Well Construction Lower Stumble, Balcombe

The request was partially successful.

Dear Health and Safety Executive,

1. As the production well at Lower Stumble had insufficient time to run cement bond logs due to end date stipulated in planning consent. Please now supply the cement bond log that should have been run as part of any well completion programme.

2. On what date was the programme to complete the well completed?

3. If incomplete what is still to be done and on what date will the well at Lower Stumble be complete?

4. What other tests have been carried out by the operator to check the integrity of the well? Please supply the report of 'other tests' carried out.

5. What tests have HSE conducted themselves to confirm well integrity at the site Lower Stumble, Balcombe, West Sussex?

6. Please supply the document submitted under the Borehole Sites and Operations Regulations 1995 notification of the well design for Lower Stumble, Balcombe.

7. Please supply the Well Operations Inspector report with regard to question 6.

8. Please supply the submitted weekly operations reports for Lower Stumble, Balcombe.

9. Please supply any notes or comments on the inspected reports by a Well Operations Inspector at HSE.

10. Under what circumstances will the HSE take 'appropriate regulatory action' during construction phase?

11. What is 'appropriate regulatory action'?

12. During the well construction phase of Lower Stumble, Balcombe please supply copy emails and written correspondence between HSE and the operator

13. On what dates and where did HSE meet with the well operator of Lower Stumble Balcombe prior to operations to ensure they have a good understanding of the Health and Safety regulatory regime?

14. How did HSE ascertain that the well operator had good understanding of the Health and Safety regulatory regime?

15. As there were NO on site inspections by HSE at Lower Stumble and HSE state that 'wells are deep underground and complex in their construction. Most of the structure is not accessible to visual inspection' and NO cement bond logs or cement density logs were submitted for Lower Stumble please supply documentary evidence that the well at Lower Stumble absolutely complies to regulations.

16. Also supply the independent well inspectors report of well integrity and how he/she ascertained the well at Lower Stumble Balcombe integrity.

17. What regulations are in place for 'below ground' hazards and how do HSE monitor below ground operations?

Yours faithfully,

Diane Forster

Health and Safety Executive

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1 Attachment

 
 

Elspeth More / Business Support Administrative Team Leader / 

HID Energy Division - Offshore

Health & Safety Executive, Lord Cullen House, Fraser Place, Aberdeen, AB25
3UB 

(: Internal Direct Line 525 2535 | (: External Direct Line +44(0) 1224
252535 | *: [1][email address]

 

Working Pattern

Tuesday - Thursday 0930 - 1700

Friday 0930 - 1530

 

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Dear Health and Safety Executive,
Further to your reply to my FOI 30 July 2014 and your reply 29th August 2014.

My questions have not been fully answered and I therefore request full replies to the following

CBL's have not been run and HSE in a previous FOI stated the following.

'The production casing was run and cemented but due to the end date stipulated in the planning consent and delays to the construction there was insufficient time to run a cement bond log. A cement bond log will now be run as part of any well completion programme for which the Well Operator has applied for planning permission.'

Research shows that - Completion, in petroleum production, is the process of making a well ready for production (or injection).

Question 1: If permission is granted for exploration and or production at Lower Stumble will HSE publish the CBL's and set a date by which the CBL's must be not only completed but analysed and reported upon prior to any work being started.

Question 2
If as you infer from the answers to my previous FOI the Well Balcombe 2 is NOT complete, what is still to be done to make Balcombe 2 complete? If it is indeed complete when will HSE make available the CBL's?

Question 3
If HSE do not hold reports of 'pressure tests and the cement casing sheaths formation integrity tests' on what date did you have sight of these test results and which agency does hold the results?

Question 4
HSE requested 'confirmation that the 7" casing was pressure tested , to what pressure confirmation that has been carried out below the 7" casing and to what value'
I request a copy of said report? The date it was requested by HSE ?and the date it was submitted by well operator at Lower Stumble ?

Question 4
If as you state 'it is not the role of HSE to prove compliance with regulations but to take appropriate action where there is evidence that a duty holder is in breach of relevant regulations'

What evidence is required to prove a breach?

Question 5
My previous question regarding 'below ground' hazards and how HSE monitor below ground operations. You directed me to Wells Design and Construction Regulations 1996. This document relates to OFFSHORE
'The Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996'

Therefore please answer my question what regulations are in place for below ground hazards ONSHORE such as Lower Stumble?

Question 6
HSE use non disclosure to my previous FOI questions 6 & 8 as commercially sensitive.
How are these reports commercially sensitive?
HSE also state disclosure would adversely effect Intellectual Property Rights.
As defined - Intellectual property rights
Intellectual property rights are the rights given to persons over the creations of their minds. They usually give the creator an exclusive right over the use of his/her creation for a certain period of time.
My question then - Surely the weekly reports requested are not 'the creation of the mind' rather factual reports, therefore I question withholding the reports.

Can you fully explain HSE rationale for this decision?

Question 7
Also in reply to my request for reports question 6 & 8 30th July 2014 HSE section in RED that begins 'The presumption under the EIR is that environmental information should be released unless there are compelling and substantive reasons to withhold it. - disclosure of the information: In taking account of the harm caused to the third party reaction to having their rights threatened, in that they may no longer be prepared to provide information to the level of detail they submit which may inhibit our effectiveness'
My question then - is it not REGULATION that operators provide information as part of their permissions to operate. That with out submission of the required information and documentation the operator whom ever they are would be in breach of Regulations and stopped from continuing. Who police's the REGULATIONS to ensure a regulatory regime fit for purpose?

Question 8
Your final sentence in RED 'Disclosure of sensitive and intellectually protected information is likely to affect the level of investment in the development of alternate energy' Please direct me to the remit of HSE that puts levels of investment in any project over and above protection of the environment from risks that may arise from work activities? Where in the HSE guidelines and regulations are such rules/statements/regulations?

Question 9
HSE Document in reply to my question 7 (30/7/14)

'Notification Assessment Summary' 26th April 2013
Please explain the following from Inspector Remarks/Issues

Submission compliance
Generally complies -
When was there a NON compliance and what was the NON compliance?

Major hazards -
Potential collision with Balcombe 1
What further action was advised/taken with regard to the 'major hazard'?

Novel Equipment
Separate notification to be submitted for 'matrix acid wash'
Please provide this notification?

Intervention required
drill to Ashdown as a water well to monitor and get baseline readings for gas.
Supply baseline readings as submitted?

Question 10

Email dated 9th September 2013 09:47

Please supply response to that request and also advise HSE's interest in Noise pollution which is regulated by the EA?

Question 11

Email dated 19th June 2013 11:49

Please provide reply to email that shows the chemical constituents of the mud system?

Question 12
Email dated 8th May 2013 13:11 from HSE

Para 3. matrix acid wash with coil tubing - Confirm what was in this Matrix Acid Wash.

Para 4. Please supply copy of the report 'Status of Balcombe 1'

Para 5. supply copy report covering this paragraph - Balcombe 1 flowed water in the Ashdown Beds, there appears to have been gas associated with this flow - please advise make up of this gas.

Final para. Supply a copy of the Safety Document as required by the Borehole Sites and Operations Regulations 1995 and HSE's review of that document.

Question 13

Email Dated 31st May 2013 08:32
Please advise the process employed and confirmation that the sands were not drilled into.

Question 14
Email 22 August 2013
Please send reply to HSE question the intent of Cuadrilla top go straight to acid was prior to any attempt to flow the well.

send reply and advise from Cuadrilla to points raised in HSE email as above including
When initial flow attempt will be made?
squeeze pressures for acid matrix wash?

Question 15
Please supply a copy of the UPDATED BSOR document that reflects the additional risks associated with testing operations.

Diane Forster

Health and Safety Executive

Dear Ms Forster

 

Environmental Information Request Reference No: 2014090082

 

Thank you for your request for information concerning 15 queries regarding
a previous request 2014080035.  We tried to provide you with the necessary
answers/information as best we could.  Please note we are treating this
query as a fresh request and will endeavor to respond to your queries as
requested.

 

Your request was received on 4^th September 2014 and I am dealing with it
in accordance with the Environmental Information Regulations 2004. Under
the terms of the Regulations you are entitled to a response within 20
working days of receipt.

 

If for any reason we are unable to meet this deadline we will keep you
fully informed of the reasons for this and will tell you when you can
expect a response.

 

Guidance on how the Health & Safety Executive deals with requests under
the Freedom of Information Act and Environmental Information Regulations
can be found on the HSE website at [1]http://www.hse.gov.uk/foi/index.htm

           

If you have any queries about this letter, please contact me. Please
remember to quote the reference number above in any future communications.

 

Yours sincerely

 

Jennifer Donaldson

FOI Officer

 

 

Jennifer Donaldson / Business Support Administrator / HID Energy Division
/ Offshore.

Health & Safety Executive, Lord Cullen House, Fraser Place, Aberdeen, AB25
3UB

Internal Direct Line: 525 2503 / External Direct Line +44 (0) 1224 252503
/ Email: [2][email address].

Work Pattern: Mondays & Tuesdays only

 

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Communications via the GSi may be automatically logged, monitored and/or
recorded for legal purposes.

References

Visible links
1. http://www.hse.gov.uk/foi/index.htm
2. mailto:[email address]

Dear Health and Safety Executive,

Re:Environmental Information Request Reference No: 2014090082

I am yet to get a response from you. Please reply as this FOI exceeds 30 days.

Yours faithfully,

Diane Forster

Health and Safety Executive

Due to my work pattern and leave, I will return on Monday 27th October 2014. If anything requires urgent attention, please contact Elspeth More on 01224 252535, or Jean Evans 01224 252583.

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Health and Safety Executive

Dear Ms Forster

 

Environmental Information Regulations Reference No: 2014090082

 

Thank you for your request for information about 15 queries regarding a
previous request (20140800035).  Please note this is a fresh request and
will endeavor to answer your queries as fully as requested.

Your request was received on 4^th September 2014 and I am dealing with it
under the terms of the   Environmental Information Regulations 2004.

I can confirm that the Health and Safety Executive holds the following
information:

 

1.     If permission is granted for exploration and or production at Lower
Stumble will HSE publish the CBL’s and set a date by which the CBL’s must
be not only completed but analysed and reported upon prior to any work
being started.

 

A.    The executive do not hold the results of the cement bond logs they
are the property of the Well Operator.  To comply with the Borehole Sites
and Operations Regulations 1995 the well operator has to submit to the
Executive a well notification, a minimum of 21 days prior to proposed
start of operation, with a schedule of operations he will undertake on the
well.  The well notification will be inspected by a well operations
inspector and the schedule of work agreed.  The Executive are not
prescriptive in how well operators manage their operations.  If the
Executive are not satisfied that the risks are as low as is reasonably
practicable then they can take enforcement action.

 

2.     If as you infer from the answers to my previous FOI the Well
Balcombe 2 is NOT complete, what is still to be done to make Balcombe 2
complete? If it is indeed complete when will HSE make available the CBL’s?

 

A.    The Balcombe 2Z borehole has been constructed and suspended as
planning permission for operations at the site expired.  It is understood
that there is an on-going appeal against the granting of additional
planning permission, however, if the borehole was to be completed then as
a minimum a production tubing and Christmas tree will be run to provide a
conduit for any hydrocarbons to be produced to surface.  The exact details
of the completion program will be included in the well notification to be
submitted by the Well Operator.  The borehole has not been completed.

 

3.     If HSE do not hold reports of ‘pressure tests and the cement casing
sheaths formation integrity tests’ on what date did you have sight of
these test results and which agency does hold the results?

 

A.    To comply with the well aspects of the offshore installations and
wells (design and construction etc.) regulations 1996 the well operator
must submit to the Executive weekly drilling activity reports.  These
reports will contain details of pressure tests and formation integrity
tests.  The weekly drilling activity reports are held by the Executive.

 

4.     HSE requested ‘confirmation that the 7” casing was pressure tested,
to what pressure confirmation that has been carried out below the 7”
casing and to what value’.  I request a copy of said report? The date it
was requested by HSE? And the date it was submitted by well operator at
Lower Stumble?

 

A.    The information on pressure testing was requested from inspection of
the weekly drilling activity report ending 15^th September 2013.  The well
operator responded on the 16^th September 2013 with the requested
information.

 

5.     If as you state ‘it is not the role of HSE to prove compliance with
regulations but to take appropriate action where there is evidence that a
duty holder is in breach of relevant regulations’.  What evidence is
required to prove a breach?

 

A.    The HSE’s enforcement policy statement sets out the regulatory
approach.  Please see link attached for more information:

[1]http://www.hse.gov.uk/pubns/hse41.pdf

 

6.     My previous question regarding ‘below ground’ hazards and how HSE
monitor below ground operations.  You directed me to Wells Design and
Construction Regulations 1996.   This documents relates to OFFSHORE ‘The
Offshore Installations and Wells (design and Construction, etc.)
Regulations 1996’.  Therefore, please answer my question what regulations
are in place for below ground hazards ONSHORE such as Lower Stumble?

 

A.    The Well aspects of the offshore installations and wells (design and
construction etc) regulations 1996 apply equally to onshore and offshore
wells.  Regulation 3 of the said regulations “Application” guidance 19
states – “This regulation applies to the requirements on wells in DCR to
oil and gas wells in Great Britain, and all wells in territorial waters
and the UK Continental Shelf.

 

7.     HSE use non-disclosure to my previous FOI questions 6&8 as
commercially sensitive.  How are these reports commercially sensitive? 
HSE also state disclosure would adversely affect intellectual property
rights.  As defined – Intellectual property rights.  Surely the weekly
reports requested are not ‘the creation of mind’ rather factual reports
therefore I question withholding the reports.  Can you fully explain HSE
rationale for this decision?  The weekly reports contain commercially
sensitive information that cannot be released without approval of the well
operator.

 

A.    We stand by our decision on our interpretration of the EIR
Regulations.  Please see our reasons for non-disclosure at the end of this
correspondence.

 

8.     Also in reply to my request for reports question 6 & 8 30^th July
2014 HSE section in RED that begins ‘The presumption under the EIR is that
environmental information should be released unless there are compelling
and substantive reasons to withhold it – disclosure of the

 

information: in taking account of the harm caused to the third party
reaction to having their rights threatened, in that they may no longer be
prepared to provide information to the level of detail they submit which
may inhibit our effectiveness’.  My question then – is it not REGULATION
that operators provide information as part of their permissions to
operate.  That without submission of the required information and
documentation the operator, whoever they are, would be in breach of
Regulations and stopped from continuing.  Who polices the Regulations to
ensure a regulatory regime fit for purpose?

 

A.   The current level of information supplied by the operators is far
greater than what is required by our Wells (Design and Construction)
Regulations 1996.  If this information was to be disclosed to third
parties then this would result in the operators greatly reducing the level
of detail – There is a robust and long established regulatory regime in
place in the UK covering all petroleum wells and boreholes.  There have
been a number of reviews of the work of HSE over the last few years.  Each
of the reviews has found that the regulatory regime is fit for purpose. 
Further information is available on the HSE website:
[2]http://www.hse.gov.uk/aboutus/health-and...

9.     Your final sentence in RED ‘Disclosure of sensitive and
intellectually protected information is likely to affect the level of
investment in the development of alternate energy’.  Please direct me to
the remit of HSE that puts levels of investment in any project over and
above protection of the environment from risks that may arise from work
activities?  Where in the HSE guidelines and regulations are such
rules/statements/regulations?

 

A.    See response to question 7.  Also attracting investment into
alternative energy is not part of HSE’s remit, it is part of the wider
Government remit.  As such it should not have been included in the
original response.

 

10.   When was there a NON Compliance and what was the NON Compliance?  A
number of queries were sent to the well operator to be responded to, to
show compliance with the schedule.  What further action was advised/taken
with regard to the ‘major hazard’?

 

A.    A Weatherford magnetic MWD is planned for the sidetrack.  Magnetic
interference from Balcombe-1 has been considered, and consultation has
indicated that at 33ft separation the magnetic tool should be
satisfactory.  However, the base plan is to stroke the drill string into
the hole with the pipe marked for the motor bend, such as has been common
practice in other wells in the area to greater depths.  This is regarded
to start sidetracking at least within the chosen quadrant, with correction
being achieved once magnetic interference ceases.  The error ellipse is
calculated taking this into account.  A magnetic instrument (Weatherford
AMS) is being considered instead of Totco measurements for the pilot hole,
which will provide early indications of magnetic interference.  A custom
Instrument Performance Model (IPM or toolcode) is also being investigated,
based on another Operator’s successful experience with multiple wells on
17ft spacing.

 

11.  Email dated 9^th September 2013.  Please supply response to that
request and also advise HSE’s interest in Noise pollution which is
regulated by the EA?

 

A.    The Company Response to this request is as follows – “We have been
having an on-going battle against noise, after measurements early in the
project lead us to believe we were compliant.  All indications are that we
are compliant during the day, so drilling operations have been running
during the day, Mon-Friday.  We shut down all weekend due to “LAF90”
measurements indicating 45-48dB(A) at the closest residence, versus the
limit of 42dB(A) permitted between certain hours/days.  Yesterday we
installed a 6m high scaffolding wall along the west and north sides of the
heavy machinery and draped that with Eco-mats.  Today a layer of plywood
is being added to the scaffold-board wall which apparently further
increases attenuation.  Yesterday evening a noise specialist made
measurements indicating 42-43 dB(A) while drilling so we shut down again
for the night, in order to be sure of being fully compliant.  We expect
that today’s measurements will put us below the limit so that we can
operate 24/7 and actually get finished.  We do not receive noise
measurements from our fixed monitoring station continuously as live feed,
rather the data is downloaded periodically and then processed by a
different noise consultant – hence the lag in response in the past.”

 

The HSE regulates noise as it applies to worker exposure.  The relevant
legislation is described in HSE publication L108 ‘Controlling Noise at
Work’, which describes the requirements of the Control of Noise at Work
Regulations 2005.  On rare occasions, where it might become involved in
consideration of exposure to members of the public, this would normally be
at higher levels than those referred to in the extract.  Environmental
noise as described, is therefore outside our jurisdiction, and is
regulated by other bodies in England and Wales, including the Environment
Agency and Local Authorities as appropriate.

 

The noise exposure to workers on the site does come within HSE
jurisdiction, but there is insufficient information in the extract to make
a comment on that matter.

 

12.  Please provide reply to email that shows the chemical constituents of
the mud system?

 

A.    The chemical constituents of the drilling mud for the water well
were:

1.     Pure Bore: natural biodegradable drilling fluid base product

2.     Clear-Stabiliser HV/LV: natural cellulosic high viscosity fluid
loss polymer

3.     Ground marble (calcium carbonate), for bridging and initial
densification

4.     Barite, for final densification

All products used were confirmed by the supplier to be termed
non-hazardous pollutants to ground water per 2000/60/EC Annex VIII (the EU
Directive).

 

13.  Confirm what was in the Matrix Acid Wash and supply copy of the
report ‘Status of Balcombe 1’, Supply copy of report on flowed water in
the Ashdown Beds and appears to have gas associated with this flow and a
copy of the safety document.

 

A.    The matrix acid wash was not completed.

Status of Balcombe 1:-

 

The vertical Balcombe-1, Well Registration Number LR/30-3, was drilled
during 1986 by Conoco(UK) Limited, the then operator on PL244.

 

After drilling to TD of 5660ft in 8 1/2” hole, two openhole tests were
carried out, across the Corallian Limestone and Kimmeridge Micrite, before
plugging the 8 1/2” openhole back to 4560ft.

 

7” casing was then run to surface and these two formations were tested
again, both before and after acid washes, with some oil production noted
using nitrogen lift and swabbing lift assistance.  46 bbls of 33° API oil
was recovered at a rate of approximately 50bbld/day from the Kimmeridge
Micrite after acid wash using swabbing lift assistance.

 

The well was permanently plugged and abandoned during March 1987 using the
West Endeavour workover unit.

 

Taken from Exlog’s mud logging records:  the gas composition as recorded
from the water flow at 178ft near the top of the Ashdown Beds was C1 at
54,910ppm and C2 at 1335ppm.  It is noted from the reports that the
section was drilled with only the conductor pipe in place, and after
taking the 150bbl water flow, the well was killed by circulating 8.9lb/gal
mud into place, and drilling continued without further events.  There is
no indication that free gas flow occurred.

 

We are unable to provide a copy of the Safety Document as this is the
company’s own document which is kept onsite and a copy would either be
viewed or requested by our HSE Inspector and once satisfied with document
is returned to the company and is not retained by us at HSE.

 

14.   Please advise the process employed and confirmation that the sands
were not drilled into.

 

A.    The top of the Ashdown Beds were confirmed by the water monitoring
well drilled at the edge of the well pad and so the confirmed top of the
Ashdown was available before the spudding of Balcombe-2.

 

15.  Please send reply to HSE question the intent of Cuadrilla top go
straight to acid wash prior to any attempt to flow the well.  Send reply
and advice from Cuadrilla points raised in HSE email, when initial flow
attempt will be made and the squeeze pressure for acid matrix wash.

 

A.    It was intended to go straight to the acid wash without first
attempting to flow test.  The purpose of the acid wash is not for
stimulation of native permeability but for removal – as far as possible –
of completion-induced formation damage.  The objective is to establish the
productivity achievable with a horizontal borehole in the least damaged
condition.  The completion operations were not started as it is understood
that there is an appeal against the planning permission.

 

16.  Please supply a copy of the UPDATED BSOR document that reflects the
additional risk associated with testing operations.

 

A.    As per previous response on question 13, this updated safety
document is not retained by HSE.

 

Information numbered [1-3, 5-16] as answered above.  Information numbered
[4] (namely the Weekly Drilling Activity Report) is being withheld in full
as it falls under the exceptions in Regulations 12 (5) (c) ‘Intellectual
Property Rights’ & 12(5) (b) ‘Course of Justice’.

Regulations 12 (5) (c) & 12(5) (b) are qualified exceptions that are
subject to the public interest test.

 

This means that HSE has to balance the public interest factors favouring
disclosure against those favouring non-disclosure.  I have decided not to
disclose the Weekly Drilling Activity Report.

In this case, I have considered the following factors in favour of
disclosure:

 

·         Disclosure would promote transparency and build public
confidence in HSE’s Regulatory regime.

·         Disclosure would assist the public to understand an issue which
is subject to significant public interest, i.e. the Borehole Site and
Operations Regulations 1995.

And the following factors in favour of non-disclosure:

 

·         Disclosure would inhibit HSE’s ability to conduct investigations
effectively as duty holders would be less willing to volunteer information
with the level of detail they currently provide to HSE if information is
disclosed inappropriately;

·         Disclosure could weaken our position with the wider public
concerning this highly sensitive subject and the usefulness of such
sensitive information to its competitors.

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terms of the Open Government Licence. To view this licence, visit
[3]http://www.nationalarchives.gov.uk/doc/o... or
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TW9 4DU, or e-mail: [4][email address].

 

Information you receive which is not subject to Crown Copyright continues
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If you have any queries about this letter, please contact me. Please
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If you are unhappy with the decisions made by HSE you may ask for an
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If you are not content with the outcome of the internal review you have
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Tel: 01625 545700

Fax: 01625 524510

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Website: [6]http://www.informationcommissioner.gov.uk

Yours sincerely

 

Jennifer Donaldson

FOI Officer

 

Jennifer Donaldson / Business Support Administrator / HID Energy Division
/ Offshore.

Health & Safety Executive, Lord Cullen House, Fraser Place, Aberdeen, AB25
3UB

Internal Direct Line: 525 2503 / External Direct Line +44 (0) 1224 252503
/ Email: [7][email address].

Work Pattern: Mondays & Tuesdays only

 

show quoted sections

 

 

show quoted sections

Communications via the GSi may be automatically logged, monitored and/or
recorded for legal purposes.

References

Visible links
1. http://www.hse.gov.uk/pubns/hse41.pdf
2. http://www.hse.gov.uk/aboutus/health-and...
3. http://www.nationalarchives.gov.uk/doc/o...
4. mailto:[email address]
5. mailto:[email address]
6. http://www.informationcommissioner.gov.uk/
7. mailto:[email address]

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