Twenty five years after the Piper Alpha tragedy, it seems appropriate to reflect on some of the changes that have taken place in the offshore oil and gas sector. Undoubtedly the period has seen a fundamental shift in the approach to safety. But has this led to a better understanding of vulnerabilities and is the sector safer as a result?
Process safety has evolved dramatically in parts of the world but arguably not in others. Piper Alpha led to a Safety Case regime in the North Sea which puts the onus on goal setting safety performance. Major hazards and associated risks must be identified and steps taken to ensure that they are eliminated, wherever possible, and any residual risk reduced to as low as reasonably practicable (ALARP). Operators need to drive improvement continuously and individuals need to take responsibility for the safety of what is going on around them.
There is no doubt that the requirement following Piper Alpha for all offshore production and drilling facilities in the North Sea to have a Safety Case, has made the region a safer place for all concerned. Following Safety Case development for the North Sea, the Dutch and Danish sectors quickly followed suit, as did Australia. Norway, meanwhile had a similar target setting approach, developed in response to the earlier Ekofisk Bravo and Alexander Kielland incidents and there are few arguments regarding that country’s commitment to process safety.
Some 25 years after Piper Alpha and much less time since incidents such as Deep Water Horizon in the Gulf of Mexico, process safety as practised in different parts of the world is still a variable concept. While the North Sea works reasonably well under the Safety Case regime, there is undoubtedly room for improvement. Other offshore regimes may be considered ripe for an even more dramatic overhaul.
It is perhaps no surprise following a number of serious incidents that operators in different parts of the world are looking at a more integrated approach to process safety. This means more effective integration of the different man/machine elements but also of the different impacts relating to an incident. What, for example, would have been the environmental impact of a Deep Water Horizon style incident in the North Sea? How far should operators look at planning for such a low frequency–high consequence event and what are the benefits of considering safety and environmental risks, and corresponding emergency response, together? Indeed, should the Safety Case style approach now be expanded to include not only environmental risks but also wells and pipelines outside the normal 500m zone around the facility?
Life after Maitland – and SEMs
The independent Maitland review, initiated by the UK Government following the Deep Water Horizon disaster, recognised the strengths of the UK’s offshore regime in managing both safety and environmental hazards. However, it also suggested that further improvements could be made through the introduction of ‘Safety Case’ style Environmental Assurance Plans and a greater integration between the respective Safety and Environmental regulatory bodies in the UK. Industry has already accepted and implemented many of the recommendations from Maitland and is currently progressing others.
Clearly, more integration needs to make the right connections without compromising the practicality of the ALARP or equivalent principle, depending on the regime. In Europe, for example, there is the prospect of an EU Safety Case regime which does indeed link process safety and environmental impacts. Fortunately, the initial intention of the EU for a ‘one size fits all’ set of regulations which could impact arrangements in the North Sea has now retreated, largely in recognition of the standard of the regime already in place. In its place will be a Directive which leaves the UK Industry in a position to influence how safety and environmental risk management can best be integrated to maximise the benefits without eroding the strengths of the current system.
In the US, in the aftermath of Deep Water Horizon, operators in the Gulf of Mexico must demonstrate that they have a Safety and Environmental Management System (SEMS) in place. However, the extent to which this is going to become a goal setting approach is still up for debate. Over prescriptive regimes arguably limit progress on safety and environmental risk reduction because they focus on compliance rather target setting performance.
Early stage risk assessment
Another facet of a more integrated approach, is the focus on the early stage of design of equipment and facilities. Offshore incidents may occur because of fundamental design flaws which haven’t fully taken into account the functionality or durability of the equipment to be used or how it will be operated and maintained. It is still the case that many well intentioned formal safety assessment studies performed during the design process do not have their findings and recommendations adequately fed back into the design. In these instances operators have to be particularly vigilant to ensure they don’t unknowingly inherit risks, making them vulnerable to certain incidents whatever their own safety regime.
Not surprisingly, perhaps, the Deep Water Horizon trial, which recently finished its first phase, has put the role of contractors in the spotlight. To what extent should contractors share responsibility for managing safety and risk? How far should a manufacturer – for example in the case of a blowout preventer - be held responsible for the accident? The upshot may well be that operators and contractors move closer towards an environment of shared risks, with operators requiring contractors to adopt and abide by much stricter controls.
In short, all roads point towards a more integrated, risk-based approach to process safety. Piper Alpha and other incidents have shown the industry that there is simply no other option.