Offshore safety management systems

Although the SEMS rule has legal application only on the United States OCS, an understanding of what it is and how it is applied is pertinent to offshore facilities anywhere in the world because it is representative of offshore Safety Management Systems in general. Also, because many of the major oil companies are U.S.-based, they tend to use American regulations as a basis for aU of their safety work, regardless of location. 

The UK government enquiry into the Piper Alpha disaster in the North Sea in 1988 has had a significant impact on working practices and equipment and has helped to improve offshore safety around the world. One result has been the development of a Safety Management System (SMS) which is a method of integrating work practices, and is a form of quality management system. Major oil companies have each developed their own specific SMS, to suit local environments and modes of operation, but the SMS typically addresses the following areas (recommended by the Cullen Enquiry into the Piper Alpha disaster) ... 

In addition to the developments of this book, other books in the same series have been published. Offshore Safety Management is now in its second edition and focuses on regulations, management systems, and technical issues to do with the offshore oil and gas business. Plant Design and Operations covers detailed topics, as can be seen from the chapter titles. 

The oil and gas industry has operated on the U.S. outer continental shelf (OCS) for decades, but the U.S. offehore wind industry is only now becoming established. At the time of this writing, offshore wind projects have received preliminary approvals from relevant federal agencies, but construction has not yet started. As mentioned in Chapter 3, the Bureau of Ocean Energy Management (BOEM) issued basic requirements for a safety management system (SMS) in Subpart H of 30 CFR 585 in 2009 but has not fully defined the substance to be included in an SMS. Chapter 4 identified many hazards shared by land-based and offshore wind farms and relevant federal regulations and industry standards that may apply, and it discussed several hazards unique to offshore wind farms. 

Minerals Management Service Technology Assessment and Research (TA R) Project 633, Template for a Safety Management System for Offshore Wind Farms on the OCS, October 2009 ... 

Moreover, the event revealed structural flaws in the safety management systems of offshore facilities. 

In order to reduce the number and severity of major events companies need to develop and implement a Safety Management System, or SMS. The details of an SMS vary from company to company and agency to agency, but they all tend to have broadly the same structure and content. In the United States, the agency responsible for offshore safety, the Bureau of Safety and Environmental Enforcement (BSEE), issued its Safety and Environmental Management System (SEMS) rule. The management elements of SEMS are shown in Table 1.2. 

Risk Management This first chapter provides an overview ot satety management in the offshore oii and gas industry. Trends within the industry are discussed, aiong with an assessment ot the impact of the Deepwater Horizon incident. A description of the different types of safety— occupationai, process and technicai —is provided, aiong with a description of Safety Management Systems. 

The development of fomal safety management systems for offshore oil and gas facilities can be said to have started with the Piper Alpha catastrophe that occurred in 1988. Offshore platforms had had safety programs before that time, of course, usually built around Safety Cases (described in Chapter 8). But Piper Alpha ushered in a new and much more thorough approach to system safety. 

There is no clear distinction between Partial and Full implementation. As has been stressed many times, virtually all offshore operators already have a Safety Management System in place. Therefore they can all be considered Partial, but some will be near the starting gate, whereas others may have a mature SEMP. The word Partial is not specific enough. 

Moreover, it is unlikely that the regulator will have a sufficient number of qualified people to fully evaluate the safety management system for each and every offshore facility. Indeed, that is why companies prepare their own safety system—only they fully understand the technology and systems on the platform or rig. 

But the impact of Deepwater Horizon/Macondo went beyond the United States the accident caused oil companies all over the world to think through the effectiveness of their safety management programs. Moreover, events such as the Montara blowout in Australian waters in the year 2009 showed that these events are not confined to one place. The contents of this book therefore go beyond the United States regulatory environment. The book describes some of the major offshore incidents that have occurred over the last 40 years or so, some of which occurred onshore, that led to the development of modem safety management systems and regulations. So, for example, it contains a thorough discussion of the Safety Case approach—a system that was first used in the North Sea but that has now spread to many international locations. 

The HSE internal document Proems safety management systems also identifies principles of process safety management. Although intended for process safety management of offshore installations, many of the principles are equally applicable onshore. Key points are ... 

The UK offshore industry has developed guidance for interfacing health and safety management systems between dutyholders involved in shared activities. The guidance deals with all the elements of an SMS including issues such as ... 

In the aftermath of the publication of the Cullen report (1990) on the Piper Alpha disaster, there was strong pressure to make far-reaching changes in the way in which offshore inspectorates carried out their role of regulation and inspection. One of Cullen s main recommendations was to shift the focus of inspection from the details of technical compliance to the establishment and assessment of safety management systems and safety cases. The Dutch government decided to follow this approach also. Working parties of SodM and industry representatives were set up to consider whether and how to implement Cullen s recommendations in the Dutch sector of the... 

Santos-Reyes, J., Santos-Reyes, D., Assessment of safety management systems in the oil and gas industry. Proceedings of the Offshore Technology Conference, 2002, pp. 1469-1485. 

SEMS and SEMP are not the only types of Safety Management Systems. Offshore facilities in other parts of the world, for example, develop through the use of safety cases. This chapter describes the structure of a typical safety case. Related topics, such as levels of acceptable risk, are also discussed. 

Probably the most important lesson from Flixborough for the offshore industries is that it is necessary to have a Safety Management System. The Flixborough accident did not occur because one or two of the elements of PSM/SEMS were badly implemented. It occurred because Nypro did not have a Safety Management System and because there was inadequate oversight of the industry on the part of the government regulators. 

The above situation still applies to some of the companies working offshore. For example, Table 5.4 in Chapter 5 shows that approximately half of the companies operating in the Gulf of Mexico (GoM) do not have a complete SEMP in place. This does not mean that they have nothing in the way of Safety Management Systems. Nevertheless it would appear as if there is substantial room for improvement. 

Yet, with respect to safety management systems, these differences are not nearly as profound as the similarities, as even the most superficial examination of the TMl shows. Indeed, as discussed in Chapter 4, the offshore oil and gas industry would appear to be... 

Contractors do not work in isolation—they have organizational and physical interfaces with the operator of the offshore facility and with other contractors. Since each company will have its own Safety Management System a bridging document is needed. This document is essentially a map that links the relevant sections of the different standards. So, if the operator s plan calls for start-up procedures, then the bridging document would show where the same iifformation is located in the contractors documents. 

The previous seven chapters of this book have demonstrated how much the offshore safety management business has changed and matured in the quarter century since the Piper Alpha accident. Yet, as the Deepwater Horizon and Montara events illustrate, more progress needs to be made, particularly with respect to process and technical safety. The industry has not yet arrived. No doubt ongoing application of the Safety and Environmental Management Systems (SEMS) and safety case techniques will lead to further improvement, yet there may also be a need to make a step change, and to find new ways of improving safety. 

This book has attempted to provide an overview of the topic of offshore safety management—with a particular focus on technical and process safety, and the avoidance of catastrophic events. The development of process safety management systems such as SEMS and technical safety systems, such as the Formal Safety Assessment part of safety cases, has been discussed in depth. Although it is diffictilt to pin down how much improvement such systems have generated, there can be little doubt that they have been effective at reducing the number and severity of offshore accidents. 

The Failure and Inventory Reporting System (FIRS) program was developed by the Geological Survey Division of the U.S. Department of the Interior for safety and pollution prevention devices on offshore structures that produce or process hydrocarbons. The program collected data on mechanical and some electromechanical systems on offshore oil platforms. About 8,000 failure events were documented. Access has been limited to internal materials management system use. No real-time access or periodic output products have been available. 

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