Girish U. Pai, Devendra Awadhiya and Zubin Fatakia discuss the evolution of safety case in designs for offshore platforms.
Offshore installations are exposed to nature’s fury all the time. The operations involve handling very heavy modules weighing tens of thousands of tons. Presence of hydrogen sulfide or other lethal gases in process streams pose serious hazards to people working there. Movement of tugs, barges around the installations further increase the accident potential. Deepwater Horizon brought out the dangers of oil spills, causing serious damage to flora and fauna in oceans.
Safety systems need to address all these hazards. All countries, therefore, have rightly formulated standards and regulations and established monitoring agencies to ensure safe conduct of offshore operations. Every country has its own legislations for safe design, construction and management of offshore installations.
In 1974, the American Petroleum Institute (API) published its Recommended Practice 14C, which covers recommendations for design, installation and testing of a basic surface safety system on an offshore production platform. In this recommended practice, basic concepts of a platform safety system are discussed and protection methods and requirements of the system are outlined.The first successful effort to improve safety was setting up the National Safety Council in 1913 to pool information. Government agencies such as the Bureau of Mines and National Bureau of Standards provided scientific support while universities also researched safety problems for firms and industries. In the 1960s, economic expansion led to rising injury rate. Hence, in 1971, the US Congress established the Occupational Safety and Health Administration (OSHA) to ensure that employees are provided with an environment free from recognized hazards, such as exposure to toxic chemicals, excessive noise levels, mechanical dangers, heat or cold stress, or unsanitary conditions.
After the 1988 Piper Alpha catastrophe that killed 167 people, API published its Recommended Practice 75, for development of a safety and environmental management program for offshore operations and facilities in 1991. It has been updated regularly since. The standard recommends that companies create a safety environmental management program (SEMP). API RP 75 is performance-based and insists on continuous improvement and effective communication.
In 2010, Bureau of Ocean Energy Management, Regulatory and Enforcement (BOEMRE) mandated that all references in the API RP 75 document cited as “shall” or “should” will be considered “must.” In 2011, the US split BOEMRE into two organizations: the Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE). Following the Deepwater Horizon event, BOEMRE implemented a requirement that safety cases be prepared for drilling operations. Companies can use the template from the International Association of Drilling Contractors (IADC), which is widely used.
Regulations in India
To ensure proper implementation of various aspects of safety in the oil industry, India set up the Oil Industry Safety Directorate (OISD) and gave it authority to formulate and coordinate the implementation of a series of self regulatory measures for enhancing the safety in the local oil and gas industry.
India’s government also created Petroleum and Natural Gas (Safety in Offshore Operations) Rules, 2008, to regulate safety in offshore exploration, exploitation, conservation and management of petroleum and natural gas and matters connected therewith. PNG Rules, 2008, follow a goal-setting approach, i.e. what is to be achieved rather than prescribing specific solutions.
Solutions chosen by the operator shall be based on customary practice in the industry, requirements, and specifications appearing in other documents such as nationally and internationally recognised industrial standards (e.g standards like API, ISO, OISD), codes and conventions (e.g. MARPOL, SOLAS, ISM, MODU code). However, evidence in form of documentation, demonstrating that solutions selected by the operator fulfill the functional requirements of the rules, shall be maintained by the operator at all times. Safety systems of Indian operators such as ONGC and GSPC comply, among others, with API RP 75, API RP 14J and API RP 2C.
Guidance notes issued by OISD in April 2012 made it mandatory for operators to get a valid certificate issued by an independent party (including a classification society ) to achieve the “fit for purpose” status for an oil installation.
In the UK, The Health and Safety at Work Act 1974 is the primary piece of legislation covering occupational health and safety. The Health and Safety Executive (HSE) with local authorities (and other enforcing authorities) is responsible for enforcement. The Piper Alpha disaster was a watershed event in UK offshore, which caused a paradigm shift in offshore safety systems not only in the UK , but in the offshore industry worldwide.
After Piper Alpha, the UK introduced the most comprehensive legislation for protection of workers and ensuring integrity of installations. A few of the regulations include:
- 1992: Management of Health and Safety at Work Regulations 1992
- 1995: The Offshore Installation
- 1995: Pipeline Works (Management and Administration) Regulations
- 1995: Prevention of Fire and Explosion, and Emergency Response Regulations (PFEER) 1995
- 1996: The Offshore Installations and Wells (Design and Construction, etc) Regulations 1996.
The most important of all, the Offshore Installations (Safety Case) Regulations 2005, came into force in 2006, which made it mandatory for the operator or owner to prepare a safety case and submit it to HSE for acceptance.
Safety case: For submitting a safety case, the operator has to prepare a detailed and structured argument to establish that the oil facility is safe. In general, a safety case should clearly describe the following elements:
- The system and its operational context.
- The safety claims and safety criteria.
- Hazard Identification and Risk Assessment.
- Risk control measures and their effectiveness.
- Why the residual level of risk is acceptable:
- Roles, responsibilities, organizational safety policies and organizational safety management system.
The challenge is to present the information in an easily accessible format, improve communication and involve a wide range of people in understanding important risks and issues.
A Safety Case must demonstrate that:
- Major accident hazards have been identified and that the necessary measures have been taken to prevent such accidents and limit their consequences for persons and the environment.
- Adequate safety and reliability have been incorporated into the design, construction, operation and maintenance of installations linked to major accident hazards.
- All necessary measures have been taken to reduce identified risks to as low as reasonably practicable (ALARP).
- It meets all regulatory requirements of the Petroleum Submerged Lands Act.
The operator has a duty to ensure and pay for the training of the safety representatives.
Secondly, the workforce is involved in developing the safety case for an installation. The safety case regulations require the operator both to demonstrate they have consulted with the workforce when preparing the safety case and to make copies of the accepted safety case available to them.
Benefits: Since safety case is primarily built from first principles and not from legacy standards, it can integrate safety evidence from diverse sources, such as trials, human factors analysis and operational experience.
- Safety Case acts as a focus for discussion between all stakeholders such as system designers, manufacturers, operators, managers and workers. The benefit in terms of increased communication is tremendous.
- Safety Case makes the implicit explicit. It documents existing implicit assumptions and risk acceptance judgments. This increases transparency.
- It is an opportunity for understanding limitations of current safety system and making improvements in it.
Safety Case vs. conventional approach: Conventional approach has focused primarily on prescriptive safety requirements, e.g. In India and USA, safety executives look for compliance with codes like API RP 75, PNG Rules 2008. With such approaches, operators claim safety through satisfaction of the regulator’s requirements. With the introduction of safety cases, the responsibility is shifted back to the operators and it is up to the operators to demonstrate that they have an adequate argument of safety.
Why safety case is not widely adopted (beyond the UK): In principle, a safety case can be developed for any activity. However, in practice, they are generally only prepared for large, complex industrial or technical systems such as nuclear power plants, military and civilian aviation and offshore oil and gas installations. Such systems are complex, and, in the event of an accident, the consequences could be very severe.
Also, the use of API standards and related documents has been proven fairly successful. Although the Deepwater Horizon event was extremely serious, it was the first major blowout in US waters since 1969, with the Santa Barbara blowout. In 1999, a wellhead blowout occurred on a platform, which operated under safety case, at the Montara oil and gas field in the Timor Sea off Western Australia. The development of safety cases and the application of the subsequent safety case regimes is expensive, time consuming and creates a large amount of paper work. If it could be demonstrated that this investment truly improves safety then there would be no argument. However, there is no convincing evidence that either approach if clearly better than the other.
When all platforms are designed and operated to the same standards (mostly from the API) it is relatively easy to audit them. The auditor simply has to look up the appropriate code or rule, and he or she can come to a quick conclusion. Such is not the case with a safety case system, where each platform has its own unique program against which it has to be evaluated.
Safety systems continue to evolve as oil and gas operations become more challenging. World over, safety systems predominantly operate in a regime where the systems have to meet requirements of prescribed standards. However, the legacy standards may not meet the requirements of highly complex industrial or technical systems such as nuclear power plants, military and civilian aviation and large offshore oil and gas installations where the consequences of an accident could be very severe.
For smaller installations, the benefits of prescriptive safety systems outweigh the higher cost and time involved in building up a safety case. UK has made it mandatory for all oil installations to get a safety case approved by HSE. The US has made it mandatory only for drilling operations.
However, it is worth noting that a safety case preparation presents an opportunity to operators and contractors to have a reality check on their safety systems, look for gaps and improve safety with the active involvement of all stakeholders. A powerful safety regime is one which measures the performance of critical success rather than relying on occupational health and safety statistics.
Girish U. Pai serves as advisor, HSE & Quality Assurance at Larsen & Toubro Hydrocarbon Engineering (LTHE), India. He is in charge of implementing best HSE practices for upstream oil & gas projects. He holds a B. Tech. in chemical engineering from I.I.T. Bombay and a diploma in management from Mumbai University. He has over 35 years’ experience in offshore projects. Prior to 2012, he was head of engineering and procurement at Larsen & Toubro.
Devendra Awadhiya is a chemical engineering graduate from Marathwada University, Aurangabad. He is a chartered chemical engineer certified by Institute of Chemical Engineers, UK. Awadhiya has over 20 years’ experience in the area of process design and engineering. Through his career he has been responsible for process design, engineering, start-up, commissioning, process optimization, and trouble-shooting of onshore and offshore process plants / platforms.
Zubin Fatakia serves as process and commissioning manager at LTHE, based in India. He is responsible for process design, engineering, commissioning, start up and trouble shooting of offshore platforms. Fatakia earned a B.E. in chemical engineering at Mumbai University and has over 10 years’ experience in process engineering, commissioning and HSSE studies.