SAFETY MANAGEMENT CHANGING IN U.K. NORTH SEA

Safety management is changing in the U.K. North Sea. The basis for safe operations once was a sector-wide set of rigid regulations applied to all installations equally, enforced by inspection. Now operators must identify all hazards on their platforms and demonstrate that operations can be conducted safely. The change follows recommendations of the Cullen Report on investigations into the July 1988 Piper Alpha disaster.

Sept. 2, 1991

6 min read

Safety management is changing in the U.K. North Sea.

The basis for safe operations once was a sector-wide set of rigid regulations applied to all installations equally, enforced by inspection.

Now operators must identify all hazards on their platforms and demonstrate that operations can be conducted safely.

The change follows recommendations of the Cullen Report on investigations into the July 1988 Piper Alpha disaster.

The first stage of transferring safety responsibility to the operator requires a formal safety assessment leading to a platform safety case, which must be approved by authorities.

As well as identifying hazards on a platform, operators must show how they will control risks to personnel.

They also must demonstrate that safety management is adequate.

To provide cover for off shore personnel, each installation must have a temporary refuge where workers are safe from fire or explosion. Detailed plans are also required for evacuation, escape, and rescue.

Operators also are responsible for policing safety through monitoring and auditing of approved safety management systems.

AUTHORITY TRANSFERRED

Authority for safety in U.K. waters has now been transferred, on the recommendation of the Cullen Report, from the Department of Energy to the Health and Safety Executive (HSE), which is independent but financed by government.

Under the new regime, the HSE establishes parameters and timing of safety assessment submissions and approves safety cases for individual platforms. Later it will ensure that the operator's system for monitoring and auditing safety is working effectively.

First objective of the HSE's new offshore safety division is to publish a consultative document containing draft regulations early next year. This would lead to legislation.

The HSE's timetable has created a problem for operators, particularly those with large numbers of offshore installations. It is clear that safety assessments on all existing installations must be completed and the safety case submitted by the end of 1993. HSE acceptance is required by the end of 1995.

The penalty for failing to meet this timetable may be shutdown of production until an acceptable safety case is submitted.

The schedule has forced operators to begin safety assessments without definite knowledge of what the draft regulations at the end of this year will contain.

Operators with large numbers of installations face a considerable task. BP Exploration must produce more than 20 assessments and safety cases. Shell U.K. Exploration & Production, operator for the Shell/Esso group, has 33 installations that need the same treatment. Between them, the two operators account for about 50% of the installations in the U.K. North Sea.

Unofficial guidance is available. The U.K. Offshore Operators Association has produced a document on procedures on formal safety assessment (FSA) that many operators are using for preliminary work on FSAs. While the document has not been officially approved by either the Department of Energy or the HSE, no objections have been raised to any of the contents.

The document is designed to provide the skeleton for an FSA, with operators providing details to meet requirements of individual platforms.

Offshore affiliates of multinationals know that the timetable for drawing up a safety assessment is tight. Experience of downstream subsidiaries that have produced safety cases for refining and petrochemical plants indicates it could take up to 5 years to prepare safety cases for all existing installations.

Some small operators have delegated responsibility for the FSA to outside contractors because they lack manpower to handle the work effectively. Larger companies are making the preparations themselves to take advantage of the experience that will accrue from the complex assessment exercise.

REGULATORS' OBJECTIVES

Tony Barrell, who heads the HSE's North Sea safety division, said he expects North Sea operators to make a critical and honest assessment of the hazards of every aspect of offshore work.

Operators' strategies must reduce the risk of small incidents, which make up the bulk of offshore accidents, as well as the rare but attention-catching disasters.

Other requirements will be overhaul of management safety systems, operational procedures, and command structures. Where possible, Barrell wants companies to improve technology and hardware.

In the area of manpower, the HSE will be looking for operators to involve the off shore workforce in the safe running of installations and to provide information enabling workers to avoid dangerous situations.

Barrell added that operators will be expected to do more than just monitor operations to ensure that standards set by the safety case are maintained. They will be expected to seek improvements and higher standards.

The new safety chief has kept in touch with industry thinking through an informal liaison group made up of representatives from BP, Shell, Chevron, and Conoco.

Similar liaison groups have been set up with leading drilling companies and the trade unions.

All information on HSE thinking is valuable. Mike Payne, manager of BP Exploration's post-Cullen safety team, pointed out that the stakes are high: Failure to meet the requirements could lead to a shutdown with enormous commercial implications.

BP Exploration ran a program of immediate remedial action on its platforms after Piper Alpha and has worked out the methodology for formal assessments on all its platforms.

A pilot operation is being run on the Forties Charlie platform, one of the most crucial units in the BP North Sea infrastructure as it is a first generation collector platform.

Payne said the pilot was an exercise in methodology designed to ensure BP's proposed system worked properly. The pilot also showed there were a few areas where the methodology could be improved and resources could be better utilized.

This was especially important, he said, as there is a severe shortage of safety experts throughout the North Sea, and not all of the " experts" meet the standards being set by leading companies.

Payne added that the lessons learned from the Forties Charlie pilot will provide guidance for BP's safety cases in the North Sea.

Currently, BP's Cullen team is working on ways to involve offshore personnel in the safety assessment exercise and on meeting the undertaking given to the authorities to produce evacuation, escape, and rescue studies for all North Sea platforms before the end of the year.

This may highlight areas where procedures need tightening. It might also spot weaknesses that would be rectified in the full safety case.

The move to involve the offshore personnel is important, said Payne.

Local knowledge is valuable in building a safety case as the people offshore know where the hazards lie.

Offshore workers will be shown the methodologies for developing the core of the safety case and the types of hazards expected. The workers can also contribute to reducing effort spent on areas that are not a hazard on a particular platform.