The Norfolk Boreas Offshore Wind Farm Amendment No 2 Order 2025 and UK health and safety law: implications for regulatory compliance

The Norfolk Boreas Offshore Wind Farm Amendment No 2 Order 2025 and UK health and safety law: implications for regulatory compliance

What has changed

The Norfolk Boreas Offshore Wind Farm Order 2021 is being amended by The Norfolk Boreas Offshore Wind Farm Amendment No 2 Order 2025. The amendment is implemented as a non-material change under paragraph 2 of Schedule 6 to the Planning Act 2008, following an application under the Infrastructure Planning (Changes to, and Revocation of, Development Consent Orders) Regulations 2011. This means changes to an existing Development Consent Order without creating a new consent. The update forms part of the ongoing management of the approved project within the planning framework rather than a fresh consent process.

Why this matters for UK health and safety law and business

Even though the change is described as non-material, it can influence how the project is planned, resourced and governed. The Development Consent Order sets conditions that interact with site safety planning, environmental controls and contractor oversight. Duty holders should ensure that the amendment is reflected in governance arrangements, risk controls and documentation to maintain alignment with UK health and safety law and HSE requirements. Clear governance and up to date records support regulatory compliance and safer delivery of offshore works.

What organisations should do next

Actions you should consider include:

• Establish a formal change control process to capture and interpret the amendment and its implications for project risk and safety planning.
• Review the DCO amendment and refresh health and safety risk assessments, permit to work regimes and control measures where needed.
• Update project governance and procedures to reflect any changed conditions, including contractor and supplier management arrangements.
• Communicate changes to site teams, provide briefings and update training to reflect new requirements.
• Ensure your ISO 45001 aligned health and safety management system remains consistent with the amended consent and related commitments. Consider expert support from ISO 45001 occupational health and safety management.
• Engage a competent adviser for any specialist interpretation if required, using appropriate internal or external resources. See Competent Person support.
• Review contractor and supply chain arrangements to ensure alignment with updated DCO conditions and HSE expectations. See health and safety support packages.
• Monitor enforcement and ensure timely compliance with the amended conditions, updating governance and management system documentation as required.

In practice, organisations should treat the amendment as a trigger to strengthen governance around change, risk assessment and safety management, ensuring robust oversight of offshore construction and operation in line with UK health and safety law and HSE requirements.

What this means in practice for governance and risk management

The amendment requires organisations to align their project governance with the updated consent. This includes reviewing how conditions are implemented on site, updating risk assessments to reflect any revised scope or timing, and ensuring contractor oversight remains rigorous. Maintaining up to date records and ensuring clear communication with workers and suppliers are essential to demonstrate ongoing regulatory compliance and to sustain safe delivery of offshore activities.

Wrap-up: The Norfolk Boreas Amendment No 2 Order represents a carefully scoped adjustment to the approved consent that carries governance and safety planning implications. Addressing the changes promptly supports compliant project delivery and reduces risk to workers and stakeholders.