HOW ARE WE DOING? INDUSTRY HCR PERFORMANCE
No. of leaks
0
50
100
150
200
250
300
Minor
Significant
Major
Total
2014-15 preliminary data
Agenda 08:30-08:40 Welcome and safety brief
08:40-09:00 Introduction from AISG co-chairs
Alan Chesterman (Apache) / Alan Johnstone (Amec Foster Wheeler)
09:00-09:30 A contextual from the Health and Safety Executive
Rog Thomson (HSE) / Andrew Taylor (DECC)
09:30-10:15 Learning and Sharing Work Group Update and Case Study
Ian Wright (Petrofac) / Hugh Bennett (Amec Foster Wheeler) / Roddy Smith (RGU)
10:15-10:45 Coffee Break
10:45 – 11:30 HCR Improvement and Implementation Work Group Update and Case Study
Andy Ewens (Amec Foster Wheeler) / Alan Blacklaw (Nexen) / Damon Bowler (Shell)
11:30 – 12:15
Major Accident Hazards Understanding Work Group Update and Case Study
Peter Hepburn (Maersk Oil) / Stuart Taylor (Apache) / Stephen O’Neill (Bilfinger Salamis)
12:15 – 12:30 Q&A All
12:30 Closing comments and networking Les Linklater 12:45 Lunch
ALAN CHESTERMAN (APACHE) ALAN JOHNSTONE (AMEC FOSTER WHEELER)
Asset Integrity Steering Group
SPONSORED BY
“Demonstrate that best practice is being identified and spread in an effective and transparent way and on an ongoing basis” “Secure a more strategically coordinated approach for the gathering and dissemination of lessons from incidents and standards of good/best practice within the UK regime and internationally”
Recommendation 4.2 Maitland Report (Dec 2011)
Aims
• promote and support hydrocarbon release (HCR) reduction
• help industry maintain facilities’ integrity and condition in compliance with performance standards
• promote application of best practice and industry learning from past major accidents
HCR Improvement & Implementation • Drive and support company / asset by asset
improvement actions • Identify & share MAH/HCR good practice • Monitor plan execution and performance impact
Learning & Sharing • Better sharing of information • Continuous application of past learning
Asset Integrity Steering Group
Major Accident Hazard Understanding • Pan-industry education in “Major Accident Hazard
management” • Map how everyone plays their part, tailor learning
content to suit
Assurance & Verification • Update the existing guidance in line
with European Safety Directive
* Any learning from other industries? Visit to Sellafield
ANDREW TAYLOR, INSPECTORATE TEAM LEADER, DECC ROG THOMSON, PRINCIPAL INSPECTOR, HSE
Offshore Safety Directive (OSD)
SPONSORED BY
11 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
Setting the Scene
Deepwater Horizon – 20 April 2010 – 11 workers killed. Pollution – 4.9 million barrels
EU Directive 2013/30/EU
• Commission's initial aim was a European Regulation covering offshore oil and gas
operations
• The decision to move away from a Regulation was due, in large part, to the
collaborative efforts of HSE, DECC and Industry
• Directive published 28 June 2013, and objective is to reduce as far as possible the
occurrence of major accidents relating to offshore oil and gas operations and to limit
their consequences
• Directive requires the establishment of a Competent Authority, and in the UK this
will be delivered by OSDR, a regulatory partnership between DECC and HSE
governed by an enhanced MoU
• Scope of Directive is vital to understanding the partnership Competent Authority and
the regulatory regime that has been introduced in the UK to transpose the Directive
12 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
Scope of Directive
Article 2(1) ‘Major Accident’ means, in relation to an installation or connected
infrastructure:
a) an incident involving an explosion, fire, loss of well control, or release of oil gas or dangerous substances
involving, or with significant potential to cause, fatalities or serious personal injury;
b) an incident leading to serious damage to the installation or connected infrastructure involving, or with a
significant potential to cause, fatalities or serious personal injury;
c) any other incident leading to fatalities or serious injury to five or more persons who are on the offshore
installation where the source of danger occurs or who are engaged in an offshore oil and gas operation
in connection with the installation or connected infrastructure; or
d) any major environmental incident resulting from incidents referred to in points (a), (b) and (c).
Article 2(37) ‘Major Environmental Incident’ means an incident which results, or is
likely to result, in significant adverse effects on the environment in accordance with
The Environmental Liability Directive
Scope doesn’t cover all of DECC’s or HSE’s regulatory responsibilities
13 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
Partnership Competent Authority
14 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
HSE Competent Authority DECC
Health and Safety at Work Design / Relocation Notification SEA
Occupational Safety Production Safety Case Environmental Impact
KP4 / Step Change Non-production Safety Case Habitats and Species
COSHH Well Operations Notification Chemical Use and
Discharge
RIDDOR Combined Operation Notification Hydrocarbon Discharge
COMAH Material Change Notification Geological Surveys
(Seismic)
GMO Verification Scheme Marine Licensing
Explosives CMAPP Etc., etc.
Etc., etc. Safety / Environmental
Management
Internal Emergency Response
Navigational Safety
DECC OGED Regulatory Framework
15 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
The Offshore Petroleum Activities (Oil Pollution Prevention &
Control) Regulations 2005 (as amended)
The Mercury Export and Data
(Enforcement) Regulations 2010
REACH Enforcement Regulations 2008
The Offshore Installations (Emergency Pollution Control)
Regulations 2002
The Merchant Shipping (Oil Pollution Preparedness, Response
and Co-operation Convention) Regulations 1998 (as amended) The Environmental Protection (Controls on Ozone–Depleting
Substances) Regulations 2011
The Fluorinated Greenhouse Gases Regulations 2015
The Offshore Chemicals Regulations 2002 (as
amended)
Pollution Prevention & Control Act 1999
The Offshore Combustion Installations (Prevention and
Control of Pollution) Regulations 2013
The Greenhouse Gas Emissions Trading
Scheme Regulations 2012
The Energy Act 2008, Part 4A Works
Detrimental to Navigation
The Offshore Petroleum Activities
(Conservation of Habitats) Regulations 2001
(as amended)
The Marine & Coastal Access Act 2009
The Environmental Assessment of Plans and Programmes
Regulations 2004
The Food and Environmental Protection Act
1985, Part II Deposits in the Sea
The Offshore Petroleum Production and
Pipelines (Assessment of Environmental Effects)
Regulations 1999 (as amended)
The Offshore Marine Conservation (Natural Habitats, &c.)
Regulations 2007 (as amended)
The Energy Savings Opportunity Scheme
Regulations 2014
The Energy Act 2008 (Consequential Modifications) (Offshore
Environmental Protection) Order 2010
7 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
OSPAR EMS
Legislative Changes Main changes to the offshore oil and gas environmental regulatory regime to
implement the Directive requirements are: • New Offshore Petroleum Licensing (Offshore Safety Directive) Regulations 2015; and
• Amendment of the Merchant Shipping (Oil Pollution Preparedness, Response and Co-
Operation Convention) Regulations 1998.
Main changes to the offshore oil and gas safety regulatory regime, to be
discussed by HSE, are: • The introduction of the Offshore Installations (Offshore Safety Directive) (Safety Case etc)
Regulations 2015;
Additional environmental requirements now included in such safety cases: • Assessment of consequence of a major accident
• Safety and Environmental Management Systems and Safety and Environmental Critical
Elements
• Internal Emergency Response Plan (including arrangements for oil pollution)
• Corporate Major Accident Prevention Policy (including environmental protection)
16 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
New OGA Licensing Regulations - Licensing
• Licensing Authority will be the Oil and Gas Authority (OGA)
• Licenses will continue to be granted under the Petroleum Act 1998, but the Directive
introduces new environmental and safety requirements, and the Competent
Authority will have to be consulted
• OGA, via the Competent Authority, will be required to consider:
– Safety and environmental performance of applicant
– Safety and environmental management systems and structure
– Sensitivity of local and adjacent environment, and potential cost of degradation of that
environment
– Where details can’t be provided at application stage, commitments will be checked prior to
commencement of operations, including Financial Responsibility submissions relating to
well operations
17 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
New OGA Licensing Regulations –
Appointment of Operators
• Licensees will be required to appoint operators with respect to any offshore
petroleum operations
• Proposed appointments must detail functions relating to the appointment
• Licensees will be able to appoint installation operators and well operators, for all or
different phases of operations
• Licensing Authority will be required to consult the Competent Authority who will
consider:
– Safety and environmental performance of applicant
– Safety and environmental management systems and structure
– Sensitivity of local and adjacent environment, and potential cost of degradation of that
environment
– Capacity to comply with relevant statutory provisions
18 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
New OGA Licensing Regs - Capacity of Operators
• The Competent Authority will assess the capacity of operators to undertake their
duties, and notify OGA if the performance of the operator is considered
unacceptable
• OGA must notify licensees of the Competent Authority’s determination
• Where licensees are informed of a determination, the operator’s appointment must
be terminated
• Where an operator’s appointment is terminated, the licensee becomes responsible
for carrying out the operator’s functions
• Where an operator’s appointment is terminated, the licensee must propose a new
operator
• Draft guidance on the safety and environmental requirements for licence
applications and the appointment of operators will be circulated to industry around
the end of May 2015
19 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
OPRC 1998 Amendments • The new Safety Case Regulations require an Internal Emergency Response Plan,
which must include arrangements for responding to oil pollution
• The Merchant Shipping (Oil Pollution Preparedness, Response and Co-Operation
Convention) Regulations (the OPRC Regulations) have been amended in relation to
operations in external waters
• Oil Pollution Emergency Plans (OPEPs) remain essentially consistent with previous
guidance, but certain changes have been made and include:
– Requirement for Non-Production Installations to hold an approved OPEP;
– Requirement to include / reference an inventory of response equipment and an assessment of the
effectiveness of oil spill response measures;
– Changes to who is required to hold an OPEP (e.g. well operator, NPI owner, installation duty holder);
– New terminology. Temporary Operations OPEP (TOOPEP) replaces ‘drilling addendum’.
– Concept of a Communication & Interface Plan (CIP) introduced replaces ‘Comms Annex’;
– A 21 day regulatory review period for certain TOOPEPs and CIPs; and
– Amended worst case modelling requirements.
20 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
Other Environmental Controls
• Safety and environmental management should be the responsibility of approved
persons in charge of day to day operations
• Environmental permits etc. will therefore be held by installation and well operators
• Responsibility and accountability for complying with the regulations will fall to
installation and well operators
• OSPAR EMS reporting requirements will also fall to the installation and well
operators
• Liability for environmental and economic damage, and financial security
requirements will remain with licensee(s)
21 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
The OSDR Partnership • The European Offshore Safety Directive took effect on 19th July 2015
• In the UK, the ‘Competent Authority’ required for the regulation of major offshore
hazards is DECC and HSE working in partnership
• The Competent Authority is called the Offshore Safety Directive Regulator (OSDR),
and referred to as ‘the OSDR Partnership’
• OSDR is not a new body, or separate legal entity, but it will have branding and
presence
• The OSDR partnership delivers the government’s commitments made in response
to the legislative consultation
• From a stakeholder perspective, the OSDR organisational arrangements should
provide a single, consistent regulatory interface with the UK oil and gas industry for
major safety and environmental accident hazards covered by the Directive.
22 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
Single Regulatory Interface In practice, building the single, consistent regulatory interface for stakeholders includes:
• Creating a website for information relating to the OSDR partnership and an online portal for all
regulatory notifications and submissions, regardless of whether the submissions relate to
safety or environmental issues
• Developing a new on-line portal, to integrate with OGA licensing system (LARRY), the OGA
and DECC register of installations (DEVUK) and the OGA well consents system (WONS)
• Building a single, coherent set of submission, assessment and acceptance procedures for
safety cases, oil pollution emergency plans and the various other regulatory notifications and
submissions that are required, including major hazard incident reporting.
• Providing a single intervention plan for each owner or operator of offshore installations covering
all planned OSDR interventions, with the presumption of joint DECC / HSE visits where
appropriate
• Coordinated investigations, with decisions made at an early stage as to which regulatory
partner should lead, with aligned principles of enforcement covering safety and environment
23 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
OSDR Governance • OSDR is established through an enhanced Memorandum of Understanding,
supported by an Articles of Governance & Management document.
• OSDR has a single, high level strategy on prevention and control of major accident
hazards, which brings together existing DECC\HSE strategies.
• OSDR is governed by a joint DECC / HSE Senior Oversight Board (SOB)
• OSDR operations are managed by a joint DECC / HSE Operational Management
Team (OMT)
• Operational management arrangements are described in a range of publicly
available OSDR business process frameworks and supporting documents that
detail the competent authority functions (already online).
24 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
Safety Case Regulations 2015 • SCR2015 replaces SCR2005 in relation to external waters, to provide for the
preparation of safety cases to meet the Directive requirements
• All installations operators have received letters stating when to submit a revised
safety case for assessment under the new 2015 Safety Case Regulations. The
main changes are inclusion of:
– CMAPP – Corporate Major Accident Prevention Policy
– SEMS – Safety and Environmental Management System description
– IERP – Internal Emergency Response Plan (PFEER+OPEP) descriptions
– SECEs – Safety and Environmental Critical Elements descriptions
– Environmental Information, & consequence assessment of a major environmental incident.
– Well Examination Scheme & Verification Scheme descriptions
• First transitional cases submitted April 2015. Coming in at roughly 10 per month for
the next three years. Jointly assessed by DECC and HSE
25 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
Major Accidents & Environmental Incidents
Major Accident
• An event causing, or with significant potential to cause death or serious injury
arising from fire, explosion, loss of well control or release of dangerous substance,
major damage to installation structure, plant, loss of stability.
• Any other event arising from a work activity involving death or serious injury to five
or more persons
• Failure of life support systems for diving operations in connection with an
installation, detachment of diving bell, trapping of a diver in a bell or subsea
chamber
• Any major environmental incident resulting from any of the above
Major Environmental Incident
• An incident that results in, or is likely to result in significant adverse effects on the
environment in accordance with the Environmental Liability Directive
26 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
New Reporting Requirements - Dutyholders
• The new EU Implementing Regulation affects incident reporting. It expands what
was already required in UK law and makes compulsory, some of what was in the
voluntary hydrocarbon release reporting scheme. Duty holders must report:
– All major accidents, or situations where there is an immediate risk of a major accident
– When suitable measures are taken to address a significantly increased risk of a major
accident
– On request, when a licensee or operator that is a UK registered company with operations
outside the EU, details of any major accidents they, or their subsidiaries, have been
involved in outside the EU.
• The EU Implementing Regulation reporting requirements take effect when
installations transition to the 2015 Safety Case Regime:
• HSE and DECC are working to integrate all offshore incident reporting into a single
tool for installation owners and operators to use from January 2016
27 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
PON
2
PON
10
New Reporting Requirements - Dutyholders
• Ministers approved a policy decision not to alter or remove RIDDOR. We will
therefore have overlapping health, safety and environmental reporting regimes.
28 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
PON
1
RIDDOR OIR
12
EU
Implementing
Regulation
DCR MAR
• One single reporting tool to
cover all the reporting
requirements.
• Report of an Oil and Gas
Incident (ROGI)
• Available now for
transitioned installations
• Whole industry to use from
Jan 2016
• Final version web-based
• There are new requirements surrounding what Member States must report to the
European Commission
– This involves the type and number of major accidents, and normalised data on reported
incidents.
– The purpose is to share information across Member States to learn lessons and prevent
recurrence.
– First reporting year is January to December 2016
• OSDR must make similar information available to the public, including summary
information on major accident investigations.
• Similarities to information that could be released under freedom of information
requests.
29 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
New Reporting Requirements – to EU & Public
Further Information • DECC and HSE have jointly provided a series of industry briefings
• Advice is available to companies from DECC and HSE focal-point inspectors
• Information is available online at:
The Offshore Directive website
http://www.hse.gov.uk/offshore/directive.htm
The OSDR website
www.hse.gov.uk/osdr
30 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015
HUGH BENNETT (AMEC FOSTER WHEELER) IAN WRIGHT (PETROFAC) RODDY SMITH (RGU)
Sharing and Learning
SPONSORED BY
“prior to any disaster there will nearly always be information somewhere within an organisation that trouble is brewing....critical information must not be allowed to lie around unrecognised, ignored or buried like some landmine waiting to be triggered. The challenge is to find ways to assemble this information and move it up the hierarchy to the point where it can be understood and reacted on responsibly.”
Andrew Hopkins (Lessons from Longford)
Improvements in the learning culture and processes for spreading best practice
Where incidents are potentially high in impact but occur very infrequently, it
is particularly important to extract and promulgate, quickly and
comprehensively, valuable learning to prevent a recurrence with more severe
consequences.
Sharing learning from previous incidents and events is also vitally important.
Thorough post-event analysis enables identification of lessons which, if
widely implemented, can prevent recurrence elsewhere. In a major hazard
industry such lessons should not be proprietary to any one organisation;
they must be shared for the safety of all and for the protection of the
environment.
Geoffrey Maitland (FREng), Professor of Energy Engineering, Imperial College London
There are no new incidents!
We can learn without having to experiencing incidents if we ask others and share our own
• Pose a problem
• Ask others
• Create curiosity
• Tell stories and share experience
• Be surprised what you learn!
SAFETY ALERT
Improved! Continues!
JUT Videos
New!
SAFETY MOMENT
LESSON SHARED
• Basic level of Information sharing
• Ideally short, relevant and valuable
• “It happened to us, check its not going to happen to you!”
What hazards are there? What could go wrong? What might be the consequences?
Reciprocating gas compressor with small bore tubing for instrument connections.
DISCUSS
Small bore tubing failure
Following maintenance work, a helically coiled tubing was re-instated upside down. The tubing was left with a pre-load stress and tool marks suggesting it was re-fitted using force.
Vibration from the compressor led to fatigue cracks emanating from the tool marks.
Full through thickness failure occurred. An estimated 1.67 Tonnes of gas was released over 83 min. Due to the open module configuration the gas was not detected by fixed detectors and the leak was manually detected by a routine inspection.
No ignition occurred.
Fatigue failure of instrument tubing following reinstatement of an incorrect orientation using incorrect fitting practices
Small bore tubing failure
What behaviours and steps could prevent this from occurring?
What might you do differently today in your work?
Small bore tubing failure
DISCUSS
Help and advice It is important that people are aware of causes of previous failures which could re-occur. Competence and knowing your limitations is essential when dealing with hazardous equipment. You will get more respect from people if you ask for their help when you are unsure. Making yourself open to help encourages others to ask, and helps protect us all. Useful resources: Joined-up Thinking training packages – Competency Mechanical joint integrity – Route to competence
Small bore tubing failure
Which of the 7Cs are involved in this safety alert?
• Change management
• Communication
• Complacency
• Control of work
• Competence
• Culture
• Commitment
Did this presentation result in discussion that could lead to creating another alert to share with industry? Please contact: [email protected]
Small bore tubing failure
What hazards are there? What could go wrong? What might be the consequences?
Reciprocating gas compressor with small bore tubing for instrument connections.
DISCUSS
Small bore tubing failure
Following maintenance work, a helically coiled tubing was re-instated upside down. The tubing was left with a pre-load stress and tool marks suggesting it was re-fitted using force.
Vibration from the compressor led to fatigue cracks emanating from the tool marks.
Full through thickness failure occurred. An estimated 1.67 Tonnes of gas was released over 83 min. Due to the open module configuration the gas was not detected by fixed detectors and the leak was manually detected by a routine inspection.
No ignition occurred.
Fatigue failure of instrument tubing following reinstatement of an incorrect orientation using incorrect fitting practices
Small bore tubing failure
What behaviours and steps could prevent this from occurring?
What might you do differently today in your work?
Small bore tubing failure
DISCUSS
Help and advice It is important that people are aware of causes of previous failures which could re-occur. Competence and knowing your limitations is essential when dealing with hazardous equipment. You will get more respect from people if you ask for their help when you are unsure. Making yourself open to help encourages others to ask, and helps protect us all. Useful resources: Joined-up Thinking training packages – Competency Mechanical joint integrity – Route to competence
Small bore tubing failure
Mechanical Joint Integrity – Route to Competence Guidance
or effectively:
Training and competence guidance for all personnel involved making and breaking hydrocarbon joints
This guidance reflects current industry practice guidance as well as a definition of minimum standards of competency for working on mechanical joints. It has been developed by a working group including members from industry and standard setting bodies. The guidance sets out a structured approach to the principles of managing competence for those involved in mechanical joint operations. It describes how to train, develop and assure competence, reducing the risk of personal injury and hydrocarbon and non-hydrocarbon release when working with mechanical joint related activities such as construction, maintenance and disassembly operations. Summary: The guidance sets out a structured approach to the principles of managing competence for those involved in mechanical joint operations.
ALAN BLACKLAW (NEXEN) ANDY EWENS (AMEC FOSTER WHEELER) DAMON BOWLER (SHELL)
HCR Improvement & Implementation
SPONSORED BY
7 Key Themes:
Performance
Operational activities
Investigation
Competence Integrity
management
Communication
Human factors
1. Performance Best in Class
Nexen – FLIR camera
Areas for Improvement
Common classification of weeps/seeps o Clarify language/definitions around fugitive
emissions, weeps, seeps, leaks etc o Common thresholds allow formal recognition
of smaller HCRs, and therefore consistent management
Sharing of KPIs o KPIs and dashboards are widely used, but
KPIs are specific to each organisation o Much re-invention of KPIs exists o Cross-industry reporting is impacted by
differences in KPI definitions o Propose a ‘dictionary’ of KPIs with agreed
definitions, and pros and cons of application o Reduces invention phase, and better
supports cross-industry reporting
2. Operational Activities Best in Class
Apache – Operational Risk Assessments Comprehensive (ORA) process in place o Remedial action plan assigned to each
ORA o Technicians sign-off on safety critical
ORA’s within 48 hr of arriving on platform
o Daily control checks part of morning calls/reports
o Overview of Safety Critical ORAs provided at heli-brief for new crew
Areas for Improvement
Start-up assurance Shell and WGPSN identified as BIC: Robust start-up assurance process in place for an asset which had been shut down for a considerable time There is an opportunity to develop industry wide guidance on what start-up assurance should consider.
3. Communication Best in Class
Chevron – internal safety alerts o Two-tier alert system in place
o Immediate single page alerts issued
o Incident bulletins include formal actions
o Actions tracked in the Corporate
Incident Management System
o Learning is formalised
Areas for Improvement
Post Incident Feedback and Learning o Too often comms breaks down at
onshore / offshore interface
o Pace & efficiency of learnings - low Procedures o Effective design of procedures
o Efficient roll out of procedures
4. Investigation Best in Class
Shell – Investigation & Action Management o Cross-discipline Incident Review Panels
(IRPs) used to ensure sharing of learnings, challenge actions to ensure they are robust and SMART
o Resulting actions managed within corporate assurance tool
o Incident Investigation Tool recently developed to include human factors considerations
Areas for Improvement
Cross Industry Learning Learning from events: SADIE review and learning isn’t in the DNA WHY? Learning from best practices: Now integral to AISG work groups Events like this one…..more of them!
5. Competence Best in Class
Wood Group PSN – 3rd party contractor competencies o Compliance with WGPSN base level
discipline competence, where applicable
o Provision of demonstrable evidence to assure competence prior to approval to mobilise
o Individual assigned a buddy for initial site visit as a minimum, to restrict lone working
o Quality assurance audit/check on provider prior to inclusion on supplier list
Areas for Improvement
3rd party competence o Establish minimum levels of
“understanding” for all offshore personnel
o Greater awareness of potential impact across all trades
• Eg –impact to scaffolding on LoS gas detectors
o Better use of industry leading training • Bespoke SBT course • Spadeadam
o Overreliance on 3rd Party competency management processes.
6. Human Factors Best in Class
Chevron o Documented HF processes, supported
by internal expertise. o HF is part of all incident investigations
and is formalised within investigation handbook.
o Standardised re-write of SOPs for key equipment, with HF focus.
o Cultural programme to be rolled-out offshore from Jan 2016.
o HF & coaching are competence driven. o Fatigue modelling & overtime impact
assessments conducted with support from Keil Centre.
Areas for Improvement
Simplification and embedding
7. Integrity Management Best in Class
Apache – Anomaly Management o Integrated anomaly management across
assets within a single application
o Simple, logical, anomaly creation workflow
o Complete access to all anomaly data within a centralised application
Areas for Improvement
Adopting / designing technology There is a lot more to integrity than pipes and vessels – where are the technology advances?
7. Integrity Management Best in Class
BG Group – Small bore tubing o Training encapsulates SBT, flexible hose
assemblies and flange management.
o 2 tiered approach for SBT; • Tier 1 creating new pipework with
a focus on experienced practitioners,
• Tier 2 for dismantling and reassembly focused more on people with little knowledge or infrequent use of skills.
o SBT joints are captured using GOC,
treated and managed like flanges.
Areas for Improvement
Doing the basics right: o Flange / joint management
o Small bore tubing
o Flexible hose assemblies
What’s Next? Q4 2015
• 4 more operator assessments
• Develop assessment for tier 1 & 2 contractors
• Extend the assessment offer to drilling companies
• Working group sustainability
2016 • Continue assessments of Ops Co.'s + tier 1 & 2 contractors
• Extend further through the supply chain
• Publish best practice documents
The assessment
• Assessment undertaken 2nd June 2015 (pilot)
• Step Change assessors – Alan Blacklaw ( ) & Andy King ( )
• Facility approach rather than by themes – 7 facilities (10 onshore & offshore installations)
• 1 hour assessment for each facility on a subset of the 7 key themes
• Wide cross-section of people interviewed – Asset Managers, Facility Managers (OM’s), OIM’s,
Operations Leads, Maintenance Leads
What the assessors found Strengths
• Open and comprehensive reporting culture
• Facility-focused organisation (facility Hydrocarbon Release Prevention plans)
• Robust incident investigation process
• Comprehensive Authorised Persons Register
• Facility Risk Review to manage high risk threats
• FLIR cameras in routine inspections
• ‘Goal Zero’ ambition (no harm, no leaks)
• Leadership commitment (to bring about performance improvement)
• Human Factors Incident Investigation Tool
Opportunities
• Standardised reporting (to remove confusion)
• Re-energise some facility Hydrocarbon Release Prevention plans
• Better use of cross-asset learnings
• Make more of Major Accident Hazards awareness offerings
• Consolidated approach to leak detection technologies
• Make HCR prevention message clearer at the working level
• Bring process safety into Mind Safety
• De-mystify human factors into tangible activities
What did Shell get out of it?
Need to set some context first…
Shell was receptive to getting something out of it
• Shell’s HCR performance was improving – but not quick enough compared to its peers
• Relative stagnation in performance a revelation and fostered a strong desire to look at how others do things
• Willingness to have an external perspective to hold the ‘mirror held up’
• New facility-focused organisation provided new opportunities for improvement
• HCR data well understood and a prevention plan in place – in the process of being reviewed in the light of the new organisation
How Shell has benefited
• Direct benefits of being assessed – Comprehensive, on-the-day feedback across the spectrum of key HCR
vulnerabilities (the 7 key themes)
• Shell currently reviewing its plans to incorporate key opportunities from the assessment
e.g. clarifying the prevention message, making human factors more tangible
• Indirect benefits of assessing others – Unique insight into Best-in-Class practices (learning opportunities)
• MAH Tool (management visit arranged)
• Small-Bore Tubing management
• approach to Operational Risk Assessments
STUART TAYLOR (APACHE) PETER HEPBURN (MAERSK OIL) STEPHEN O’NEILL (BILFINGER SALAMIS)
Major Accident Hazard Understanding
SPONSORED BY
Purpose:
• To develop a step change in the understanding of Major Accident Hazard Management across all onshore and offshore organisations working in the UKCS.
• To give everyone in the industry a clear line of sight between their role and prevention of a Major Accident.
• To develop a more informed workforce.
Major Accident Hazard Understanding
• Peter Hepburn Maersk Oil (Co-chair)
• Stuart Taylor Apache (Co-chair)
• Fiona Fitzgerald DNV GL
• Melanie Taylor HSE
• Imogen Hutchcroft Apache
• Tony O’Shea WG Kenny
• Mark Stagg Sea Energy
• Iain Wright Total
• Glen Sheppard Nexen
• Alasdair Smith Oceaneering
• Mark Anderson Amec Foster Wheeler
MAH Understanding workgroup
• A reduction in hydrocarbon releases
• Improved workforce engagement and understanding of MAH & MAH barriers
• Improved asset integrity and reliability
• Promotion of a MAH management culture
• Provision of an industry-agreed minimum scope & learning outcomes for MAH understanding
The aim is to prevent major accidents by:
• Define “the entire workforce” into populations
• Define MAH management and publish a common language/framework
• Identify each population’s learning needs and objectives
• Produce a MAH understanding Gap Analysis tool for self-assessment with an accompanying guide for use
• Produce a roadmap to resources for each group so gaps can be closed
• Identify OSD opportunities
Objectives
OIM
Technicians
& Operatives
All
MD
Senior
Leadership
Managers
Engineering
Supply Chain
HR MIST 2 (Complete)
Technician Training
Frontline Supervisor Training
Managers Training
Leadership Training
Frontline
Supervisor
Population Framework
HSE
The offshore and onshore populations
Process Safety Management – AICE: A management system that is focused on prevention of,
preparedness for, mitigation of, response to, and restoration from a major accident hazard.
– HSE from HG254: The term ‘process safety management system’ is used to describe those parts of an organisation’s management system intended to prevent major incidents arising out of the production, storage and handling of dangerous substances.
– Layman’s terms: Process safety management is about how we manage the risk associated with major accident hazards. Can also be referred to as Major Accident Hazard Management.
Common language/framework guide
Prevention of a MAH is not just offshores responsibility –
procurement / logistics / HR etc. all have a part to play
Everyone has a part to play – MIST 2 (light)
Learning Outcome Main Categories
• Major Accident Hazards • Barrier Management
• Major Environmental Incidents • Hazard and risk Identification
• Safety and Environmental Critical Elements • Risk Assessment
• Safety and Environmental Critical Elements, maintenance, verification and assurance
• Impact of Behaviours on Major Accident Hazards
• Safety Case • Communications
• Major Accident Hazard Management • The 'So What?'
Item Objective Context Suggested Training
Activities
Major Environmental Incidents
Define a major environmental incident
Use HSE definition and Step Change terms to give clear understanding of what a Major environmental Incident is and how it relates to a MAH
Consider Major Environmental Incident examples and a case studies
Learning outcomes
Roadmap to resources
Understanding Bow ties
Item Objective Context Suggested Training Activities
Major Accident Hazards
Define a Major Accident Hazard
Use HSE definition and Step Change terms to give clear understanding of what a Major Accident Hazards is
Consider using examples of Major Accident Hazards on your site and also industry examples (Texas City, Deepwater Horizon etc.)
Describe Major Accident Hazard identification process
Provides an understanding of how Major Accident Hazards were identified through HAZID based on the scenarios that have the potential to cause a major accident
Consider Major Accident Hazard examples and case studies
• Learning Outcomes developed for senior managers
• Lunch and Learn sessions to be arranged throughout 2016
• Included in the HCR Improvement and Implementation questionnaire
• At be discussed at Operator and Contractor forums
• Link to HSE strategic plans
Senior Management engagement
Timeline
Action By when
Technician gap analysis tool (Pilot) Today
Roll out and promote implementation Oct ->
Supervisor gap analysis tool Nov 15
Leadership breakfast roll out Nov 15
Manager gap analysis tool Dec 15
Develop resources roadmap and identify resources Dec 15
Senior Management lunch and learn sessions 1Q 2016 ->
Monitor uptake through the Improvement & Implementation group 2016
Introduce to EITB and O&G academy for input into their syllabus 2016
Leaders should: • Educate themselves to become better
informed • Be advocates for better MAH
management through education of the workforce
• Ask probing MAH question of others • Challenge each other • Defend the line
How do we develop a better MAH management culture?
Everybody needs to play their part
Major Accident Hazard Management:
A Contactor‘s Perspective Stephen O‘Neil HSEQ Manager | Step Change
Bilfinger Salamis
October 2015
The traditional management of MAHs
▪ Safety Case
▪ Operators
▪ Duty Holder
▪ Regulators
▪ Contractors?
Bilfinger Salamis UK Ltd page 95
Image obtained from google. Undefined
source
Bilfinger Salamis a major provider of support services
▪ Scaffolders
▪ Rope Access Technicians
▪ Painters
▪ Blasters
▪ Insulators
▪ Specialist cleaning
▪ Inspection services
▪ Architectural outfitters
▪ Deck/Helideck operators
▪ Asbestos removal
page 96 Bilfinger Salamis UK Ltd
Bilfinger Salamis cont’d
▪ 2000 personnel on 70 client
assets
▪ Work in places often outwith
normal access
page 97 Bilfinger Salamis UK Ltd
Contractors influence on Process Safety issues
page 98
Contractors’ negative impact
Contractors' positive
influence
Process safety awareness
Protection of safety critical equipment
Joined up approached
Prompt reporting
Bilfinger Salamis UK Ltd
Bilfinger Salamis’ approach
▪ Process Safety is everyone’s
responsibility
▪ Bilfinger Salamis working to make
all trades aware of Process Safety
issues
▪ Everyone can keep the assets and
personnel safe
page 99 Bilfinger Salamis UK Ltd
Process Safety Awareness – keeping it simple
Bilfinger Salamis UK Ltd page 100
We should all be familiar with this as it is drilled into us
• Do not turn of lights
• Open windows and door
• Get out
• Call emergency number etc
Proving awareness and a reporting mechanism
page 101
Process Safety Cards
provided to every
operative
Training package being
developed
Process Safety
Handbook
Bilfinger Salamis UK Ltd
Process Safety pocket form and e-form
Bilfinger Salamis UK Ltd.
Process Leak
Unusual Noise
Unusual Smell
Surface Corrosion
Damage Insulation
Damage Fireproofing
Damage/Missing
support
Structural Failure
Missing Faulty Bolts
Damage Joint Face
Failed Paint system
Corroded
Bolts
Impact Damage
Unapproved
Modification
Collapsed
Cover/surface/structure
Other
page 102
Reporting mechanism
Bilfinger Salamis UK Ltd.
1) Operative finds an issue
2) Reports immediately for serious finding in accordance
with clients procedure
3) Fills in paper Process Safety Card
4) Arranged for card to be electronically logged on platform
via Act Safety SharePoint portal
5) Onshore gets automatic notification. Client notification if
required
6) Data collation and trending
7) Lessons learned/ shared
page 103
Case Study 1: Process Safety intervention
May 2015 - Bilfinger Salamis :
• Bilfinger Salamis’ scaffolders working on bridge between the accommodation
and compression jacket
• Smell gas and reported
• Work stopped
• Lines purged and depressurized
• Crack found at the connection between 2 ‘’ and 16 ‘’ line
• Potentially serious incident averted
page 104 Bilfinger Salamis UK Ltd
Case Study 2: Process Safety intervention
2014 Bilfinger Salamis:
• Rope Access Team working fabric maintenance campaign on live asset
• While working, discovered a hole in pipework which they reported
• Live condensate line
• Praised by client for intervention and process safety award given by Bilfinger
Salamis
page 105 Bilfinger Salamis UK Ltd
Bilfinger Salamis
• 2000 noses to smell
• 2000 mouths to taste
• 4000 eyes to see
• 4000 ears to hear
Provided with the knowledge, awareness and a
reporting culture, contractors are a powerful additional
resource in process safety and MAH management.
page 106
Contractors have a role to play in MAH
management
Bilfinger Salamis UK Ltd.
Summary and closing comments
• The purpose, structure and direction of travel have been overhauled to better serve the industry in the management of MAH
• Workgroups staffed by experts and committed people have delivered excellent work
• The challenge of moving forward is for industry to make use of the work to better manage MAH
What you can expect from us • HCR Improvement:
– Keep the peer assists going and promote transfer of learning between companies
– Identify areas that industry struggles and act on them
– Track how company HCR plans are working and offer support
• Learning and Sharing: – Continue work on website, roll out new learning and sharing process
– Take learning info, turn it into a form that’s easy for industry to use
• MAH Understanding and Education – Finish defining MAH learning needs for the entire workforce, roll out to industry
– Hold seminars on MAH understanding and education with key leaders
– Follow up longer term education opportunities e.g. technician MAH training
• Look at nuclear industry to ensure we’re not missing something
What we ask of industry • Get involved in the HCR peer assessments
• Share how your HCR plans are working, what’s working well and your improvement areas
• Use the new learning format & info and hold engaging conversations at all levels to learn lessons by asking questions
• Share your lessons with Step Change in the new format
• Use the MAH learning needs to look at the depth of MAH understanding in your organisation
• Take action to get everyone involved and playing their part