New regulations, such as the recently issued EU Offshore Safety directive, mirror a zero tolerance for offshore accidents. Yet, major accidents still occur. Graham Bennett outlines how better barrier safety management is key to overall safety.
Oil and gas (O&G) exploration and production activities are not inherently safe. Major offshore accidents have occurred on all the continental shelves, resulting in loss of lives, damage to the environment and destruction of assets.
New and improved technical solutions have been developed and operational systems and regulations support a wide variety of O&G developments. Operating practices have been tested and refined. However, major accidents and near-misses continue to occur. In addition, we are heading into deeper waters, more remote locations, increasingly challenging reservoirs, harsher environments and more environmentally sensitive areas.
This article suggests ways to improve offshore safety and environmental performance above current levels. In particular, it suggests ways to prevent and mitigate major accidents, and outlines factors necessary for improved offshore safety and the management of the associated risks, especially when entering more demanding areas.
Six key levers
The resultant model that has emerged from the study presents six interconnecting performance levers and dependencies. The model should form the basis for all planning and execution of offshore O&G operations.
In this model, the operator must achieve performance excellence in all important elements or dimensions. Poor performance in one or more will weaken the overall safety level. In order to achieve this, the following levers must be in place:
Performance-Based Regulations: Performance-based regulation requires a risk-based health, safety and environmental (HSE) management system and is deemed fundamental to ensure continuous improvement, innovation and adaptations to relevant conditions and new risks. It should be supplemented by prescriptive regulations and standards for well-proven solutions and conditions. An independent verification scheme is needed to validate that the required performance is met.
Clear roles and responsibilities: Overall accountability for all operations must rest with the operator or licensee. The operator may sub-contract an activity, but the risk remains with the operator. It is also important that each part of the organisation, from the boardroom to the offshore installation, is aware of its role in barrier management.
A holistic risk approach: To maintain a holistic risk overview in a total field lifecycle perspective, all the involved parties in the activities need to have access to a tool that records up-to-date risk identification and provides a complete view of the risk exposures for an asset, asset cluster, project or company. The tool must include consideration of major hazards that might result in loss of life or large hydrocarbon spills, and also address the risk of rare events that would have major consequences.
Shared performance monitoring: Many parties are generally involved in the planning and execution of an offshore operation. To ensure effective risk management, they must share the same safety performance targets, monitor the same safety conditions, and have a common understanding of the status and effect of nonconformities/deviations.
Advanced barrier management: Investigations into major accidents conclude in most cases that the events that occurred were known risks, for which several safety meastures had been planned and implemented. However, the accidents occurred as a result of multiple barrier failures, often in combination with a lack of or inadequate barriers in certain areas. Although preventive barriers are preferred, mitigating barriers is also important.
People, processes & plant: Safe operations are the product of reliable technology, an effective organisation, a competent strong management, and motivated people. Now that shallow-water development areas are more mature, operators are looking towards new offshore and onshore areas to further develop their O&G portfolios. These developments have in common a large degree of technical innovation, inherently triggering new risks.
Safety barrier management
To achieve a step change in offshore safety, additional priority should, arguably, be given to the performance of safety barriers, and what the operators do to ensure the barriers are reliable and meeting their expected performance.
The O&G industry is already familiar with the use of safety barriers to prevent major accidents from happening, and to mitigate the consequences when they do occur. The approach is often illustrated by the bow-tie model. However, this approach is not always used to its full potential, and regulators and operators will benefit from zeroing in on the weakest link. Barriers degrade over time if not looked after. Particularly the barriers designed to prevent a near miss incident from developing into a serious accident. This line of defence could be forgotten in day-to-day operations. One example is equipment for emergency shutdown that is to be used only in emergencies, meaning it is difficult to test during operations and tests are infrequent.
Ideally, companies have real-time status on each barrier to manage their activities safely. Some companies have developed procedures that specify what barriers must be functioning for every planned activity; this recognises that barriers have holes and some may degrade. But a challenge is to know which barriers are degraded. Inspection, preventive maintenance and audit are all good techniques, but have a cycle time that can leave a year or more between status updates.
Pragmatic and close to reality
To strike a balance between plans, regulations, safety theory and a healthy dose of reality checks, existing processes can be put to better use.
Actual and near-miss incidents are routinely reported and investigated. Based on knowledge from major accident investigations and more routine incident investigations, DNV GL has developed a method to provide much more frequent updates on barrier statusùthe BSCAT investigation method.
Every incident means that some barriers have failed, and since many facilities experience over 100 actual or near-miss events annually, analysing these for barrier failures can provide the most frequent and up-to-date status of barriers. It has the side benefit that the facility risk assessment is used for every incident, verifying that it is correct and reinforcing the importance of risk management to all staff. It turns out this approach is not much more work than routine investigations. Since barrier performance is assessed this feeds very well the new requirements for process safety indicators. Both the American Petroleum Institute (API) and the International Association of Oil and Gas Producers identify demands on barriers amongst the most useful leading safety indicators eg, API 754 and OGP 456), and many companies are committed to adopting these standards.
As historical evidence shows, most major accident hazards are caused by a known threat, when technical, human and/or organisational safeguards were allowed to degrade over time. Therefore, risk management in offshore operations requires an up-to-date and clear understanding of the current status of barriers and how they affect risks.
The bow-tie risk model presented in combination with the BSCAT model allows frequent updates on barrier status. This process reinforces the role of supervisors and staff in reporting every incident and near miss.
The author is a Vice President, Business Development for Europe & North Africa, at DNV GL, a global risk management major for energy, O&G and maritime industries.