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THE OFFSHORE SAFETY REGIME – FIT FOR THE NEXT
DECADE
On
27th November the Oil Industry in the UK held a one day conference to
consider the future of the Safety Case.
It started with breakfast. Disappointingly there
were no fried eggs, and so those of us who now normally eat a healthy breakfast
due to pressure from our partners or sheer laziness, were unable to experience
the delights of an egg yoke running over, and soaking the fried bread . Indeed
it is possible that this risky activity had been banned on health grounds.
Never-the–less some of us were able to have scrambled egg, sausage and bacon and
consume them while listening to Des Brown, Minister of State, Department for
Work and Pensions. Apparently his is the department ultimately in charge of the
HSE and so has an interest in the way in which the regulations may change, and
therefore the proceedings of the conference. Unfortunately Mr Browne himself had
urgent appointments elsewhere and had to leave after the breakfast, but other
very important people from the HSE remained to generally support the safety case
regime and to take the flack from the members of UKOOA and IADC who were
present.
The conference itself actually took the form of
four separate sessions with panel members speaking on a topic and then questions
and comments being encouraged from the floor.
First of all some-one from the HSE spend half an
hour telling us the regulations were going to change, and then telling us what
the changes would be. The delegates also had a revised set of regulations to
look at. There are really two big changes proposed. The first is that the safety
case review periods should be changed from three to five years, and the second
is that the combined operations safety case should be a part of the normal
safety case.
After this presentation we heard four discussions
from the podium, the first titled “Is the Safety Case Regime Fit for Purpose?”,
the second entitled “Who is the Safety Case For?”, the third entitled
“Accountabilities and Working Together” and the fourth “Making the Safety Case
Regime Work”.
“Hang on!”, I hear you say, “what’s happened to
the new regulations. Is no-one going to discuss them?”
Surprisingly the answer is no, apart from various
remarks by HSE personnel about how the reduction in the frequency of review
would give the HSE inspectors more time to get out there and meet people and
keep up with what was going on. And probably nothing much would be different in
three years anyway. In truth it was quite difficult to relate the proposed new
rules to the conference.
Mind you, we were impressed by the presence of a
number of very important people including Timothy Walker, Director General of
the HSE, who chaired one of the discussions, and Margaret Burns Commissioner,
Health and Safety Commission, who chaired another.
The discussions themselves really dealt with two
themes, the first that there was insufficient worker consultation and the second
that there were too many Issue Notes, and if you have read this far without
already having an intimate knowledge of the issues and the safety case regime in
general it would seem appropriate to offer both congratulations and a bit of
information about the background.
The Safety Case Regulations and their Guidance
have always prompted the owners of Installations to consult with the workforce
on the various aspects of the safety case, but the problem is that the safety
case is a very technical document and its development has become very
specialized, to the point that most operators find that it is essential to use
safety professionals – probably on a subcontract basis. The two main parts of
the document, the technical description and the risk assessment, take research
and calculation respectively and neither task can be taken on lightly.
Describing the components of offshore installations in words is often difficult
and even though drawings are always included, even reading a drawing takes
practice.
The risk assessment process is even more
difficult. Lord Cullen required that “suitable and sufficient QRA” should be
undertaken to determine the level of risk to persons on the installation, and
doing QRA is even more specialized. The results, expressed in terms such as
“10E-3” are even less accessible than the technical description. Hence it seems
unrealistic not to use specialists and it is difficult to consult with the
workforce.
The second problem – Issue Notes – relates more
to the cost of the HSE services than the Issue Notes themselves. All Safety
Cases must be reviewed by each of the specialist topic units in the HSE and so a
dozen Safety Cases will be printed by the dutyholders and taken to the HSE
Offshore Safety Division headquarters, Lord Cullen House. Subsequently the
assessors will start to ask questions about the safety case. These are Issue
Notes. Answering Issue Notes used to be the only cost for the dutyholders,
although they found this onerous enough, requiring as it did, more specialist
input. But now the HSE charge for their services by the hour, so the more Issue
Notes there are, the higher the cost. And the cost of an HSE assessor is about
£160 per hour. Even the assessment of a safety case which creates no Issue Notes
costs several thousand pounds.
Several of the speakers, within the general Issue
Note exchange, brought up the subject of assessor hobbyhorses, and here there
does seem to be a real problem for the HSE to solve. Any of the assessors are in
a position to stop the safety case acceptance process dead in its tracks if they
raise a Level 1 Issue Note, and in reality it could be about anything, because
there is no means of appeal for the dutyholders. This interaction goes like
this:
The assessor asks that a particular risk or
problem or statement be addressed. The dutyholder is reluctant to do the
required work. The assessor says that if it is not done the safety case will not
be accepted. Since we would now be about five weeks from the dropdead date,
after which the installation would be unable to operate due to lack of an
accepted safety case, the dutyholder has no option but to comply.
HSE hobbyhorses would probably make a separate
article on their own, but a couple are the use of the personnel basket for
evacuation and the 10,000 year storm. I am tempted to go further into this, but
suffice it to say that Taf Powell, head of the HSE OSD said they would look into
it.
Getting back to the worker consultation then, and
the spectre of the Safety Case “gathering dust” on the OIM’s office shelving
instead of being thumbed through constantly be interested workers. This topic
seemed to be a cue for the trades unionists to have a bit of a go at the
operators, possibly the most vocal being Roger Spiller the General Secretary of
Amicus who spoke from the floor. Jake Malloy of OILC also spoke from the podium
within the session “Who is the Safety Case For”. Of course these guys were less
inclined to talk about the safety case than about the perceived wrongs being
done to the workforce which would be unlikely to be corrected even if a
representative number of the installation crew committed the safety case to
memory.
It generally makes you wonder where it is all
going. Correct me if I’m wrong but we seem to be advocating a reduction of HSE
input, from the guys who actually understand what the safety case is about and
will be able to tell whether a case for safety is actually being made, and an
increase in the input from the workforce who will only know whether a case for
safety is being made if they understand the numbers. If they do understand the
numbers they will probably be safety engineers. If I were a member of the
workforce I would be inclined to put my trust in the HSE.
The last session was called “Making the Safety
Case Work” within which Ciaran McIntyre, who is some-one very important in
Lloyds Register, contrasted some of the industry golden rules with other lesser
rules. He suggested that rules such as no-one carrying knives offshore, no-one
carrying matches offshore are never broken, where-as rules such as not letting
fire pumps go down are often broken. Absolutely no-one commented on his speech,
which may have been a failure on the part of the facilitator. But it was a
statement which followed up on a representation made to the HSE by the
classification societies that Verification is not working.
And if you find yourself asking what verification
is, it may be best to have a look at last month’s feature about the Ghost Ships
of Hartlepool because everybody seems to understand about the environment.
As well as the large numbers of oil industry
people from the UK, the conference was also attended by personnel from Norway,
Australia, Denmark Holland, America, and the Faeroes. What they made of it all
I can’t imagine.
Vic Gibson December 2003 |
