It is not contentious that Shell neglected to inform HSE about the 1999 PSMR and its findings. In 2006, Shell defended this by stating that the PSMR was just a Review and not an audit. The facts established and accepted by the CPS is that the PSMR was conducted by Auditors, was based on seven offshore audits, the PSMR report was issued by the Internal Audit Manager and was ipso facto an audit. Not to inform HSE and the offshore workers about the results of a health and safety Audit is an offence under Safety Case Regulations. The PSMR produced many recommended actions, these were accepted by Shell Expro, but not effectively implemented. This contributing to the deaths on Brent Bravo and to the chronic weaknesses in essential controls across the oilfield as witnessed in 2003. As previously stated if the full facts had been known by the CPS at the time it is likely that a more general Inquiry would have been held.