend the first minute of this debate on the matter. When I moved new clause 1 on capital punishment on Monday, my hon. Friend the Member for Thurrock (Mr. Janman) was one of several hon. Members who intervened in my speech. He made a point about miscarriages of justice. I obviously misunderstood what he said, because I said that I did not agree with him. Having had the opportunity of checking Hansard, I should like to put the record straight and say that I agree with him very much. More to the point, are not we very fortunate to have theHansard writers and printers doing such a splendid job for us, along with all the other staff? I should like to take this opportunity to wish them, and you, Mr. Speaker, a happy Christmas.
I am glad to have the opportunity of raising an issue on the Adjournment under the Consolidated Fund Bill for the first time. Many subjects demand and deserve our attention, and, like many other hon. Members, I never find it easy to decide which should take priority when dropping you, Mr. Speaker, a note before the ballot on what subject I might wish to raise. Pressing local constituency matters may demand too much attention, and sometimes we fail to raise often enough wider and more general issues that are of great importance. I believe this to be one such issue.
Christmas is a time for the family, but many people will be working over the Christmas holiday in our hospitals, in police forces and fire stations or in ensuring the essential supply of energy to cook the Christmas lunch. At the beginning of that energy chain are the men who work on the oil and gas platforms around our coast, particularly in the North sea. In the light of recent developments, I felt that it would be opportune to discuss before the recess safety on North sea installations.
I should declare a personal interest in this subject, as my father-in-law and my brother-in-law have worked for many years on North sea platforms as engineers. My father-in-law was involved in drilling many of the oil wells before production commenced.
Offshore installations present unique safety problems. A production platform is a community in its own right, which encompasses drilling operations, a refinery and nothing less than a hotel. All those functions are squeezed into a space of a few hundred feet each way—even rather less than we enjoy at the Palace of Westminster. There is also a helicopter landing area on each platform. On land, such operations would be spread over tens of acres. An oil platform is not just compact, but must be self-sufficient in an emergency; there is no question of waiting for the fire brigade to arrive. Therefore, the means of surviving an emergency while staying on the platform are crucial and critical. The means of escape and evacuation, if necessary, are equally important.
378 Oil and gas platforms represent extremely complex technology that is sited in a uniquely hostile environment. Recent events reminded us just how hostile that environment can be as huge waves and storm force winds took the lives of six men in a fishing vessel, washed over an oil installation and took lifeboats away. When I look out to the North sea from the safe haven of Filey on the north Yorkshire coast, I am struck by a grey sombre sight, particularly at this time of year. When the wind is blowing from the north-east, I find it remarkable that oil and gas operations can be maintained at all.
Tragically, over the years, there have been a number of incidents involving loss of life, of which the Piper Alpha disaster was perhaps the worst. As the House knows, on 6 July 1988 a series of explosions ripped through the Piper Alpha platform, following what Lord Cullen believes was a gas leak caused by night staff in the gas compression module who tried to restart a pump unaware of the fact that a safety valve had been removed.
Following an 80-day inquiry under the chairmanship of Lord Cullen, sweeping changes in North sea safety were recommended. The Government immediately accepted those recommendations when the report was published and brought to the House on 12 November. This debate provides an opportunity for the House to demonstrate its concern that all those recommendations should be implemented without delay and for the Government to report progress and give a more measured and deliberate response.
Some feel that the Piper Alpha tragedy was perhaps the worst in the history of oil exploration and extraction in the world. As a result of that disaster, 160 men lost their lives—it must never, never happen again.
Other tragedies have occurred even since the Piper Alpha tragedy, which underlines the dangers of oil and gas operations in the North sea and the urgent need for improved safety. In the past two and a half years, there have been at least 30 serious incidents and nine deaths on installations off our coasts. Even the day before the Piper Alpha disaster, management on Shell's Brent Alpha platform, east of Shetland, evacuated part of the installation after a gas explosion. Three months later, there was a serious fire on the Ocean Odyssey drilling rig, again after a gas blast, which killed a radio operator—thankfully, 66 workers were rescued. Only last July, six crew and passengers on a Sikorsky S61 helicopter were killed when it hit a crane in the Brent field. In 1988, two other S61s were ditched and 34 men were rescued. In November last year, a rig, Interocean 11, sank in bad weather and the crew was rescued by helicopter. Last January, an accommodation platform in the Brent field, Safe Gothia, was evacuated after winds snapped two anchor cables.
Since oil and gas exploration began in the 1960s, about 500 lives have been lost in the North sea. I am sure that the House wishes to pay every tribute to the bravery of the men who have helped our economy and who put up with such dreadful conditions. At this Christmas time, we should send every sympathy to the families and loved ones of those who have died.
The tragedy of the Piper Alpha disaster is that, as Lord Cullen's report showed, if more had been done beforehand it might have been avoided. Sadly, that is true of many other disasters of recent years. The two dreadful incidents at football grounds in Yorkshire—at Bradford and at Hillsborough, in Sheffield—the Clapham rail crash, the 379 sinking of the Herald of Free Enterprise all come to mind. In all those cases greater attention to detail would have prevented loss of life.
Following Piper Alpha, many have argued that the implementation of the recommendations of the 1980 Burgoyne committee should have gone further. I expect that there will continue to be disagreement among hon. Members on that point for some time, particularly among those who have a special knowledge of the industry which, I must confess, I have not. However, there are two points on which we should be able to agree.
First, as my right hon. Friend the Secretary of State for Energy told the House on 12 November:
In 1980, the Government accepted the majority view of the Burgoyne committee, which was set up by the previous Labour Government. It said that, on balance, it believed that the best case for safety in the North sea was to leave the matter with the Department of Energy."—[Official Report, 12 November 1980; Vol. 180, c. 333.]In 1990, 10 years later, Lord Cullen recommended that, on balance—again, it is a matter of balance, as my right hon. Friend said—the best case is for transferring responsibility to the Health and Safety Commission. The Government have accepted the recommendations of the majority committee in both cases and they are to be commended for that.My right hon. Friend the Secretary of State also pointed out that North sea operations have become more complex over the past 10 years and that the Health and Safety Commission has developed its expertise. More importantly, Lord Cullen found no evidence that the Department of Energy put production before safety.
The second point on which we can agree is the role of the owner of Piper Alpha, Occidental. Lord Cullen concluded that there were significant flaws in the way in which safety was managed by Occidental. The hon. Member for Holborn and St. Pancras (Mr. Dobson) asked the Secretary of State on 12 November whether Occidental would be prosecuted. Hon. Members on both sides of the House, as well as the families and communities of those who were killed, shared the view that Occidental should be prosecuted. My right hon. Friend the Secretary of State was surely right immediately to send Lord Cullen's report to the Lord Advocate, and there the matter must rest for the time being.
The House must now ensure that, in future, North sea operations are safer then they have been in the past. Safety must be paramount. We all recognise the inherent dangers in working in the North sea, but we must not take unnecessary risks with other men's lives. The Piper Alpha disaster suggests that we may have done so in the past. We must never do so again.
The whole House has rightly given a warm welcome to Lord Cullen's most impressive and penetrating report. The extent of his deliberations is revealed in the fact that the weighty document that I hold in my left hand is only the first of two volumes.
Drawing, no doubt, on the experience of his assessors, Lord Cullen has provided a most comprehensive analysis of the conditions necessary for the safe management of offshore installations. I am sure that the report contains lessons for the safe management of other industrial activities. The report is the most significant landmark in the evolution of offshore safety since the most recent legislation—the Mineral Workings (Offshore Installations) Act 1971.
380 Lord Cullen's report rightly concludes that safety in such a demanding environment as the North sea cannot be secured by fixed rules or off-the-peg solutions. We need a flexible approach and the ability to evaluate the best compromise between conflicting safety objectives. Solutions have to take account of the varying circumstances of individual installations. That is why Lord Cullen was right to suggest that every installation must be assessed. He provided a comprehensive list of what a good safety management would incorporate. It would need to cover
organisational structure, management personnel standards, training, for operations in emergencies, safety assessment, design procedures, procedures for operations, maintenance modifications and emergencies, management of safety by contractors in respect of their work, the involvement of the work force (operators and contractors) in safety, accident and incident reporting, investigation and follow-up, monitoring and auditing of the operation of the system and systematic reappraisal of the system in the light of the experience of the operator and the industry.I make no apology for listing the important objectives which Lord Cullen identified. I am sure that the House will agree that the recommendations rightly place the responsibility where it belongs—with the owners and operators of the installations.The oil industry is one of our most dynamic industries. It has shown great inventiveness and resourcefulness, not least in maintaining the economic viability of North sea production when world prices fell sharply in the mid-1980s. I gladly acknowledge, too, that the Government have played their part by keeping an open mind on taxation issues and making adjustments where the case has been made. The industry deserves credit for its adaptability and ingenuity. The oil industry should also have the freedom to apply its drive, adaptability and ingenuity to safety problems. It is tempting to say that there must be definite rules and a clearly prescribed approach, but such an assertion is fallacious. In real life —in the practical world—reasonable safety objectives often conflict with each other, and Lord Cullen recognised that. A better standard of safety depends on achieving the best trade-off between those conflicts, and not in a prescriptive, rule-book approach.
I particularly welcome Lord Cullen's report for its clear recognition that the operators must play a more extensive and fundamental role in choosing the best means in each case to attain the defined standards. A programme of work for the installation of emergency shutdown valves on offshore platforms is also important. With the approach of the 31 December deadline—another reason for having the debate tonight—I hope that my hon. Friend the Minister will be able to bring the House up to date on the progress that has already been made.
§ The Parliamentary Under-Secretary of State for Energy (Mr. Colin Moynihan)I may be able to help my hon. Friend on this critical point. Oil companies have generally made good progress with the installation of emergency shutdown valves—to date more than 134 valves have been fitted and a number of others are expected to be completed by the end of the year. However, a number of applications for temporary exemptions have been received and have been rigorously scrutinised in detail by my Department's inspectors. In considering those applications, my inspectors have taken into account the fact that, in all cases, emergency valves exist but are not optimally located.
381 Therefore, I have decided that a number of new compulsory measures must be implemented by operators to enhance safety until the new valves are installed in those cases where production is to be permitted to be continued. They include reducing the pipeline operating pressures, switching from live crude oil production to dead crude oil and introducing enhanced operating procedures. We have received applications for 53 valves, of which we have agreed 25 exemptions. Some 24 have been withdrawn after discussions with my inspectors and four have been refused. Rigorous conditions will be attached to all such exemptions in order to enhance safety. In addition, applications in respect of four valves on the Texaco Tartan, Mobil and Beryl Alpha platforms have been rejected on the basis of information received.
§ Mr. GreenwayI thank my hon. Friend for his important statement, which clearly could not come too early either in this debate or in general terms. I am sure that those involved will welcome his statement for the clear way in which it set out the progress that has been made and what more needs to be done. I am sure that my hon. Friend will have other interesting matters to report to the House when he responds to the debate.
It is also right that, within the North sea, there must be proper controls and monitoring of safety standards. They must be more flexible than in the past, but nevertheless remain defined, understood and enforced. That places substantial demands on the enforcement agency, which must deploy a high level of expertise to be able to evaluate and respond to new approaches brought forward by the industry. That will not be a cheap option, but I am convinced that it is right.
Lord Cullen was correct in feeling that we should be circumspect about legislating safety into an industrial activity. The disadvantages of over-detailed legislation were highlighted by the Robens committee that began its work 20 years ago and published its report on health and safety at work in 1974. Its objections to over-detailed legislation on safety matters still seem to be valid and were in many ways vindicated by what Lord Cullen said in his report. Safety must spring from the initiative and active concern of the company and its own determination to tackle safety problems. It has to find the right system, and the means, and to put them into effect. It must then ensure, by training and monitoring, that they are applied and continue to be applied.
I think that it will be accepted on both sides of the House that it is essential that companies involve all their workers. I am aware that there has been some controversy about union recognition in the North sea installations. That is a quite separate issue from safety. Whether they are members of staff, employees, production workers, sub-contractors, members of unions or not, they must all be properly involved in safety. In a highly critical safety area such as offshore installations, every worker must perceive his proper contribution to safety, and have the knowledge and training to play his part. That must mean better communication than in the past.
I refer for the final time to volume 1 of Lord Cullen's report, which dealt with why the explosions occurred. He made one important statement:
From the evidence I conclude that this"—the failure of the system— 382was due to a failure in the transmission of information under the permit to work system and at shift handover".So even at the most mundane level of operations, communication between staff—each member of staff understanding the others' roles and the importance of every procedure that he carries out—cannot be given too high a priority.Safety must not merely be sold as a philosophy or some vague concept to the worker by means of exhortation. Dialogue with the worker and involvement in everything he does is essential to a safe working environment.
Lord Cullen's report was also greatly to be welcomed because it faces up to the difficulties and tackles them squarely. It proposes a framework that is flexible as to solutions but ensures that all the right questions have been asked. It avoids detailed prescriptions for hardware or management systems, but it puts the initiative and responsibility where they belong—with the operators and employers. Equally, it provides a stringent basis for probing examination by the regulatory body.
There will have to be real dialogue, not a rigid imposition of predetermined rules. The regulatory body will need a high degree of expertise and, more importantly, adequate resources. I know that my right hon. Friend the Secretary of State has made general promises in that direction, but I hope that the Minister will say more this evening about these points. In addition, as my right hon. Friend the Member for Kincardine and Deeside (Mr. Buchanan-Smith) told the House on 12 November during questions on the statement about the publication of the report, the new regulatory body should and must be independent and seen to be so. That view is shared throughout the industry and this House.
I make no apology for returning to the critical importance of monitoring. It is not enough for proper principles to be endorsed by management in the form of manuals of safety left standing on the shelf gathering dust, or in the workplace. The principles must be put into and kept in effect. I referred earlier to the Clapham railway tragedy. The report on that incident showed what a contrast there can be between sound principles and their adequate practical implementation. It is right to emphasise monitoring and the new proposals for systematic audit by the operator and for the audit and inspection of that activity by the regulator.
Lord Cullen does not make the point, although I believe it strongly, that the insurers have a distinct role to play in monitoring and enforcing standards. The Piper Alpha tragedy claim was, I understand, for £1.4 billion. Insurers will surely be asking themselves whether the disaster could have been avoided if Lord Cullen's proposals had been in force before it happened. The claim was for £1.4 billion, but it should not take the loss of the lives of 167 men to reach a proper definition of an adequate safety regime for operations in the North sea. The insurers have continuous contact with and influence over the companies that they insure. Just the other day, an insurance representative told me that a private insurance company would have refused to insure King's Cross underground station as a private place because the fire safety arrangements were clearly inadequate.
The Cullen report is the basis for effective regulation of safety and has been recognised as such. The oil and gas industry is important to our economy. It has made a major contribution in the last decade, and I am sure that it will continue to do so in the next decade and into the next 383 century. But it is a dangerous industry, and we must maintain proper standards within a dynamic system that is capable of growing.
I am glad that the Government have been able to accept all the recommendations. They must now ensure prompt and effective implementation of this highly significant report's blueprint for the future. That will require careful planning, a systematic approach and, as Lord Cullen recommends, proper consultation about contractors' interests. It will also mean new staffing and training for the regulatory agency.
A separate offshore safety division at the Department of Industry was set up on 10 December. I first read about it in The Engineer and I understand that it is under the direction of Tony Barrel], who is the current director of technology in the Health and Safety Executive. That is a significant first step and will help to ease the transfer of responsibility for offshore safety from the Department of Energy to the Health and Safety Commission, as Lord Cullen recommended. The commission has welcomed that transfer, but has again called for more Government resources to do the job properly.
The House should not be under any illusions about the costs involved in assessing every offshore installation. As the Health and Safety Commission chairman, John Culler, has said, those costs will be substantial. Resources must be found so that Lord Cullen's vision for a safer North sea will soon become a reality. The lives of husbands, fathers, sons and brothers working in the North sea this Christmas deserve nothing less.
§ Mr. Frank Doran (Aberdeen, South)I thank the hon. Member for Ryedale (Mr. Greenway) for raising this issue, because it is not debated often enough. I hope that, in the new year, we will have an opportunity fully to discuss all the implications of the Cullen report. Not only is this a vital industry employing almost 50,000 people, but it plays a vital part in the country's economy.
The Under-Secretary of State for Energy made a mini-statement on the installation of shutdown valves. It is worth reminding the House of the circumstances in which the issue of shutdown valves was raised. Those valves were a major cause of the scale of the Piper Alpha disaster. There were no shutdown valves in a safe place on the platform and tonnes of gas were released on to the platform when the valves which were in place there were damaged by explosion. The cause of the disaster was the failure to have adequate cut-off mechanisms between the surrounding platforms, the Tartan and MCPO1, and Piper Alpha. As a result, all the gas in the pipeline was released to Piper Alpha.
I wrote to the then Secretary of State for Energy on 14 July 1988, just eight days after the disaster, setting out the case for emergency shutdown valves to be located on the sea bed, a safe place away from the structure, so that, if a similar incident occurred, the valves would be at no risk whatever.
About a month later, I received a letter from the head of safety in the Department, saying that it accepted the argument for sub-sea valves and intended to legislate as quickly as possible in the circumstances. That commitment has been watered down somewhat, although I am aware that many of the companies in the North sea have decided that, without Government regulation, they will install 384 sub-sea valves. Occidental and Texaco, the two companies most affected by the Piper Alpha tragedy, made that decision, and many others have followed suit. The Government have yet to introduce the regulations that were promised to me in August 1988. Therefore, I should like the Minister to tell us where we are on that important issue.
The Minister has made a significant and full statement about the requests made by a number of oil companies for exemption from the regulations that require the top-side valves to be relocated before the end of the year. I accept that there has been a thorough investigation, but must ask why it is that these applications were made, and we have had a response from the Minister so late in the day. This is a crucial issue. Location of sub-sea values is a technical issue, and I do not pretend to understand it fully, but I am aware of the problems of location and of the fact that responsibility for location and inspection of location were highlighted by the Burgoyne committee as far back as 1981. There appears to have been no action since. Paragraph 5.64 of the report makes specific reference to the grey area of the pipeline. We saw the predictions in that report unfortunately and tragically fulfilled in what happened to Piper Alpha.
That tragedy happened on the night of 6 July and the early morning of 7 July 1988, and now, at the end of 1990, a large number of oil companies, are still asking for exemptions. It is noticeable that this includes the largest of the oil companies. In particular, Shell has received exemption for 14 of the sub-sea valves in the Brent system. As one of the largest operators, it has one of the largest problems, so it is difficult to understand why so many exemptions have been granted in that field. Shell has had the same amount of time as every other operator in the North sea to install the valves. Is there something about the Brent field that requires that number of exemptions to be granted?
I should like some explanation of what the Minister means by "restrictive conditions". He has described three areas where there will be more restrictions and these seem to be sensible moves when the sub-sea valves are not to be installed immediately. However, we need to know what implication that has for the overall safety of the platform. What consideration has been given to that?
What time scale will apply to the exemptions? When are the sub-sea valves to be finally installed? It is not good enough to leave our work force out there in the North sea, albeit with these new restrictions, without the essential safety of the removal of the valves to a safe location on the platform. This is particularly so when we know that the platforms involved—the Forties, the Brent system, Thistle, Murchison and Balmoral—are among the oldest in the North sea. Consequently, they have the highest risk.
In any debate on North sea safety, the Piper Alpha tragedy overshadows every aspect of our discussions. Many tributes have been paid to Lord Cullen for the clarity of his report, the detail of it and the precision that he applied. I believe that the report will often be referred to by generations to come as a model for the way in which such issues should be addressed. I hope that it will not need to be referred to too often. Lord Cullen brought to his task all the best qualities of the Scottish lawyer. The Scottish legal system is based on principle, not on precise rules. Lord Cullen sought—I believe that he achieved his objective—to apply principles and to explain and set out the principles which should apply to safety in the North 385 sea. The report has been welcomed by all. Given the fraught nature of the industry, especially in the context of industrial relations, it is a tribute to Lord Cullen that he was able to produce a report to which everyone was able to agree.
Crucial issues arise from the report, not the least of which is the transfer of responsibility from the Department of Energy to the Health and Safety Executive. Lord Cullen was emphatic that there were major difficulties in the Department of Energy, one of which was resourcing. There was a failure to apply the mind—I blame the political mind—to ensure that North sea safety was properly policed. There was a lack of real political direction. It is clear that the safety inspectorate was the Cinderella of the Department. The efforts of the Department rapidly to increase salaries and to appoint a new safety director before the Cullen report were cynical moves.
But enough of that carping criticism. We must look forward. The question of blame lies in the past. Lord Cullen has reported on that and his words are clear. We must ensure that the Piper Alpha tragedy does not recur. There must be an adequate system of supervision. Everyone must know exactly what his or her task is. Responsibility must be allocated fairly.
There is still no precise detail about when the complete transfer of responsibility will take place. Several possible dates have been suggested, the most likely of which seems to be 1 April 1991. There is an urgent need for the Government to define precisely where responsibility for safety lies in the interim period of transfer from the Department of Energy to the Health and Safety Executive. Many of Lord Cullen's recommendations require urgent action by the industry. The representatives of oil companies whom I meet regularly have told me that they wish to proceed quickly to implement the recommendations. I have firm evidence to substantiate that from my contact with them.
The industry requires prompt technical discussions with the regulatory body to define and agree the detailed interpretation of the report and, of course, its consequences. There are specific examples to show that delay would be inexcusable. The first is the preparation of a safety case for each installation. That is the most far-reaching of Lord Cullen's recommendations. It will lead to the provision of a complete dossier to demonstrate that the operator has identified the major hazards of the installation and has provided appropriate controls, that the operator has provided in each installation a temporary safe refuge for personnel in the event of a major emergency and means of evacuation, escape and rescue, and that the operator's safety management system is adequate to ensure the safe design and operation of the installation.
There is an urgent need for the Government to provide expert advice to operators on the detailed scope, format and timetable for the safety case. I hope that the Minister will give us some idea of who will do this and when it will be done.
Another consideration is acceptance standards for risk of death offshore. Lord Cullen's fifth main recommendation concerns setting acceptance standards for overall risk of death or injury to personnel on an installation. Standards are also to be set for the endurance of the 386 temporary safe refuge during major emergencies. Initially, these standards are to be set by the regulatory body. They will be the most important standards to be set. They will determine ultimately the risks of accidents or death to offshore workers. They form the cornerstone of any safety case, as all the elements of the safety case, taken together, must satisfy the overall acceptance standards.
Those standards must be determined quickly, because without them work on the safety cases for new and existing installations cannot be taken very far. It is also important that the process for setting those standards be open to discussion and scrutiny by all parties with a legitimate interest, including operators and offshore workers and their representatives. Who is responsible for setting those standards? What process will be followed? What is the timetable for conclusion?
There is also a question about the resources for the Health and Safety Executive. We understand that the executive and the Treasury are discussing the matter. It is determining what its budget is likely to be, and clearly it has a long and uphill struggle with the Treasury to achieve an adequate budget. The system that prevails in the Department of Energy, which led to inadequate supervision and to criticism by Lord Cullen, cannot continue. The HSE must be adequately resourced. I hope that the Treasury's starting point in its discussions with the HSE will not be the miserly payment made to the HSE each year for the Department's expenditure on safety. As was shown in an answer to a parliamentary question of mine just over a year ago, that amounted to £500,000 a year. It is clear that the safety system envisaged by Lord Cullen cannot be provided for that sort of money. It is important that the Department of Energy, and the Secretary of State in particular, put their full weight behind the HSE's arguments.
Recommendation 22 says that the regulatory body should review its procedures for consultation with representatives of employers and of offshore employees in preparing new guidance notes on safety offshore. Lord Cullen made it clear that he fully recognised the value of involving those who work offshore in the new safety regime. We expect that the Health and Safety Commission, as a tripartite body overseeing the HSE, will share that view and ensure that proper mechanisms for consultation are developed. It is not sufficient only to involve the work force through existing installation safety committees. Many of the new guidance notes will affect the design of new installations and will cover complex technical and engineering matters.
The only effective means of representation for offshore workers on such matters is through the trade unions, and I shall say more about that later. They have the resources to commission studies and to present findings to the HSE. All the trade unions involved with the HSE onshore have developed technical departments that can give advice to work forces. Certainly, offshore that advice will be crucial and fundamental. Large sections of the offshore work force wish to be represented by their trade unions in the new safety regime, yet employers have stubbornly resisted that change.
Anyone seriously interested in achieving high safety standards recognises that the genuine and informed participation of the work force is essential. The more enlightened companies offshore recognise that that applies not only to safety, but to overall quality and the success of the whole enterprise. Is it not time that the Government 387 took on board that message and encouraged employers to be more co-operative towards trade union representation offshore?
§ Mr. Tim Devlin (Stockton, South)How might that be achieved? Many of my constituents work in the offshore industry, and their experience is that safety officers are often NRB-ed—that is, not required back—when they are sent on leave. Anyone involved in that sort of representation frequently ends up without a job.
§ Mr. Doran1 am surprised to have the hon. Gentleman on my side. We have been hammering away about that issue for years. I am being careful not to criticise the industry too much because I know that progress is being made. I shall be happy to discuss with the hon. Gentleman any examples of discrimination that have been reported to him. I am pleased that he has been able to add to the views that have been expressed to me by my constituents who work offshore, but who are consistently denied representation by the Government and the oil companies. Clearly, the independence of the health and safety representative and the health and safety committee is crucial. Employers onshore have learnt that an independent committee can enhance and improve safety as long as they are prepared to trust their work forces. That clearly is not the position offshore at the moment.
Many oil companies refuse to trust their work forces and to allow them to participate through their trade unions. The companies will pay the price in poor productivity and high operating costs, of which there are many examples in the North sea. The areas with the lowest productivity and the highest operating costs have the worst industrial relations.
The country pays the price in lost oil production. Offshore workers may pay the highest price of all because of poor safety. Oil companies risk their capital; oil workers risk their lives. That is becoming a cliché, but it is true. Piper Alpha, Brent Spar and all the other incidents show that, as well as the many unreported deaths offshore.
There have been significant developments in industrial relations during the past few days. During the past two years there have been some serious offshore disputes, and there is a real threat of industrial problems again next year. At the root is the genuine sense of frustration felt by the work force as a result of its working conditions. The oil companies tend not to trust their employees—at least the majority do not. They tend to operate a system which militates against communication and the development of skills and identification with a particular workplace.
Almost two thirds of employees offshore are employed through the user contracting system. There is no continuity of employment. The expression NRB is common in my office. If a man's card is stamped NRB he is not required back because he is a trouble-maker or a safety representative who asked the wrong questions. That is the history of the North sea and it is a problem which needs to be dealt with. I am pleased that the oil companies seem to be coming round to recognising that, but there is still a long way to go.
It is worth mentioning the offshore industry liaison committee, an unofficial body that has been established in my constituency in Aberdeen and seeks to represent the work force offshore.
§ Mr. DevlinI thought that it was in Newcastle.
§ Mr. DoranIt is in Glasgow, Newcastle, Hull and Great Yarmouth, but its main base is in Aberdeen. It has established other bases round the country because of the migrant work force which moves to Aberdeen from those places.
The people who formed the OLC recognised that the major problems for the work force offshore were not being met by the trade unions. It is appropriate here to recognise that the trade unions have not always represented their members quite as they should have done, mainly because of the difficulties of representing a mobile work force. Men move from rig to rig and from platform to platform at short notice, employed by a company based onshore, but working offshore. They work for a number of different oil companies, many of which employ the same contractors. Therefore, it is difficult to represent the work force and the OLC has filled the vacuum. It has been behind the industrial action during the past two years.
It is significant to record the amount of support from offshore workers that the OLC has enjoyed. Several thousand workers responded by taking industrial action—not by any means the whole work force, but certainly a significant proportion of it, and enough to cause real difficulties during the past two summers. The oil companies have been forced to respond by looking at their working practices, not only because of Lord Cullen's report, which makes extremely important recommendations, but because of the success of the action carried out by the OLC. It is clear, too, that the official trade unions now recognise the difficulties involved, and are working hard to improve the position of their members offshore.
I am pleased at reports today that the employer's body —the Offshore Contractors Council—has offered to enter into discussions with the trade unions. There is not total satisfaction with the offer, because it seems fairly restricted, but at least it is a beginning. Discussions will take place with the unions about a possible agreement covering certain categories of offshore workers.
The trade union movement will certainly be seeking other agreements, to ensure some regulation of offshore employment and worker protection, and that terms and conditions of employment are standardised and improved. The oil companies offer very satisfactory terms and conditions to their own work forces, but they are, in the main, denied to the workers who are employed by contractors—even though they may be doing the same work side by side with oil workers. There is often a huge disparity between them, and that adds to the frustration.
§ Mr. DevlinThe hon. Gentleman has a wide knowledge of the industry near his constituency, but there are enormous discrepancies between the conditions on some of the older North sea platforms and those on the newer ones. When I visited the Brent field in the summer, I noted that the accommodation ships moored alongside the Brent were used because the accommodation available on the Brent itself is rather poor. Workers prefer the conditions on the more comfortable Swedish and Finnish accommodation ships. All platforms should be brought up to the standards of the best.
I and my constituents welcome the Cullen report's recommendation that responsibility for safety and for safety inspection should be taken out of the hands of the Department, which has not fulfilled its obligations in that respect very well, and be put into the hands of the Health and Safety Executive. Many would like the same 389 conditions to prevail in the North sea as prevail on land, where an independent inspectorate is available to conduct surprise visits and to examine conditions on behalf of the work force. That is what we all want, and we should welcome such a development.
§ Mr. DoranAgain, I welcome the hon. Gentleman's agreement with the position that I have often stated. I am pleased that we are finally having an effect, which is enhanced in the case of the hon. Gentleman because of his experience of offshore workers in his constituency.
Some companies are finally making progress. When I visited the Ninian field last year, I met its safety committee and had discussions with the work force. It was clear that the operating company, Chevron, has made a serious attempt to integrate its work force. It employs contractors, as does everyone else, but when it changes contractors, it tries to ensure that the work force remains stable. Chevron has reduced the barriers between its employees and those of contractors, so that everyone who works on the Ninian platform feels that he works for Chevron, no matter who pays his wages.
The company has sought to ensure also that the benefits of its new contracts with agency companies filter through to the work force. That should be done throughout the North sea. I know that the same practice operates in Conoco fields. Those are two of the better offshore companies.
The larger companies have larger problems. I am aware that both BP and Shell recently introduced new systems that should in the longer term, and perhaps in the medium term, improve the lot of offshore workers. Shell and BP decided to go for longer-term contracts and have sought to ensure that they filter through to the work force, so that there will be some continuity of employment. Of course, they have got to try to do what companies such as Chevron have done, and to break down the barriers, so that there is not the animosity and frustration and the contracting work force becomes part of a team and achieves the highest productivity for the industry and the company. Everyone will benefit from that, and there is an enhanced benefit to safety, which is what everyone wants to achieve.
It has always been my view—it is not a novel idea—that one cannot have bad industrial relations and good safety. Until the problems are dealt with properly by the companies involved, there will continue to be poor safety standards in the North sea. I am pleased to see, and I commend, companies such as BP and Shell, which are finally beginning to deal with this problem.
We have had other good news on the industrial relations scene today. One of the unfortunate consequences of the dispute in the summer was that Shell created a blacklist of employees who they were not prepared to have working on their platforms. Recently, I met the chairman of Shell, and the managing director of Shell Exploration and Production and I am pleased to say that, yesterday, the company announced that it would remove the blacklist with effect from 1 January—as I understand it, without qualification. I like to think that I and my hon. Friend the Member for Holborn and St. Pancras (Mr. Dobson) had some influence upon Shell's decision—we hope so.
In our discussions with the chairman of Shell and the managing director of the exploration company, we heard about Shell's efforts to resolve the difficulties. There was 390 not much disagreement between us, and I hope that they will be able to secure their objectives of removing the barriers in the North sea, breaking down the distinctions between company employees and contracted employees and improving safety.
The removal of the blacklist is a crucial step, and I hope that the trade unions will respond to it and that Shell will discuss properly with the offshore trade unions the way ahead. There is a way ahead, but it involves discussions on all sides.
I was involved with the Piper Alpha families' association, which attempted to convene a conference at which the entire industry would be represented in one way or another. The Minister gave me valuable support in arranging that conference, and we hoped that the oil industry and the contractors would be able to come along and discuss, in private, with the trade unions and other interested parties—including the Health and Safety Executive and the Department of Energy representatives, the trade unions, and the families association—the issues which face the industry, how Lord Cullen's recommendations could be implemented and the problems posed by the industrial dispute.
The oil companies, through the United Kingdom Offshore Operators Association, found that they could not attend that conference. I regret that because they missed an opportunity to show the public—who in my part of the world are extremely concerned about the problem of offshore safety—that they care, too. They stuck behind the barriers that they created during the industrial dispute, when they said that the dispute did not have anything to do with them, but was for the contractors, as the legal employers of the men involved. They said that they had no influence, but that is not the case. They pull the strings in the North sea and have influence. It is the oil companies which need to deal with the problems. I bitterly regret that UKOOA and the Offshore Contractors Council did not feel able to join in a discussion, which had no higher objective than to get people into the same room to discuss this crucial issue.
With the removal of the blacklist, and the possible offer of talks with the trade unions, there is room for progress. I listened carefully to what the hon. Member for Ryedale said. Before the Piper Alpha tragedy it was unlikely that we would have heard a Conservative Member make the contribution which he made, or the interventions by the hon. Member for Stockton, South (Mr. Devlin).
The worries about safety go across party divides and the divides within the industry. It is incombent on everyone in the industry to deal with the problem and to break down the barriers. That is a message to both sides— the trade unions and the industry—to get together and talk.
In the discussions that I had with the Minister since he took office, I have been impressed by the serious way in which he has dealt with the issues, and how he has already begun to deal with the niggling problems that have beset us. For example, the hon. Member for Ryedale mentioned the need for inspectors to be able to get on to helicopters at short notice and carry out snap inspections. Labour Members have argued for that for a long time, without success, and I was pleased to read recently that the Minister had issued instructions for it to happen.
Such difficulties can be resolved if we address them with an open mind. Lord Cullen has enabled us to do so, and I hope that we can now make progress.
§ The Parliamentary Under-Secretary of State for Energy (Mr. Colin Moynihan)Let me begin by replying to a point made by the hon. Member for Aberdeen, South (Mr. Doran) about the conference and the response to it of the United Kingdom Offshore Operators Association. As he knows, I too was sad that a full house was not possible on that occasion. I note that the conference has been postponed: let me say through the hon. Gentleman—given his involvement with the organisers—that I very much hope that this is a postponement and not a cancellation, and that it can be reconvened shortly. I hope that UKOOA will respond positively; certainly I shall, if diaries and the business of the House permit it.
I congratulate my hon. Friend the Member for Ryedale (Mr. Greenway). We have had occasion to differ on a number of sporting issues in recent years, but I agreed with everything that he said in his speech tonight, which was sensitive and clearly the result of a good deal of detailed analysis and preparation. It was helpful of him to give us our first opportunity to debate the Cullen report in detail.
My hon. Friend rightly paid tribute to all who work in the offshore oil and gas industry. Let me echo those admirable sentiments: I entirely share the esteem in which he holds those people, who often work in very difficult conditions. Let me also place on record my support and respect for our inspectorate, which is composed of men of the highest calibre.
I am glad that mention has been made of Tony Barrell, who has transferred from the Health and Safety Executive. I welcome that move: Tony Barrell has shown tremendous dedication and enthusiasm since the first day. I have had so many meetings with him although he has been in post for only just over a week—that I cannot recall them all in numerical terms, but I can report that he has great expertise, and is willing to learn a good deal about the offshore industry and to steer his team into the 1990s. I know that he will respond positively to any advice and suggestions from hon. Members, whatever their political persuasion. He will proceed with an inspectorate that is professional, well qualified, committed and energetic in the pursuit of safety and excellence.
I hope that my hon. Friend the Member for Stockton, South (Mr. Devlin)—I am sorry that he is not present; I never like criticising hon. Members, especially Conservative Members, when they are not present to hear that criticism, but he was here for only a short time—will pause to reflect. I deeply regretted his innuendo about criticism of the inspectorate. Certainly Lord Cullen criticised the system in which it was operating, but he never suggested that that same inspectorate should not form the core of the new inspectorate which will look into the safety problems confronting the offshore industry in the 1990s. I wish its members well: they have been under the glare of publicity in recent months, and they deserve our full support.
I know that hon. Members on both sides of the House are at one about the importance of what my hon. Friend the Member for Stockton, South called surprise visits. Although the inspectorate undertakes many surprise visits, it is always difficult, because places have to be booked on helicopters.
We cannot just walk in, as we do onshore. A classic example of that occurred last weekend. At very short notice, two of my inspectors went out to Cormorant Alpha 392 and Brent Charlie to assess a number of concerns about topside valves and derogation. They went out with me on a number of recent visits, again at short notice and on one occasion with only a day's notice. I fully support spot visits; they are important. However, I can give an undertaking that they are already very much in place.
I echo what was said by my hon. Friend about the need for a balance to be struck between prescription and operator responsibility for safety management. It will always be a subject for debate, but I agree that Lord Cullen addressed the point sensitively. The operator must be responsible for safety on every platform. That is critical to future safety inspections. An effective audit system to be set up by each operator is equally important. The inspectorate will assess the type of assessment that will be required for safety management. That was not their prime responsibility under the old system.
I can give an undertaking to my hon. Friend that prompt and effective implementation of Lord Cullen's recommendations remain a priority for my Department. I give an undertaking to the hon. Member for Aberdeen, South that we shall devote all our energies to ensuring that adequate resources are provided. It has often been difficult to emply as many inspectors as we wanted to employ, despite a 23 per cent. increase in pay this year for inspectors. It is often difficult to persuade qualified men at the top of their profession to work for the inspectorate, riot least when some of the operators seek diligently to employ the same people. We must ensure that the inspectorate is both well staffed and well paid.
I am grateful to my hon. Friend for providing us with an early opportunity to debate Lord Cullen's report. The praise that has been accorded to it is fully merited. It is a most impressive report. Apart from being painstaking, thorough and conscientious, it is also a most penetrating report. As someone who approaches the subject without specialised knowledge, it seems to me little short of astonishing that so much can be deduced about what happened in the disaster in the absence of nearly all the physical evidence and despite the loss of the personal testimony of so many of those who were there. Lord Cullen marshalled the evidence in a masterly fashion. His conclusions demand corresponding respect.
The report is no less impressive in its shaping of recommendations for the future, a fact that is reflected in its immediate and unqualified acceptance by the Government. Before I deal with a number of specific points that have arisen in the debate, may I deal with my hon. Friend's reference to the Government's consistency of approach towards offshore safety?
Shortly after the Conservative administration came to power 11 years ago, they received the report of a committee set up by the previous Labour Government. It was the first independent review of offshore safety since the tribunal of inquiry into the Sea Gem disaster in 1968. The principal recommendation of the majority of the committee's members was that responsibility for the regulation of offshore safety should be unified in the hands of the Department of Energy. The trade union representatives on the committee, however, disagreed, arid recorded their preference for that responsibility to be given to the Health and Safety Executive.
The Government moved promptly and respnded to the main recommendation. After careful consideration, the action taken, as explained by the then Minister of State, took account of some of the concerns expressed by the 393 trade union members in their note of dissent. They had expressed concern that the Health and Safety Commission should not lose its involvement in offshore safety. The solution that was adopted enlarged the commission's involvement. It was enabled to advise the Secretary of State on all his responsibilities for offshore safety. The Government therefore acted promptly, taking full account of the independent advice that was given and, as far as practicable, of other concerns that were raised. Ten years later, we have once again received independent advice on the organisation of safety. Our response has been as prompt and comprehensive as on the earlier occasion.
However, the Government did not wait for the result of the inquiry before taking action. We moved swiftly to ensure that any early lessons that could be drawn from the destruction of Piper Alpha were disseminated as soon as possible. Even before the Department's technical investigation into the cause of the accident was completed, its director of safety wrote to all offshore operators pointing out the safety significance of emergency shut-down valves on oil and gas pipelines and asking for an immediate review by operators of their existing pipelines.
When the technical investigation was complete, the director of safety again wrote to all offshore operators asking them to pay particular attention to several other areas of operator safety systems and procedures when evaluating the technical report. Now that Lord Cullen's report has been published, the Government have wasted no time in putting in hand the necessary arrangements to implement its recommendations.
On the day that the report was published, the Department's director of safety wrote once again to the industry asking it to undertake, without delay, the necessary action to implement those of Lord Cullen's recommendations that were capable of being implemented immediately. The Government are working urgently to progress the detailed work required to implement the rest of the recommendations.
I should like to enlarge a little on the information I gave earlier in an intervention on emergency shut-down valves. I am pleased to say that operators have, in general, made good progress and to date, as I said, more than 134 valves have been successfully fitted. I expect a number of others to be completed by the end of the year—for example, on the far north liquids and gas gathering system—FLAG. It is likely to be January before that system comes back on because of gassing up the system, which is a technical and lengthy procedure. We have urged that work should be done on the fitting of those valves.
I have received a number of applications for temporary exemptions to the regulations to allow a longer period for the necessary work to be completed. These applications have been rigorously scrutinised by my inspectors, and in 25 cases I have agreed to temporary exemptions for the minimum time necessary, subject to additional safety restrictions to maintain acceptably safe operations during the period.
In some cases, I believe that work can safely continue during winter conditions, and the extension is for periods of three to six weeks only. In other cases, I support the view of my inspectors that work involving, for example, over-side working cannot safely be done in winter 394 conditions. Where my inspectors have accepted this point as relevant, I have agreed to exemptions of up to three months. In no case have I agreed to an exemption exceeding three months.
I then had to decide whether operations should accordingly cease on 31 December, and the whole Brent system be shut down. Unless a mode of operation could be devised that was at least as safe as that required by the regulations, shut-down would have been the only course. I am glad to tell the House and those who will continue to be in employment in the next three months—the men on the platforms concerned—that my inspectors have established with the company that there is a mode of operation which meets this stringent safety standard. It involves, in particular, operating the system in what is known as dead crude mode—that is, that the natural gas liquids that are normally carried through the system will not be carried.
With the other conditions imposed, that means that operations of the system after 31 December will be at least as safe as they would have been had the valve work been fully completed. Indeed, in some cases it will be more so.
The hon. Member for Linlithgow (Mr. Dalyell), through the columns of the New Scientist of which I have become an assiduous reader in recent months, kindly paid tribute to the detail and analysis of the Department on safety and, if I recall rightly, on the emergency shut-down valves and the action to be taken to enhance safety. In the past week, an enormous amount has been put in by my inspectors and me. When I was not happy with the proposals they submitted, I asked them to discuss again with Shell at great length, and with particular reference to the Brent system, the new, tough and expensive conditions for the operators. Those conditions must be implemented if a derogation from the regulations passed by the House is to be given.
Five conditions must be met. First, the pipeline shall not be operated unless the true vapour pressure exerted by the substances within the pipeline is less than 2.07 bar absolute. Measurements shall be taken of the substances in the pipeline at intervals, no longer than 24 hours apart, and the measurements shall demonstrate that the TVP of the substances is below the pressure stated—the dead crude mode.
Secondly, the pipeline shall not be operated unless the pressure is less than that percentage of the pipeline maximum allowable operating pressure as declared in accordance with regulation 6(3)(a) of the Submarine Pipelines Safety Regulations (SI 1982) No. 1513. To the layman, that means that the pipelines shall be operated at reduced pressures. The reduced acceptable operating pressure should be at least 15 per cent. and in some cases up to 55 per cent. That will have a significant impact on the balance sheet of the operators. Although every pipeline has a maximum allowable operating pressure, the pipelines should not be operated unless those pressures are less than the percentage of the pipeline operating pressure as declared in accordance with the regulations.
The third condition is that apparatus or equipment for the testing, inspecting or maintaining of the pipeline shall not be introduced or recovered from the pipeline, unless such introduction or recovery is essential to maintain the safe operation of the pipeline. We are talking, in other words, about pigging. The problem with pigging is that 395 there is a potential safety hazard in the opening and closing of pipelines and pressure valves. That is why it is important to apply this condition.
Fourthly, work involving the use of naked flames, or the generation of sparks shall not be carried out in the vicinity of the pipeline between the existing emergency shut-down valve and the proposed new location of the ESD valve unless that work is essential to maintain or enhance the safety of the installation to which the pipeline is connected. There are clear restrictions on hot works.
The fifth condition ensures that the pipeline shall not be operated unless the pipeline between the existing ESD valve and the proposed new location of the ESD valve is visually inspected at intervals, no longer than three hours apart, for signs of leakage or damage and for any activities which might present a hazard to the pipeline.
Initially, I was in favour of a shorter interval between inspections, but if there was a visual inspection every hour, it would take the best part of half an hour to get down from one of the large platforms to undertake that inspection. We believe that the three-hour provision—albeit a rigorous condition to be placed on the operators—is the shortest time interval between such visual inspections.
§ Mr. DoranWe know that the Brent system has had serious problems. I recollect that the expected production from the system was about 200,000 barrels a day. That production level has not been achieved since at least May 1989. The last time I checked, current production was around 1,700 barrels a day. Does Shell anticipate any increase in that production or is that the production level on which the exemption was given?
§ Mr. MoynihanI do not have the precise figures for the expected production from all the various platforms in the North sea. If memory serves me a right, there is no anticipated increase in production. However, the reduced levels of production were largely due to maintenance work and down-time work required for safety purposes. Those factors represent a spike on the production graphs, but I shall happily give the hon. Gentleman the proposed production profile for that system.
I have agreed to exemptions only where the operator has satisfied me that he has made all appropriate plans and all necessary efforts to achieve the 31 December deadline and that his inability to achieve it is due to factors beyond his control. In various cases, for example, they include the failure of suppliers to meet deadlines. But where, on the basis of information supplied, I am not satisfied that the conditions have been met. I have refused to grant an exemption. I must report to the House that there are four such cases. There are three valves on the Texaco Tartan platform and a valve on the Beryl Alpha platform operated by Mobil. That is on the basis of information that I have received to date.
I inform the House—in response to an intervention by the hon. Member for Aberdeen, South—that the reason why we have come to the House with details at this stage is that we feel that it is right and proper that the House should be informed. However, we emphasise that it was the decision of the House that the exemptions could be applied for until 31 December. Effectively, what I have given the hon. Gentleman is a full progress report. It would be technically possible—although we do not anticipate it—for an operator to come forward with 396 further proposals up to the 31 December deadline, as agreed in the regulations. It is possible, for example, that we might receive further information from Texaco. That is why I emphasise that my position tonight is based on information that I have received.
§ Mr. DoranWhat would be the implications if permission for the four valves were refused? Would all operations on the platforms be shut down?
§ Mr. MoynihanThat is absolutely right. The operations on those platforms will be shut down until that work is undertaken. Equally, for the 18 valves on which work needs to be done—eight on the FLAG system, two on Morecambe, two on Sun Oil on Balmoral, four Shell gas valves on the FLAG system, and two further Morecambe gas valves we have said that production cannot start on any of the platforms until the valves are in place. I hope that the hon. Gentleman realises that that is a tough programme and a tough response by Government to make operators give top priority to safety. It will cost the operators money, but we believe that that money needs to be spent because safety must be first and foremost in the minds of the public, workers in the North sea and—as the hon. Gentleman said from a sedentary position—of everyone involved.
I have not had the opportunity to go as far as I would like on safety, but I shall pick up some of the points made in the last three minutes of the debate. The Government have accepted Lord Cullen's recommendation that sub-sea isolation systems need to be assessed on an individual basis as part of the safety case for each installation. We accept the argument that that need should be assessed in the light of the overall risk assessment, and we accept Lord Cullen's conclusions on that matter.
The regulations for the safety cases will, of course, be brought forward with all proper speed. Until responsibility is moved to the Health and Safety Executive, it lies firmly with the Department of Energy. We shall continue to have ministerial responsibility for offshore safety. An announcement will be made as soon as possible about the date and nature of the move.
Again, I give an undertaking to the House that we shall not hold back in making the change, but it is right and proper that discussions progress between the safety division and the HSE to ensure that a swift and effective move is made without undue haste. As my hon. Friend the Member for Ryedale (Mr. Greenway) said, the decision to make the move was taken on balance by Lord Cullen. The move should not reduce the importance of placing safety first and giving it proper consideration. We must assess often detailed divisions of responsibility between my Department and the safety officers who to date have worked within my Department.
Again I welcome the announcement made by Shell. To echo the point made by the hon. Member for Aberdeen, South, we welcome Shell's announcement in the past 48 hours that it intends to lift the bar on approximately 500 contract workers who sat in during the offshore dispute last summer and refused to go ashore when asked to do so by their offshore installation managers during the dispute. I also welcome the fact that Shell has announced plans to protect safety representatives from victimisation. In future, any matter involving an alleged breach of discipline on the part of a safety representative will be dealt with by senior Shell onshore management.
397 I hope that, in considering these matters, the House will continue to recognise that Lord Cullen's report should be seen not as the closing of a chapter but rather as the beginning of a new approach which will place safety on a far better footing in every installation in the North Sea. We 398 understand the strength of feeling that lies behind many of the concerns that hon. Members have voiced. We are convinced that prompt, comprehensive and effective implementation of Lord Cullen's report will represent real progress towards meeting those concerns and towards showing that they have been met. The Government are committed to securing prompt, comprehensive and effective implementation.