Critical review and recommendations for strengthening health and safety and major accident prevention regulations for carbon capture and storage in UK ports

Abstract

Carbon Capture and Storage (CCS) is an essential component of the UK Government’s net-zero strategy. Policies emphasize the need for flexible and accessible CO₂ transport and storage networks, with shipping emerging as a key non-pipeline transport modality to connect industrial clusters to offshore storage. In this article, we assess whether current health and safety and major accident prevention regulations adequately govern the risks posed by expanding CO₂ handling and storage in UK ports to support CCS deployment.

Our analysis identifies three regulatory gaps. First, while the Port Marine Safety Code addresses regulatory complexity in UK ports through establishing uniform national standards for marine safety, it cannot regulate the emerging risks of anticipated large-scale CO₂ shipping activities without clear performance standards in specific legislation. Second, duly appointed harbor masters must be well-informed to effectively exercise the powers granted under the Dangerous Goods in Harbour Areas Regulations (DGHAR) to reduce serious accident risks associated with increased CO₂ shipping. Third, the Control of Major Accident Hazards Regulations (COMAH) currently exclude temporary CO₂ storage and do not include CO₂ within their scope, limiting their effectiveness for major accident prevention in port storage scenarios.

To address these gaps, we recommend issuing tailored guidance under DGHAR to clarify risk management responsibilities for CO₂ shipping and amending COMAH to include CO₂ storage and recognize CO₂ as a dangerous substance. These reforms are essential to protect port communities, ensure robust risk management, and support the safe, sustainable expansion of CO₂ shipping as a critical enabler of CCS.