Meeting the obligations of the new offshore safety regulations with your people

Lloyd’s Register: Human Engineering Limited

Meeting the obligations of the new offshore safety regulations with your peopleW Ian Hamilton & Michael Suerth

IMARESTHouston4th May 2011


Overview

• Introducing Lloyd’s Register• The importance of skilled behaviour in offshore

operations• Stricter regulatory control• Improved asset design• Meeting the demand for control of human error• Meeting the demand for competence assurance• A framework for organisational integrity


Introduction to Lloyd’s Register

• Global provider of advisory, technical

& assurance solutions

• Enhance clients’ quality, safety,

environmental & business

performance

• Origins dating back to 1760

• Employs approx 8000 staff, drawn

from over 90 nationalities

• 240 offices

• 80 countries


Introduction

• Human Engineering is the human factors and ergonomics consultancy of Lloyd’s Register.

• Our customers operate complex asset intensive, systems.

• We provide services in:

• Physical ergonomics,

• Cognitive ergonomics,

• Sociotechnical systems analysis.

• Includes design and safety assurance

http://images.google.co.uk/imgres?imgurl=http://www.laboratoryerrors.org/images2/HomePic.jpg&imgrefurl=http://www.laboratoryerrors.org/&h=472&w=437&sz=79&hl=en&start=26&tbnid=r8F9l0YBimUfMM:&tbnh=129&tbnw=119&prev=/images?q=patient+safety&start=18&gbv=2&ndsp=18&hl=en&sa=N


Assets are sociotechnical systems

The Sociotechnical Approach

A system comprises property, processes and people, and the interactions between these three components.

PropertyTechnologyEquipment

PeopleRoles &

responsibilitiesLeadership

CompetenceCulture

ProcessesProcedures

Risk assessmentCommunications

The interactions between:

• People and people,

• People and property, and

• People and processes

Are crucial to the success of the asset.


Weak Organisational Integrity multiplies risk

• Between 70% and 90% of failures are attributable to human and organisational failure

Human & Organisational failures Technical

failures

Human & Organisational

failures

Technical failures


The ND SpaceO

ptim

isin

gF

rag

ileF

ailu

re

De

via

tion

Normalisation

Real Men Don’t Use Procedures!


Organisational drift - consequences

• Technical standards and procedures are missing or inappropriate

• Competence and understanding are insufficient

• Commitment to technical integrity is lost

• Safety management processes degrade

• Supervisory decision making is weak

• Inability to detect and respond to potential failures


REGULATORY CONTROL


DOI 30 day review recommendations

II.B. Recommendation 4 &

III.A. Recommendation 1• Increased emphasis on training and

competence

III.B. Recommendation 2• Enhanced requirements for

organisational and safety management

III.C. Recommendation 3• Increased focus on personal

accountability and the control of human error


Pull through to legislation

• Performance based safety case regime

• Safety and environmental responsibility placed with the lessee

Ensure that all personnel involved in well operations are properly trained and capable ofperforming their tasks under both normal drilling and emergency well control operations.

30 CR 250 and NTL 2010-N05

IADC’s Health and safety and Environmental case guidelines... will help operators and drilling contractors demonstrate their ability to operate safely and handle the risks associated with drilling on the OCS.

DOI safety measures report, 27 May 2010


Implications for people and organisations

• Organisation: There should be clearly defined roles and responsibilities, particularly for decision-making and major accident hazard safety management.

• Competence: People should be comprehensively trained and capable.

• Processes: Procedures should be fit for purpose and practical.

• Usability: Facilities, technology and equipment should be fit for purpose and usable.

• Error: The risk of human error should be controlled.


Safety & Environmental Management Systems

• Compliance deadline for mandatory BOEMRE regulation, 15 November 2011

• Focus attention on the influences that human error and poor organization have on accidents

• API RP 75 (1998)• 13 elements: to enhance the safety and

cleanliness of operations by reducing the frequency and severity of accidents

worker safety and pollution control are largely dependent on proper human behaviorAPI RP 75 (1998)


SEMS 13 elementsGeneral Management Program

Principles

Safety and Environmental Information

Hazards Analysis

Management of Change

Operating Procedures

Safe Work Practices

Training

Quality Assurance/Mechanical Integrity

Pre-Startup Review

Emergency Response and Control

Incident Investigation

SEMS Element Audit

Documentation and Recordkeeping


Applicable Phases

SEMS applies to all OCS oil and gas operations on new and existing facilities under BOEMRE jurisdiction including• Design• Construction• Start-up• Operation• Inspection• Maintenance


Job Safety Analysis

Prepare JSA for all OCS activities identified in your SEMS

Must include:• Job steps • Existing or potential hazards • Mitigation

Generate task analysis from procedure / observation.

Identify the consequences of failure at a sub

task level.

Are these consequences

safety critical? i.e. Could they

contribute to a MAH

Identify the likelihood of a

failure of this sub task occurring (from Table 3)

Identify the human failures which

would cause this (from Table 2)

Identify the performance

influencing factors that could contribute

(from Table 4)

Identify any current

processes / mechanisms

which reduce risk of failure or enable

recovery.

Identify any future measures to reduce risk of

failure or improve recovery.

Task step / task description.

Potential consequences of task

failure

Likelihood of failure occurring.

Possible human failures.

Performance influencing factors.

Existing Risk Management

Measures

Potential to recover from failure before

consequences occur.

Additional Risk Management

Measures

Additional measures to improve recovery

NO – consider next step in the task analysis

YES – proceed to Step 3

Submit procedure to Procedure Screening Matrix. Is procedure

considered safety critical?

NO – consider next site procedure


Step 1

Site Procedure Screening

Step 2

Safety Critical Task Identification

Step 3

Human Failure Analysis


Audit requirements

• 2 years after initial implementation• Then every 3 years• Comprehensive audit of 13 elements• Designated and Qualified Personnel (DEP)• 30 day audit plan, API RP 75 section 12.1 thru 12.4• Deficiencies addressed in Corrective Action Plan (CAP)• Non-compliance can result in sanctions up to and including

disqualification as an OCS operator


ASSET DESIGN


Objectives for Human Factors Integration

To define a feasible role for people• HFI helps to specify the role for people, the manpower requirements, job design and training plans.

To specify usable interfaces and equipment• HFI helps to define requirements for the usability of workspaces, equipment and control system interfaces and to support their verification during construction leading to lean commissioning and sustainable performance.

To ensure the reliability of human performance• HFI helps to assess the human error potential within the system, its processes and procedures, and to identify workplace hazards for personnel; and so to meet the human factors requirements for regulatory compliance as well as providing operational assurance.


HFI goals for project phases

System lifecycle or maturity stages

HFI goals

All phases Primary goal for HFI: The optimisation of skilled behaviour.

Concept definition

Feasibility engineering

Main goal 1: To define a feasible role for people.

Preliminary engineering

Detailed engineering

Main goal 2: To specify usable interfaces to workspaces, equipment and technology.

Manufacture/fabrication

Commissioning

Operation

Main goal 3: To assure the reliability of human performance.


HFI Objectives for project phases

OperationManuf./CommissionPrelim/detailed designConcept/feasibility

Feas

ibilit

y

Usa

bilit

y

Reliabilit

y

• Is the role of people in the system feasible?

• Are the human-machine interfaces usable?

• Will the required level of human performance be sustainable?

• Will the organisation support the business objectives for the system?

Key questions:


HFI questions related to main goalsHFI goals Key questions

To define a feasible role for people. Is there a concept of operations for the role to be performed by people?Has the target workforce been defined?How many people are needed?What will be their jobs?What are the knowledge and skill requirements?Is there a training plan?How will competence be assured?Stopping rule: The human role is shown to be practicable

To specify usable interfaces to workspaces, equipment and technology.

Are reference anthropometric data available?What are the requirements for facilities and workspaces?Are the requirements for physical interfaces defined?Is the user population defined?Are the requirements for HCI defined?Is there a plan for testing and acceptance by users? Stopping rule: The facilities and interfaces are fit for purpose.

To assure the reliability of human performance.

Have occupational hazards been identified?Is there a risk control plan for hazards?Have all safety critical tasks been identified?Have the opportunities for human error in critical tasks been identified?Has the risk from human error been controlled?Have the requirements for a safety culture been defined?Stopping rule: The risks from human error and health hazards are ALARP.


CONTROLLING ERROR


Control of human error – the wider view

• DOI Safety measures report...

... unsafe offshore drilling operations often result from human errorIII.C. Recommendation 3.

Management and leadership

Communications

Procedures

Knowledge and skills

Fatigue and workload

Usability of

equipment


Safety Critical Task Review Method

Generate task analysis from procedure / observation.

Identify the consequences of failure at a sub

task level.

Are these consequences

safety critical? i.e. Could they

contribute to a MAH

Identify the likelihood of a

failure of this sub task occurring (from Table 3)

Identify the human failures which

would cause this (from Table 2)

Identify the performance

influencing factors that could contribute

(from Table 4)

Identify any current

processes / mechanisms

which reduce risk of failure or enable

recovery.

Identify any future measures to reduce risk of

failure or improve recovery.

Task step / task description.

Potential consequences of task

failure

Likelihood of failure occurring.

Possible human failures.

Performance influencing factors.

Existing Risk Management

Measures

Potential to recover from failure before

consequences occur.

Additional Risk Management

Measures

Additional measures to improve recovery

NO – consider next step in the task analysis


Submit procedure to Procedure Screening Matrix. Is procedure

considered safety critical?

NO – consider next site procedure


Step 1

Site Procedure Screening

Step 2

Safety Critical Task Identification

Step 3

Human Failure Analysis


MANAGING COMPETENCE


Trained isn’t necessarily competent

Competence must be measured independently of training...

Job Analysis

Define Competencies

Ability Assessment

Competence Assessment

Knowledge Assessment

Behavioural Assessment

Develop assessment methods that assess each critical

competency

Decompose role in to the competencies required to be

successful in the role

Identify the most critical competencies


The assessments

Technical Knowledge 1, 2 and 3

Mechanical Comprehension

Following Procedures

Fault Diagnosis

Management Assessment

Assessment Interview

Work Shadowing/ tours of equipment


Knowledge assessments


Ability assessment


Ability assessments = normalisation


Behaviourally anchored competencies


ORGANISATIONAL MANAGEMENT


Organisational integrity – bringing it all together

Circle

Of

Integrity

Critical Tasks

Leadership

Policy & Procedures

Workforce Organisation

Ensure competence

Usable technology & equipment

2-way Communic-

ations

Learning & Improving

Change Management

Leadership

Commitment,

Decision-

Making, trust

And common

values

Define

Practicable

Practices and

COW

procedures

Optimise

Manpower

And

Responsibilities

For safety and

performance

Tasks critical

To the

Strategic aims

Of the

Enterprise

Manage the

Changes

To systems

And

processes

Just

Attitude to

Blame and

Learning

culture

Build

Effective

2-way

Communic-

ations

Define

training

Needs and

Standards of

competence

Provide facilities,

equipment &

technology

that is fit

for purpose


Measuring Organisational Integrity

Critical Task

Equipment Design

Process & Procedure

Leadership

Recruitment

Training

Manpower

Fatigue

Incident Investigation

Change Management

0%

50%

100%

Factor Performance

Dimension Performance % Approach %

Implementation % Outcome %

Review %

Crtical Task

Leadership and Job Design

Processes and Procedures

Ensure Competence

Workload Management

Communications

Learning & Improving

Management of Change

0%

20%

40%

60%

80%

100%

Organisational Integrity Dimension Performance


Summary

• New safety regulations demand an increased focus on:• Organisational processes and safety culture• The control of human error• The assurance of competence for key workers

• Human factors integration can deliver improved asset design• Organisational integrity offers a framework for the improved

management of human factors in offshore operations.• It is a data-based assessment process• Supports error assessment for safety critical tasks• Supports competence assessment for key roles• Improves organisational safety management

Services are provided by members of the Lloyd's Register Group. For further information visit www.lr.org/entities

For more information, please contact:

W Ian Hamilton & Michael SuerthLloyd’s Register Americas

1505 Hwy 6 South Suite 250HoustonTX 77077USA

T +1 281 649 2237E [email protected] or [email protected] www.humaneng.co.uk

http://www.lr.org/entities

mailto:[email protected]


http://www.lr.org/marine
