ERM’s North America Risk Team welcomed more than 100 clients to its recent workshop focusing on the potential initiation of a safety case regime for US deepwater exploration and production activities.
Introduction to Safety Cases: A New Regime in Gulf of Mexico Drilling? provided attendees with an overview of what is required to prepare a safety case and the commitment to implementation – and the consequences of poor implementation.
The event resulted in many attendees wanting more information in these areas, in addition to the desire for regulatory development updates. Feedback included recognition of ERM’s strong understanding of what many see as a complex subject, the event’s focused content, and providing a valuable forum in which to discuss common concerns amongst operators.
Why a seminar about safety cases?
In May the US Department of the Interior (DOI) issued a report and recommendations for ways to increase safety in Gulf of Mexico deepwater drilling: Increased Safety Measures for Energy Development on the Outer Continental Shelf. The recommendations comprise five primary areas including the increased enforcement of existing safety regulations and procedures. This includes the adoption of safety case requirements.
Safety cases are documents usually produced by the operator of a facility as evidence that a facility is safe to operate. A safety case identifies hazards and risks, describes how the risks are controlled, and describes the safety management system in place to ensure the controls are effectively and consistently applied. Regulated safety case regimes are common practice in many countries.
The International Association of Drilling Contractors (IADC) has already established two sets of HSE case guidelines – one for offshore and one for onshore drilling – and is currently working on Bridging Documentation Guidance for the US.
ERM’s North America Practice Lead Morris Burch said, “The demand for this event demonstrates the continuing focus operators are placing on environment and safety and the need to manage effectively potential impacts to communities and society. Obviously a document cannot ensure safety. The critical need is to identify and manage safety-critical aspects, including safety of the environment, community, business, etc, of the business following a comprehensive hazard analysis.
“Regulators in many countries already require safety cases to be prepared before offshore operations are allowed to start. Some companies choose to adopt HSE cases even without regulatory requirements, and they typically following accepted guidelines as a basis, such as guidelines of the International Association of Drilling Contractors (IADC). With the DOI report issued in May however, there is a real focus on making the preparation of such cases the norm rather than the exception, and the client feedback from our July seminar only goes to support this.”
The North America Risk Team has extensive experience in creating safety case documents and supporting their implementation in the USA, the UK, and Australia and can provide valuable insight into what could becoming a regulatory must within the US.