A year ago, the Health & Safety Executive rather controversially created a new energy division, bringing together offshore oil and gas exploration through production and decommissioning; gas transmission and other pipelines and related infrastructure and mines.
And the HSE put the highly experienced Susan Mackenzie in charge shortly after the reorganisation, since when she has been getting to grips with her still new brief, in particular the North Sea oil and gas part.
With the 25th Anniversary of the Piper Alpha disaster of 1988 very much to the fore at the time, Mackenzie wrote in the June edition of the HSE Tea Shack News for offshore workers: “The UK has a mature goal-setting regulatory regime which was built on the lessons learned from Piper Alpha.
“These regulations have stood the test of time and are, I believe, valued not only in the UK but seen internationally as a model worthy of adopting.”
She also warned that serious incidents such as hydrocarbon releases still occurred and this was forcefully driven home late last year in a toughly worded letter to North Sea leaders in which she wrote: “HSE received 79 HCR reports between April and November 1, 2013. This compares with 56 in the same period in 2012.
“This is a worrying reversal of the positive 49% reduction in the past three years. It makes the industry target to reduce HCRs by a further 50% by April 2016 even more challenging.”
Mackenzie had just a couple or three weeks earlier warned the industry at the Offshore Contractors Association annual dinner that its way of measuring such releases was also unacceptable.
The letter continued: “Uncontrolled release of hydrocarbons is a significant offshore major accident precursor. We all recognise that reducing HCRs is essential in reducing the likelihood of a catastrophic fire and explosion.
“Any increase in HCRs is justifiably of significant concern to offshore operators, contractors, workers, Trades Unions and HSE. HCRs represent failures in your management of major hazard risk.
“I believe we must all work together to identify the causes of the increase in reported HCRs, and act to ensure they are addressed.”
It is with such issues in mind that Mackenzie with colleagues and through extensive consultation has been formulating a new strategy; one designed to ensure that the North Sea industry is, in HSE terms, fit for purpose today and capable of sustaining the relentless attention to detail that is increasingly needed as this now mature industry looks to a future measured in decades.
Here in some detail, Mackenzie articulates the HSE Offshore Division’s new strategy that will form the backbone of its approach to the North Sea in the foreseeable future.
Q: HSE’s Energy Division is about to launch a new strategy for the oil and gas industry. Why is the strategy important?
Mackenzie: I have spent the last year working with my team, consulting inspectors, talking to industry, Step Change in Safety, Oil and Gas UK, British Rig Operators Association, International Association of Drilling Contractors and unions.
The strategy sets out what we all agree is the way forward and determines how my inspectors will go about regulating health and safety offshore. ED is publishing the strategy on HSE’s website because I want everyone to be clear about how ED inspectors will go about their work, and what I am expecting of industry and its leading managers.
Q: So what will be different about the approach your inspectors take?
A: The biggest difference will be how we target our inspections.
Firstly, we will be focussing even more on major hazard risks. These are the risks that could give rise to several workers being killed or seriously injured in a single incident, the sort of thing that caused Piper Alpha.
Secondly, we will be using performance data on key major hazard risks to target the operators and installations that we inspect.
Q: What are the main major hazard risks?
A: Fires, explosions and structural collapse.
Fires and explosions most commonly result from ignition of hydrocarbon releases (HCRs). The industry recognises the importance of controlling HCRs. It set itself a target of halving the rate of HCRs by 2013. It didn’t quite reach that target but it has set itself the challenge of reducing this rate further. However, this year HCRs have increased. This trend must be reversed.
Structural collapse can happen because installations have corroded in the harsh offshore environment, are damaged by a vessel collision or because of the battering they take from heavy seas and storms. Floating platforms can be blown off station and lose their anchorage.
Q: So what are you expecting the industry to do to react?
A: The issues are all well known. In the North Sea approximately 50% of the installations are beyond their original design life. The structures themselves have decayed and the oil and gas processing plant on board can be worn and corroded, control systems may be out of date, so measures to ensure asset integrity are essential.
Some older platforms are safe, the others can be made safe, but time, effort and resource have to be made available.
The fields being exploited now are often in deeper water and product is at higher temperatures and pressures. These factors put even greater stress on the assets. Ensuring asset integrity is even more important if new fields are to be exploited.
Of course, we also have to ensure that emergency plant and equipment is effective and always ready for use. We will be checking that integrity of emergency refuges is sound.
Q: This is all about the installations, are there any other factors you will be looking at?
A: People issues are vitally important. All workers need to be competent and everyone working offshore needs to understand how their role affects safety and what they need to do keep up standards.
This means workers and managers knowing and understanding what they need to do. Managers responsible for deciding on design of plant and processes or where money is spent on maintenance or the provision of new plant, need to be aware of the implications of what they do.
This will only happen if senior managers in the industry demonstrate leadership. Commitment is the key to doing all the things we all know are necessary.
Q: What will we see if managers take up your leadership challenge?
A: That they make clear, unequivocal statements about the responsibility they take for safety and also setting themselves targets to demonstrate they are making progress. I want to see the industry agreeing some common, comparable major hazard performance measures.
I want to see the industry report publicly about how they are performing. Eventually, I want each company to make its performance figures available. In that way managers will be judged not only by my inspectors, but by their peers and the public.
Industry leaders being unequivocal in their commitment to address the increase in HCRs will be an important early indicator of their willingness to show the necessary leadership.
Q: You also said you would be targeting the work of your inspectors differently. What will this mean?
A: As well as focusing on the issues I’ve mentioned, we will be using measures of inherent hazard (effectively the number of people at risk if a catastrophic fire or structural failure happens), performance data from previous inspections and other strategic factors to select the operators and installations that my inspectors will visit.
Q: Does that mean some installations won’t be visited?
A: Yes. I want to make the biggest impact where it is most needed. And, as I said, we are not usually talking about getting something new done. It is about making sure that common, well-understood precautions and procedures are in place and working as they should.
Too often, we make improvements and industry has taken initiatives, but practice has been allowed to slip. I want us all to concentrate on making improvements where they are most needed and then making them stick.
Q: You have kept coming back to major accidents, accidents in which several people could be killed or injured. What about day-to-day safety, isn’t that important anymore?
A: Yes of course it remains important. Any death or injury is terrible and must be avoided. However, the risk of being injured in a fall, slipping, straining your back or being affected by chemicals offshore is lower than in the majority of workplaces onshore. These risks are already well-managed offshore, so I want my inspectors to deal with the major accident risks.
Q: So operators can just ignore these issues?
A: No, they must continue to comply with the law. My inspectors will also continue to investigate complaints from workers, incidents and cases of ill health, so if standards slip we will take action.
In addition, if anyone is killed offshore, whatever the circumstances, we will work with the Police to investigate. If a manslaughter case is justified it will be referred to the Procurator Fiscal.
No one should think that personal safety issues are less important, it is simply that I believe my inspectors can add greater value by dealing with the major hazard issues.
Q: This all sounds fine, but how does it fit with making sure that we keep jobs offshore and that companies can make a profit?
A: I have never seen a real conflict between safe production and sustained profitability within a business. Good health and safety and good profitability both come from having the right people doing the right things at the right time.
Both need managers to understand and analyse their businesses and take a long view of the risks and then to act to manage them.
Sir Ian Wood addresses many of the themes I have mentioned, asset integrity, clear business metrics, taking a long-term approach, working together, in his recent report about maximising oil and gas recovery from the UKCS.
I think this shows Energy Division’s strategy is attacking the right things and that getting health and safety right supports the continuing success of the UK oil and gas industry.
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