Five Estuaries Offshore Wind Farm Order 2025: implications for UK health and safety law and regulatory compliance

Five Estuaries Offshore Wind Farm Order 2025: clear implications for UK health and safety law and regulatory compliance

What has changed

In an offshore development consent known as The Five Estuaries Offshore Wind Farm Order 2025, the project promoter is authorised to construct, operate and maintain an offshore wind generating station off the coast of Suffolk. The order also authorises the compulsory acquisition of land and the use of land and to override easements and other rights in relation to the development. The change creates binding conditions linked to the project, including how safety governance, site management and contractor engagement must be conducted in line with UK health and safety law.

Why this matters for UK health and safety law and business

The order embeds safety and governance expectations into the lifecycle of a major offshore project. Duty holders across the supply chain — the promoter, main contractor, subcontractors, landowners and offsite partners — must plan, implement and demonstrate compliance with HSE requirements and the project specific conditions. This has broad implications for risk management, contractor management and safety case development in the offshore environment.

Key duties for employers and duty holders

Adopt a robust health and safety management approach aligned with UK health and safety law and, where relevant, ISO 45001. Practical duties include

• establishing clear governance and competent oversight for the project
• carrying out and maintaining comprehensive risk assessments for all offshore operations
• developing site specific safety plans, permit to work schemes and change control processes
• managing contractors and suppliers with clear safety expectations and monitoring mechanisms
• providing suitable training and worker engagement on safety matters
• ensuring arrangements for emergency response, incident reporting and investigation

Enforcement, sanctions and timelines

Non compliance with the order’s conditions can lead to enforcement action under the Planning Act 2008 and related legislation, with potential penalties including fines or revocation of consent. Organisations should plan for timely compliance and ongoing monitoring to avoid delays to the project and reputational risk.

Steps to achieve compliance

To align with the new requirements, organisations should

1. review the order’s conditions and identify all applicable safety and governance obligations
2. map responsibilities across the promoter, contractors and suppliers
3. update risk assessments and method statements to reflect offshore operations and land use constraints
4. strengthen contractor management, including pre qualification, induction and ongoing oversight
5. update policies and procedures to reflect the order and HSE requirements
6. consider adopting or aligning with an ISO 45001 health and safety management system
7. engage workers and representatives in safety planning and risk controls
8. ensure competent advice is available from suitably qualified sources
9. document governance and assurance activities to demonstrate compliance

Synergos Consultancy can support governance, risk management and management system alignment with ISO 45001 for systematic control of workplace risk and legal compliance, see ISO 45001 occupational health and safety management. For health and safety risk assessments and competent person support, visit health and safety risk assessments and Competent Person support.

Further guidance and support can be found via health and safety support packages and health and safety training.

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