Keeping Your House in order? A view on Safety Reviews from UK Offshore experience Ian Wright Business Development Director, Upstream DNV Energy, Europe & North Africa March 2009
Introduction Safety Performance achieved is the result of the combined activities performed by the company with ultimate accountability for safety and, those companies with delegated responsibilities - Impact of Regulator for the region compliance required - Impact of external scrutiny from pressure groups and Non Government Organisations - compliance + communication of performance required - Impact on Business performance Internal and Shareholder - Plan / Do / Check / Act - Production, Safety, Environment - Optimised cost - compliance +++ Feedback from UK offshore experience and developments and how to get more benefit from Verification / Certification safety activities
Introduction Independent Verification / Certification of Safety Critical Systems and limitations of the process Audits of supporting management systems and the benefits when combined with Verification / Certification Feedback from offshore assessments
Development of the UK Offshore Legislation The Piper Alpha Disaster July 1988-165 personnel of 226 on board and two rescue personnel died The Cullen Enquiry into the Piper Alpha Disaster Recommendations for - Requirement for a safety case - Requirement for a management system and audit - Repealing of prescriptive legislation - Clarification of safety responsibilities
The UK Offshore Safety Case Regulations Safety Case must Demonstrate: Management system Audits Identification of Hazards Evaluation of risks Measures to ensure ALARP PFEER Summary (added later) Verification of Safety Critical Elements Safety Case Regulations updated
Definition of Major Accidents (SCR) Paraphrased but effectively: Death or serious personal injury due to fire, explosion or dangerous substance release major damage to structure or plant, or loss of stability of the installation helicopter collision failure of diving operations life support systems, detachment of a diving bell or trapping of a diver any event involving death or serious personal injury to 5 or more people
The Design & Construction Regulations Defined Safety Critical Elements: - Safety-critical elements" means such parts of an installation and such of its plant (including computer programmes), or any part thereof - (a) the failure of which could cause or contribute substantially to; or - (b) a purpose of which is to prevent, or limit the effect of, - a major accident; Effectively plant and safety instruments, equipment and systems or, hard barriers Supporting Processes are not SCEs, e.g. operations, maintenance, inspection processes
SCEs and Managing Major Accident Risk Design>Procure>Construct>Hook-up>Commission>Operate>De-commission Eliminate>Prevent>Detect>Control>Mitigate>Rescue>Recover Layout Process containment Ignition prevention ESD Structure Preventative support processes Operations Planned Inspection Safety Fire & Gas Detection Blowdown system Planned & Corrective Maintenance Planned Assurance activities Passive Fire protection ESD Alarm & PA system Critical Fire Fighting equip. Temporary Refuge Escape equip TEMPSC Elements Safety boat
The Safety Case & Verification Scheme Hazard Management and Verification by Independent Competent Person ICP Comments on the record ICP comments on the content Hazard Analysis Define Major Accident Hazards Means of managing risks 1 Hydrocarbon Containment 2 Primary Structure 3 SMS 4 ESD 5 F & G Systems etc etc... 6 7 8 9 10 11 SCE Record Assurance processes Safety Case Performance Standards Verification Scheme 1
Typical Performance Standard Contains Envelope of equipment included & boundaries Description of specific safety function and risk management objective Measures for - Functionality - Availability - Reliability - Survivability Interactions and dependencies Often combined with assurance and verification activities
What Exactly is Verification by ICPs? Ensuring SCEs are suitable (Hardware) Examination by Independent Competent Persons - Inspect - Test - Review documents - Discuss with personnel Remedial Actions Recommended (RAR) Not the normal Assurance activities A review by a fresh set of eyes
How the Verifier works Example Verification task - Fire-pump compliance with Performance standards requirements Inspection Test - Clean, tidy, all movable equipment in its place, equipment tagged - Starts in accordance with spec., delivers steady pressure and flow rate with margin, signs of stable operation and no visible concerns Document review - No procedure for testing, No records of previous tests / maintenance / inspection Discussion - Technicians demonstrate competence and understanding of maintenance performed during talks - Advise that there is no expectation to complete records / own logbooks used by some / not trained to use maintenance software / no one ever checks the records Did it meet the Performance Standard? What does the Verifier do?
How the Verifier works It met the Performance Standard Pass but the Verifier is left with uncertainty - Signs of good culture and maintenance but only because of the good plant and people - Failings in the Process there may be: - Lack of review of maintenance records? - Lack of auditing? - Lack of process safety leadership? - Reliance on People and Plant and, Process barrier may be impaired Experienced surveyor should normally raise general comment
One View of MAH management Process Containment Fire Detection Management System Training Ignition Prevention PFP Maintenance Spares Inspection Emergency Shutdown Fire Fighting Safety Culture Competence
The UK HSE KP3 Programme HSE Launch of Regulatory Programme in 2004 - KP3 Protocol question sets for onshore & offshore assessments Benchmarking through traffic light status & regulatory action where required
Introduction 2005 - DNV introduced a service to assist operators to create improvement programmes using the HSE s KP3 protocol In depth assessments carried out at the invitation of 5 operators of the systems supporting maintenance functions onshore and offshore between January 2005 and March 2008 15 reports produced for onshore & offshore locations with specific key findings and relevant recommendations 178 interviews with key personnel supporting maintenance activities onshore and offshore The application of this assessment provided a review by an Independent party of the functions supporting the soft barriers and impacting on the consequential performance of hard barriers
Assessment Methodology All assessments were initiated by Duty-holders (often HSE managers) Scope: Use KP3 Maintenance Management System Templates (Offshore & Onshore) provided by HSE Review Management system, relevant procedures, process maps, organisation charts, job descriptions, etc. Conduct series of interviews with targeted personnel using templates - Between 10 and 20 interviews onshore - Up to 10 interviews offshore Examine Maintenance records including analysis reports & references Note - Testing was not carried out
Assessment Methodology 2 Team of 2 interviewers + Company representative Extract key findings for onshore and offshore perspectives by normalising responses and checking against data gathered from interviews Draft reports for Onshore and Offshore assessments Discuss and agree findings / recommendations and issue report Company developed a plan to create improvements
Personnel Interviewed A total of 178 interviews over 3 years onshore and offshore Personnel responsible for supervision, control and execution of work Those interviewed were the key personnel with knowledge of the issues - Maintenance Managers - Operations Shift Team Leaders - Technical Authorities - Asset managers - OIMs - Offshore Inspection Engineers - Operations Superintendents - Lead Discipline Operations Technicians - Operations Technicians - Maintenance Team Leaders - Lead Discipline Maintenance Technicians - Maintenance Technicians
Leadership for Asset Integrity Management Recognition by operators of the different backgrounds amongst board members Need for understanding of AIM to support successful business Through Oil & Gas UK and Step Change CEOs and COOs of Operators have signed up to the completion of an appreciation and learning process
Example of Template for interviews INSTALLATION DATE(S) INSPECTOR(S) Persons interviewed Position Offshore B Communication between onshore support staff and offshore maintenance technicians 1. Who are the technical authorities, discipline engineers and onshore support team for your installation? 2. How often do you have contact with them? How often do you meet them on the installation? What do you talk about? RELEVANT LEGISLATION MHSWR 5 Arrangements for effective planning, organisation, control, monitoring and review of preventive and protective measures NON COMPLIANCE / MAJOR FAILING ISOLATED FAILURE / INCOMPLETE SYSTEM IN COMPLIANCE / OK NOT TESTED / NO EVIDENCE Duty Holder Response:
HSE Definitions Non-compliance Major failing (HSE may consider Regulatory action) (DNV assessments used Red to differentiate criticality) Isolated failure Incomplete system In compliance Not tested OK No evidence
Overall Summary of DNV Assessments 2005/08 Cat Title on=onshore, off=offshore Sum 1 on 2 on 3 on 4 off 5 off 6 off 7 off 8 on 9 on 10 off 11 off 12 Off 13 on 14 off 15 off A Maintenance basics N/A N/A N/A N/A N/A N/A N/A N/A N/A B C D E F G H I J K L Communication between onshore support staff and offshore maintenance technicians Competence of maintenance technicians and their supervisors Maintenance of Safety Critical Elements (SCE) Supervision Recording of completed maintenance work Backlogs Deferrals Corrective maintenance Defined Life Repairs Measuring the effectiveness of the maintenance system Measuring compliance with performance standards N/A N/A N/A N/A N/A N/A N/A N/A N/A M Measuring the quality of maintenance work N/A N/A N/A N/A N/A N/A N/A N/A N/A N Verification N/A N/A N/A N/A N/A N/A N/A N/A N/A O Review of ICP recommendations N/A N/A N/A N/A N/A N/A N/A N/A N/A P Reporting to Sen Management on IM status N/A N/A N/A N/A N/A N/A N/A N/A N/A Q Key indicators for maintenance effectiveness N/A N/A N/A N/A N/A N/A N/A N/A N/A System test of SCE N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N?A N/A N/A Condition of Plant N/A N/A N/A N/A N/A N?A
Learnings about the assessment process KP3 was simply a catalyst for discussion people talked widely & openly an independent and impartial assessment team helped Local coordinator for interviews was essential two assessors were necessary to capture findings identify key learnings at the end of each day Confirm learnings by testing in subsequent interviews Not all interviews were successful need for normalising - Some talked defensively about what the intent was rather than the issues - Some showed a strong bias to specific issues Significant improvement programmes were created as a consequence
Key Findings General Points - Many, but not all, of the issues found from the assessment seemed known but not properly stated / recognised / understood / appreciated - The assessment process helped clarify and agree these known issues - Evolution of separate cultures on/offshore to varying degrees was a key issue - Consistent and strong wish for clear communication of findings of assessments both on and offshore - Seen as a vehicle to create change and help focus improvement - Initiated by companies wanting to improve understanding of their weaknesses and enhance performance through the development of actions plans in addition to fear of regulation (usually unduly) - In some cases findings were reviewed by the HSE and only limited regulatory reviews carried out