Transcript Current Regulations for Offshore Safety

Current Regulations for
Offshore Safety
Cory WJ Sutherland
February 10th, 2011
www.intertek.com
Nuclear and Aerospace Industries
Heavily regulated due to
consequences of failure
•3 Mile Island
•Chernobyl
•Challenger Disaster
•Airline Crashes
Much of what we can learn about risk, maintenance, inspection
and the safe operation of equipment comes from these industries.
Creation of Institute of Nuclear Power Operations (INPO)
www.intertek.com
Regulatory Success
Boiler Injuries/Deaths
Aircraft Crashes
www.intertek.com
1984 UCC Facility - Bhopal, India
Introduction of water into large tank containing methyl isocyanate
Exothermic reaction - vapors vented to atmosphere
Scrubbers and flares not working
Tons of MIC escaped
20,000 people sickened
2,000 dying within weeks
Many more died later
Resulted in the Chemical Industry’s
Responsible Care Program
www.intertek.com
OSHA CFR 29. 1910.119
PROCESS SAFETY MANAGEMENT OF
HIGHLY HAZARDOUS CHEMICALS (1992)
1) Employer Participation
.
2) Process Hazard Information
3) Process Hazard Analysis
4) Operating Procedures
5) Employee Training
8) Mechanical Integrity
6) Contractors
7) Pre Start-Up Safety Review
9) Non- Routine Work Authorization
10) Managing Change
11) Investigation of Incidents
12) Emergency Preparedness
www.intertek.com
13) Compliance Audits
+ EPA Risk Management
14) Trade Secrets
Program (RMP) 1996
Loss Curve – Chemical Industry
www.intertek.com
BP Texas City
BP Isomerization Unit
www.intertek.com
Intertek Asset Integrity Management
Process
& Operations
Monitoring
Business & Finance
Information Technology
Training
Regulations
Asset Integrity
Management
Inspection
Materials
Maintenance
HSE
Management
www.intertek.com
QA
Design
A.I.M. Evolution
Best Practice Facilities
“A comprehensive, fully integrated, strategy, process and
culture directed at gaining greater lifetime effectiveness,
value, availability, profitability and return from production
and manufacturing assets”.
Risk / Reliability Assessment, Control and Management are
Essential to Successful Asset Management.
www.intertek.com
Offshore Industry – Wake up call
Piper Alpha – 1988
•Death of 167 personnel
•2 year public enquiry
•Resulted in 106 recommendations
•Regulation of Offshore Industry Transferred to HSE
www.intertek.com
Offshore Installations Safety
Case Regulations (OSCR)
•By 1995 every offshore installation possessed a safety case that had
been accepted and approved by the HSE
•Each safety case demonstrated that the company had a safety
management system in place and had identified risks and reduced
them to acceptably low levels (ALARP)
•Early lessons in applying safety case included:
Excessive complexity
Reliance on quantitative risk assessments
Lack of workforce involvement
•In 2005 OSCR was revised in order to enhance the safety cases
value to the operator. Opinion is that the safety case and using a risk
based approach is successful and now is used in UK, Norway and
Canada
www.intertek.com
Risk Management of Offshore Events
High
L
High Likelihood
High Likelihood
Negligible Consequence
High Consequence
I
k
e
l
I
h
o
o
d
Low Likelihood
Low Likelihood
Low Consequence
High Consequence
Low
Negligible
Consequence
www.intertek.com
Very Serious
ALARP
www.intertek.com
US Offshore Industry
1978 MMS formed - Regulatory Oversight of Offshore Drilling and Collecting
Revenue
1991 Published Notice requesting comments on strategies to promote safety
and environmental protection, specifically a requirement that outer continental
shelf operators develop and maintain and implement a “Safety and
Environmental Management Program”(SEMP)
API asked MMS to postpone action so it could develop an offshore safety
standard 1993 API published a Recommended Practice guidance document
(API 75)
1996 MMS conceded that the best it could do was to encourage voluntary
compliance with SEMP
At the time of the BP blowout, about 20 years later, MMS still had not published
a rule mandating all operators to have plans to manage safety and
environmental risks
www.intertek.com
API RP 75
•Objective of this Recommended Practice (RP) is to form the basis for a
Safety and Environmental Management Program (SEMP)
•Original document (1993) did not cover standard safety management or
drill rigs (current edition is from circa 2004)
•Recommended Practice, use of “should” or “may” (i.e. “not
compulsory”)
•Has been utilized by MMS to evaluate companies
•Discusses all phases of life cycle:
•Design, Construction, Start up
•Operation, Inspection Maintenance
•Linked to other API RP’s
www.intertek.com
BP Horizon – GoM
April 20, 2010 Deepwater Horizon Blow-Out/Loss-of-Control/Ignition
The incident resulted in 11 deaths on the platform and injured 17 others
On July 15, the leak was stopped by capping the gushing wellhead, after it had
released about [est.] 4.9 million barrels (780×10^3 m3), or 205.8 million gallons
of crude oil.
www.intertek.com
Government Response
On 15 June, the President articulated a three-part response plan to the Gulf oil spill:
•Environmental cleanup
•Development of a recovery and restoration plan
•Steps to ensure that disaster like this does not happen again (National Commission)
On May 27, after a 30-day interagency examination of deepwater drilling operations,
Secretary Ken Salazar directed MMS to issue a six-month moratorium on all drilling at a
water depth of more than 500 feet in the GoM and the Pacific Ocean.
The Department lifted the moratorium on October 12, seven weeks ahead of its scheduled
November 30 expiration.
On September 30, a few weeks before lifting the moratorium, the Department promulgated
new regulations on topics such as well casing and cementing, blowout preventers, safety
certification, emergency response, and worker training.
www.intertek.com
Minerals Management Service
Not long after the tragedy, its repercussions shifted to the Minerals Management Service
(MMS), the Federal Agency responsible for overseeing the well’s drilling and operation.
Nineteen days after the rig sank, Secretary of the Interior Ken Salazar announced his
intention to strip MMS’s safety and environmental enforcement responsibilities away
from its leasing, revenue collection, and permitting functions, and to place the former
within a “separate and independent” entity.
A week later, he announced MMS would be reorganized into three separate entities with
distinct missions:
•Bureau of Ocean Energy Management;
•Bureau of Safety and Environmental Enforcement;
•Office of Natural Resources Revenue.
By June 19, Ken Salazar had discarded the “MMS” name altogether.
www.intertek.com
June 2009 – MMS 30 CFR Part 250
MMS Proposes that Operators develop and implement a Safety and Environmental
Management System (SEMS) to address oil and gas operations in the Outer Continental Shelf.
The MMS analyzed accidental panel reports, incident reports and non compliance and
determined that the root cause of most safety and environmental accidents is caused
by four elements.
The SEMP program would therefore consist of four elements:
•Hazards Analysis
•Management of Change
•Operating Procedures
•Mechanical Integrity
www.intertek.com
30 CFR Part 250
In addition to the Industry complying with the 4 elements
and electing to model their SEMS Program after a
comprehensive SEMS program like API RP 75, lessees and
operators are also encouraged to consider implementing
ISO 9001 and ISO 14001
The proposed rule will also require operators to have their
SEMS program audited at least twice every 3 years by a
qualified, independent 3rd party
www.intertek.com
National Commission Report
Lessons Learned – Industry, Government, Energy Policy
•Changing business as usual
The record shows that without effective government oversight, the offshore oil and gas
industry will not adequately reduce the risk of accidents, nor prepare effectively to respond in
emergencies
•Absence of Adequate Safety Culture in the Offshore U.S. Oil and Gas Industry
•API , (Expert or Advocate)?
•Learning from Accidents
•INPO for Oil
•Self-Policing Safety Organization for the Oil and Gas Industry
•Challenge of Change
www.intertek.com
Some of the Overlapping Authorities,
Regulations and Players
•MMS
•API
•US Coast Guard
•EPA
•DOT
•NOAA
•Army Corps of Engineers
www.intertek.com
Future – “What Could Be”
Initially, a delay [for Revised Regulations & Enforcement] is likely due to
reorganization of MMS
May include Mandated [Compulsory] Inclusion of all 12 elements (such as OSHA
1910.119 PSM)
May include Safety Case Approach (i.e. OSCR Framework)
Inevitably the Industry will become more Prescriptive with Verification of
Compliance by 3rd party audits
Needs understanding and expertise in all AIM elements, including Software
Tools, Human Factors [experience], and education in Behavioral Safety.
www.intertek.com
For More Information
Please Visit Our Website
www.intertek.com
THE DIFFERENCE BETWEEN THE AVERAGE
PERFORMER AND THE PACESETTER IS:
THE PACESETTER IMPLEMENTS.
www.intertek.com