Where this comes from
Since 2025 the HSE enforcement register has been a searchable web application with the inspector's summary attached to each notice. Thirty thousand notices are on it, covering a rolling five years. In September 2026 we read the summaries of every notice the register returns for the words operators use every day: isolation, permit, bypass, override, inhibit, written scheme, thorough examination, handover, overdue, record. That is a little over 2,300 notices, or about 1,800 once notices served together on one visit are counted once.
Three things to know before reading on.
- The summary is the inspector's account of what they found on the day, written for a legal notice. It is not an investigation report and it is not the company's account.
- Almost every notice quoted below is marked on the register as complied with, remedial action taken. The notice is the moment a site was asked to show something and could not, on that day. It is not a verdict on the site.
- “Could not demonstrate” means the inspector could not verify it. It does not mean the work was not done. That distinction is the whole point of this article, and it cuts both ways.
The pattern, in the inspector's words
1. The procedure had no way of showing it had been followed
A drilling contractor was visited after a riser package was dropped in February 2024. The inspector read the controlling procedure and wrote:
“the procedure did not contain any verification or assurance checks to confirm that the requirements of the procedure had been complied with, including such critical operations as locking the tension ring to the outer barrel of the slip joint. In addition there were no records maintained to demonstrate that the work had been carried out to the requirements of the procedure.”
The procedure existed. It was at revision 7, dated three months earlier. What it lacked was any step that would leave evidence behind.
2. The isolation was in place, but its integrity was not proven
Two notices from hydrocarbon installations say the same thing a year apart.
“production gas cooler [tag elided] had been isolated under isolation certificate DIC-CGA-0003056031 on the 15th March 2025. Inspection of the work permit and the isolation certificate for this activity identified deficiencies in: (a) Isolation integrity testing, such that valve integrity was not adequately proven prior to breaking of containment”
“Integrity of the valves - G1535F, G1644F and G1645F on the gas freeing line could not be demonstrated, and are suspected to be leaking … There were more than 50 anomalies on the IG system, 38 of them were overdue at the time. … Two inert gas block valves were open when the inert gas was not in use for system top ups without suitable isolations”
A certificate existed in both cases. What could not be shown was that the valves behind the certificate held. On another installation the check had been signed, and the valve was still wrong:
“isolation point 41 on IC DIC-GRY-0002162468 was found to be in the incorrect position. Isolation point 41 was part of a double block and bleed isolation for preventing flow of hydrocarbon gas to the work site. Your control of work process requires that all isolation points are verified by a 2nd person with additional check points included in your work permits, namely that all isolations are shown to the work party prior to work commencing. By issuing of the work permits, you considered these checks to have been completed but still failed to identify the incorrect position of isolation”
“Isolation ICC 344626 for breaking of containment on A3 well flowline relied on a single valve isolation (SVI), which you could not demonstrate had been adequately integrity tested”
Onshore, at a pharmaceutical site, the passing valve announced itself:
“During Isolation of B117 Steam Header from 22nd Dec to 28th Jan Steam Bleed Valve B was closed under permit No. 274379. The valve failed and continued to pass steam into the Header. This led to condensate forming, filling the header. Resulting in a Water Hammer event when the isolated header and pipework was returned to live steam service.”
At a chemical works in Bradford the gap was one step earlier, in who could tell:
“permit acceptors have suitable or sufficient understanding of the isolations required for work activities; they rely upon the permit to work authorisers knowledge to ensure that adequate isolations are applied to allow work to commence. Hence, they are not able to challenge the isolations or understand if adequate isolations are installed.”
3. The checks were happening, but nobody was checking the checks
The clearest single statement of the pattern comes from an offshore installation inspected in November 2021:
“In 2020 and 2021 you had not undertaken effectiveness audits of your arrangements for preventing Major Accident Hazards including areas such as Safe Isolation and Re-instatement of Plant, Control of Overrides and Inhibits, Alarm Management, and Competence Management System as required by your procedures, and b) you had not implemented suitable arrangements for the monitoring and review of findings from your frontline compliance checks to identify underlying themes or trends”
Frontline compliance checks were being done. Their findings went nowhere. Two COMAH sites onshore received the same finding in different words:
“you have failed to adopt and implement procedures for the ongoing assessment of compliance with the objectives set by your major accident prevention policy and safety management system, in particular you have failed to have effective arrangements for investigating and taking corrective action in case of non-compliance”
“The safety management system (SMS) has failed in relation to monitoring performance – it has not adopted and implemented an effective procedure for the ongoing assessment of compliance with the objectives set by your MAPP/SMS, relating to the control of your dangerous substance inventory”
“You have failed to implement your major accident prevention policy though a safety management system that monitors performance by the adoption of and implementation of procedures for the ongoing assessment of compliance for processes that involve isolating and breaking containment of plant and equipment that contains hazardous substances … specifically mechanical isolation audit procedures”
4. The plan was written. The dates were not.
“you set out your plan for maintenance of the hose reel system in document ‘GL-N-M306 – Offloading Hose Reel Maintenance Routine’ in 2023 but did not set appropriate due dates for the identified maintenance intervals on your maintenance management system based on actual maintenance history and time in operation, meaning that the identified critical maintenance routines were not completed in a timely manner.”
The same shape appears on a North Sea platform where a dead leg had been found corroding two years before the notice:
“as you have identified in ORA 461085 first raised on 13/04/24, you failed to carry out fabric maintenance as identified from your inspection findings and have failed to install permanent protection measures … There are no means to isolate the degraded sections of line [tag elided] from the SAGE riser.”
And at a fuel depot in Argyll, where the inspection reports were the evidence:
“tank inspections reports (Serial Numbers: Corr018/2024 … Corr023/2024) describe serious internal corrosion at each of the tank support saddles including pitting of the carbon steel vessel walls to 50% of as built thickness”
In all three the paper existed and said the right thing. What was missing was the link from the paper to a dated action that someone would be asked about. Sometimes the list of those actions was itself the finding:
“of 424 items on your overdue list, 237 safety and safety critical items on hydrocarbon live installations were noted as beyond the “max overdue date” i.e., they had not been repaired / rectified or been further risk assessed and managed as per the requirements of your safety case”
“you failed to action the priority one repairs and inspections as described within competent persons (Flotech Ltd) EMMUA 159 inspection report No.42008921 regards No. 4 bulk Fuel Storage Tank”
“operating equipment beyond the postponement date and not ensuring that operating the equipment does not give rise to danger”
5. The examination that the scheme required had not happened
“Your risk-based inspection (RBI) management system has led to a situation where several hydrocarbon-containing topside pressure vessels have not undergone internal inspection since being brought into service, up to 17 years ago in some instances. Internal inspections have been deferred without appropriate risk-based justification being documented … you could not demonstrate the integrity of vessel [tag elided]”
“The company could not demonstrate that it was inspecting, in line with recognised good practice, its bulk storage tanks that contain hazardous substances, which can deteriorate in service and could cause danger.”
“You have failed to ensure that a suitable written scheme is in place for your pressure vessel BBV27 … You have failed to ensure that a competent person has conducted an examination of your pressure vessel “BBV27””
“you have failed to ensure that Liquid Nitrogen Storage Tank No. 1 been subjected to a revalidation in accordance with BCGA COP 39 as required by Written Scheme of Examination 060-32-TS-X0001”
“You have not internally inspected potable water storage tanks [tags elided] since their installation in May 2016, you had not inspected rig water storage vessel [tag elided] between February 2014 and December 2025 … The temperature control parameters were out of specification for a period in 2025”
The last one is worth a second look. “Out of specification for a period” is what an inspector writes when the readings exist but nobody acted on them, or when nobody can say which period.
6. The shift changed and the information did not survive it
“you have failed to adopt procedures and instructions for the safe operation of, including maintenance, of plant, processes and equipment, specifically you have failed to adopt adequate procedures for shift handover”
“your arrangements for identifying, communicating and controlling risks through permits to work, were not appropriate. Nor were they effectively implemented, supervised and monitored … your arrangements for safety critical communication during shift handovers, were not appropriate.”
What these have in common
None of these is a small operator. Several are among the largest names in British process industry. Every site had a procedure, a certificate, a scheme, a routine or a handover arrangement. In every case the inspector's finding is about the gap between the arrangement and the ability to show it worked: no verification step, no proof of valve integrity, no review of the checks, no due date on the plan, no examination against the scheme, no structure to the handover.
What this article does not say
- It does not say these companies are unsafe. The register records that most of these notices were complied with, and a notice is served to secure an improvement, not to punish.
- It does not say how common this is. We read about 2,300 notices out of 30,000, chosen by search terms, and quote 26. HSE also publishes a separate spreadsheet of notices its own migration left off the register. No percentage in this piece would survive scrutiny and none is offered.
- It does not say “no record” means “not done”. It means not shown.
- Equipment tags inside the quotations are elided and shown as [tag elided]. The register carries them in full. Nothing else in a quotation has been changed.
- The inspector's summary is written for a notice, sometimes covering several notices from one visit. We have quoted only the passage that belongs to the notice cited.
Six questions to ask of your own records
Each of the notices above is a question a site was asked and could not answer. Ask them of your own plant before someone else does.
- Pick one item on a shift round. For a night two years ago, can you show it was checked, what the reading was, what the limit was that night, and what was done if it was outside it?
- Pick one isolation currently in place. Can you show who proved the valves held, and how?
- Pick one inhibit or override that has been in for more than a week. Does the incoming shift see it without asking?
- Pick one maintenance routine that your procedures call critical. Does it have a due date somewhere that will turn red?
- Pick one finding from last month's frontline checks. Who read it, and what changed?
- Pick one pressure vessel. When was it last examined against its written scheme, and can you produce the scheme?
Where Amberhold fits, and where it does not
Amberhold records operator rounds and temporary controls. It keeps who checked what, when, against which limit, and what they decided, in a record the database will not let anyone edit or delete. It shows every active inhibit, override and isolation on the board for the incoming shift, with a reason and a person on it. It keeps a missed check on the board until it is done or acknowledged with a reason. That covers questions one and three above, and part of five.
Straight talk
Sources
HSE enforcement notices register, notices.hse.gov.uk, read 13 and 15 September 2026. Search by notice number: 314115322 · 314993161 · 314930638 · 312483058 · 313060777 · 312185958 · 314289661 · 312111547 · 314002729 · 315977266 · 313453466 · 315922439 · 315752567 · 314465933 · 312622671 · 312596483 · 313193908 · 315389459 · 314938177 · 314938194 · 315834126 · 315834200 · 315964146 · 315748826 · 314452742 · 314061215 · 314061368.
Contains public sector information licensed under the Open Government Licence v3.0.