As highlighted in a recent BBC article, there are concerns that the industry needs to do more to tackle hydrocarbon releases; quoting the Health and Safety Executive (HSE) who testified some operators had come "perilously close to disaster". This has led to the HSE writing to all operators in the North Sea asking them to carry out a review of their ‘process safety leadership’, and the ‘assurance, audit and review’ elements of their safety management systems against a recognised Process Safety Management (PSM) standard.
What’s the problem?
During 2017 there were over 70 releases, 21 of which were significant.
A high percentage of hydrocarbon releases are still due entirely or in part to human intervention. A study conducted by LR in 2012 found a wide variety of human factors and organisational failures had contributed to the occurrence of HCRs. In reviewing these failures, there are contributory factors at many levels, which may themselves be caused by secondary factors. These include failures in engineering controls, administrative processes, management/leadership, maintenance processes and communications.
This was seen in the Piper Alpha, where 167 offshore workers lost their lives in what is still considered one of the worst incidents in Oil & Gas history. One of the main findings from the enquiry was that the shortcomings around the maintenance work that led to the Piper Alpha disaster represented failures on the part of management to give adequate attention to process safety.
Process Safety Management (PSM)*
HCRs are managed under the umbrella of PSM, failures in which can often be costly and highly visible. Most companies do have process safety frameworks in place; they write procedures and undertake risk assessments. However, workforce behaviors must align with PSM requirements, and your safety culture must also support your PSM.
There were numerous failings that occurred in the run up to and during the Piper Alpha incident. Most significantly, a lack of communication at shift change meant staff were not aware of the maintenance work that had occurred on the high pressure condensate pump and that at shift handover the condensate pipe remained sealed with a blind flange.
Improving safety culture
PSM and the safety culture of your organisation may come under more pressure in times of change and uncertainty, and when resources are stretched. Marsh’s ‘The 100 Largest Losses 1974-2015’ shows that an increase in frequencies in losses is observed either during or directly after reductions in the crude oil price. Further, Marsh identifies cost-saving initiatives or reduced investment in safety measures and training as potential factors that could compromise safety performance. This makes the focus on PSM and safety culture within organisations especially important at such times. Lord Cullen, the judge who headed the Piper Alpha disaster public inquiry has expressed fears that offshore workers still worry about raising safety concerns. We must focus on ensuring a good safety culture, as well as procedures and risk assessments. When the right focus is placed on safety culture, staff will be much more likely to identify hazards, challenge them, and engage in safety improvement activity.
Ensuring asset integrity strategies that include effective risk based inspection (RBI) and reliability centred maintenance (RCM) methodologies are also fundamental in the quest to reducing hydrocarbon releases. Operators are perpetually balancing production objectives with understanding and executing safety critical maintenance and inspection, and reducing OPEX spend. Delaying inspection and maintenance activity seriously jeopardises the integrity of an asset and in the long run, isn’t a cost effective strategy, not to mention the risk to safety and lives highlighted previously. Although the offshore industry has made significant improvements in regards to asset integrity management since the issuance of the HSE’s Asset Integrity (KP3) and Ageing and Life Extension Programme (KP4), there is always room for improvement, as echoed by the HSE in this latest address to the operators.
Although the overall number of HCRs has been reducing, and there has been a sustained downwards trend in the total number of process HCRs since a peak in 2004, they are still occurring and a focus on process safety, internal safety culture and integrity continues to be a priority.
For more information on managing process safety in times of change, download our white paper here, or to talk to one of our experts about process safety and integrity in your business, please get in touch.
*Process safety is a blend of engineering and management skills focused on preventing catastrophic accidents and near misses, particularly structural collapse, explosions, fires and toxic releases associated with loss of containment of energy or dangerous substances such as chemicals and petroleum products.
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