Offshore Northern Europe U.K. Offshore Safety Regime Raises New Challenges

Mike Baily
Health & Safety Executive
Liverpool

In November 1995, U.K. operators completed implementation of the offshore "safety case" regime, which resulted from Lord Cullen's inquiry into the Piper Alpha explosion of 1988.

Since then a number of significant milestones have been achieved, but there are continuing challenges both for the operators of offshore installations and the regulator, the Offshore Safety Division (OSD) of the Health & Safety Executive (HSE).

Recommendations from Lord Cullen's report on the Piper Alpha disaster were far-reaching and included proposals for an extensive legislative review.

They included a requirement for the submission and acceptance of a safety case document for each offshore installation, in advance of operations and underpinning "goal-setting" regulations covering arrangements for prevention and mitigation of fire and explosion, emergency response, offshore management, and design and construction, and for verification of integrity.

This major program of legislation was completed on June 30, when the Offshore Installations and Wells (Design & Construction, etc.) Regulations 1996¹ came into force.

The package of new regulations provides substantial challenges for both operators and regulator by virtue of their "goal-setting" nature.

A principle of the Offshore Installations (Safety Case) Regulations 1992² is that operators must reduce risks to the offshore workforce from major accidents to a level "as low as reasonably practicable (Alarp)."

The underpinning regulations place duties on operators to meet broad, and largely unquantified, safety objectives.

The goal-setting approach helps to clarify that it is those who create the risks to health and safety who are responsible for their control, through the application of appropriate hardware and management measures.

It also provides those with duties (principally the owners/operators of installations) under the regulations with greater freedom to develop their own solutions, and reduces the potential for legislation to be a barrier to innovation.

Safety cases

The Safety Case Regulations made it an offense to operate or abandon an installation, or engage in combined operations, without an accepted safety case. They also made it an offense to fail to comply with an accepted safety case.

Transitional provisions of the regulations allowed existing installations to continue operation until Nov. 30, 1995, without an accepted safety case, provided that a case had been submitted.

In all, 225 safety cases for existing installations were assessed and accepted by HSE in the period up to Nov. 30, 1995 (Table 1 [8200 bytes]).

HSE did not refuse to accept any of the submitted safety cases, but many were accepted only following commitments in the safety case to major programs of improvements.

In some cases considerable discussion was required to agree to a way forward, but many worthwhile improvements were secured (Table 2 [62483 bytes]).

Benefits and costs

The Health and Safety Commission (HSE's parent body) published an interim evaluation of the effects of the regulations³ in 1995, which (based on a sample of figures produced by operating companies) estimated that average individual risk had been reduced by about 70% through the safety case regime.

The overall cost to the U.K. offshore oil and gas industry of complying with the safety case regulations was estimated to be in the range £1.2-1.4 billion ($1.8-2.1 billion).

This falls at the lower end of the £1.2-2 billion ($1.8-3 billion) forecast by HSE in its original cost-benefit assessment.

The overall cost to industry of implementing Lord Cullen's recommendations was estimated at £2.3-2.6 billion ($3.45-3.9 billion), around 80% being on hardware improvements (Table 3 [7260 bytes]).

The interim report also considered the views of industry managers and the offshore workforce. Recognition by managers of the value of improved understanding and management of risks was tempered by concerns with regard to the extent of reliance on, and the credence to be attached to, the results of quantitative risk assessment, the paperwork generated, and the difficulty of workforce involvement in an inherently complex process.

More than 70% of workers surveyed said they felt more confident about their safety now that every offshore installation must have an accepted safety case.

In addition to the practical improvements secured through safety cases, benefits have arisen from highlighting previously unrecognized risk areas and gaps in technical knowledge. This has allowed both industry and regulator to focus action and research more strategically and intelligently.

Work in progress

The safety case regime is now maturing. Safety cases continue to be prepared and assessed for new offshore installations, abandonments, and combined operations.

In addition, and in accordance with the life-cycle concept of the regulations, revisions to accepted safety cases as a result of major modifications are being processed.

Later in 1996 the submission of periodic revisions to reflect changes since the last acceptance will commence. Since Nov. 30, 1995, a further 42 submissions have been accepted, and as at May 31, 1996, a further 31 submissions are undergoing assessment.

This process continues to develop the understanding of all parties and adds to the agenda of areas which require attention.

The value of regular contact between senior operational managers representing the major industry bodies and OSD was recognized at an early stage.

The Senior Managers Forum was established, consisting of senior representatives from the U.K. Offshore Operators Association (Ukooa), the International Association of Drilling Contractors (IADC), and the British Rig Owners' Association (BROA) and OSD.

Meetings have taken place on a bimonthly basis to report progress and discuss matters of mutual concern with regard to safety cases, to discuss practical matters related to the enforcement of the new legislation, and to provide information on developments in knowledge.

The relatively informal nature of this forum has allowed rapid agreement on strategies for resolving practical difficulties.

Challenges

The U.K. safety case regime has been successfully implemented, yielding significant benefits. A number of challenges remain, and both industry and regulator are working hard to meet them.

It is possible here to provide only a summary and to outline the way in which OSD and industry are addressing their challenges, which include ensuring:

• That improvements committed to during the preparation and assessment process are actually delivered.

• That safety cases are an integral part of safety management as a "living document."

• That the workforce is involved in the process.

• Effective implementation of the full package of "goal-setting" regulations.

In the relatively short times available for safety case preparation and assessment, it was simply not possible for operators to complete all improvements required to secure the Alarp objective before Nov 30, 1995. Many safety cases were therefore accepted on the basis of an ongoing improvement program, in some instances covering both improvements to analysis and improvements to hardware.

The operating environment in the North Sea has changed significantly since the acceptance of many of the safety cases as a result of market conditions, the operators' Cost Reduction Initiative for the New Era (Crine) program, and the development of new approaches.

Industry is critically reviewing some of the measures which appeared to be worthwhile in pursuit of Alarp, but the objectives of which may now be better secured by alternative means.

Appraisal

For its part, OSD's inspectors are engaged both in onsite appraisal of the delivery of improvements and in assessing the complex technical arguments put forward for alternative approaches. Reviewing the delivery of improvements is an integral part of OSD's risk-based approach to offshore inspection.

There is a temptation to see the acceptance of a safety case as the end-point of a project rather than as an important stage in the living analysis of the risk management strategy for an offshore installation. There are two principal reasons for this:

• The complex process of producing safety cases has generally been managed by onshore project teams and involved the extensive use of consultants, who cease to be involved once the safety case is accepted.

• The need for detailed hazard analysis and quantitative risk analysis has resulted in safety case documents which are often difficult for the offshore workforce to relate to their day-to-day responsibilities.

It is easy for offshore practices to deviate significantly from the approaches committed in the accepted safety case. OSD inspectors have already exercised their statutory enforcement powers to require compliance with a safety case commitment regarding the dissemination of essential hazard-control information.

Many operators are considering how they can make the best practical use of safety cases and, in particular, how to make them more user-friendly for management and workforce alike. Two of the potentially fruitful strategies in this area are:

• To revise the safety case, summarizing the key tenets in a relatively simple and logical format and supporting this with detailed technical appendices.

• To extract relevant information from the existing safety case and prepare workforce summaries for particular workgroups of the relevant hazards, risks, and controls, presented in an easily usable format.

Further discussion both within the industry and at the Senior Managers Forum will be essential in evolving strategies to enhance workforce involvement in the safety case process.

Compliance

Industry is making advances in securing compliance with the requirements of the full package of goal-setting legislation.

Particular challenges are being experienced in setting meaningful and measurable "performance standards" for measures to control fire and explosion and for measures to secure effective emergency response.

In addition, industry is striving to gain benefits from monitoring, auditing, and reviewing safety management systems as required by the safety case regulations.

For its part, OSD is using accepted safety cases as an integral part of planning its future intervention with regard to offshore operations.

For each installation a rolling 3 year strategic inspection plan (SIP) is developed, based on the specific knowledge of OSD's inspectors and their evaluation of potential risk areas based on safety case assessment.

This approach provides a structured and risk-based framework for targeting and prioritizing OSD's resources.

Key aspects of inspection will be to monitor the effectiveness with which the commitments in the safety case are being implemented, monitoring the effectiveness of safety management system and operator audits of them, and critically examining the efforts made by duty holders to actively involve the workforce in the safety case process.

In addition, HSE staff are conducting industry-wide inspection projects to focus attention on areas of generic concern, managing major research programs to enhance technical knowledge, and performing promotional work to encourage continuous improvement in health and safety standards.

References

1. The Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996, SI 1996/913, HMSO, ISBN 0-11-054451-X.

2. A Guide to the Offshore Installations (Safety Case) Regulations 1992, HMSO, ISBN 0-11-882055-9.

3. An Interim Evaluation of the Offshore Installations (Safety Case) Regulations 1992, HSE Books, ISBN 0-7176-1060-8.

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