FEATURES
 

DEEPWATER HORIZON
Deepwater Horizon - What Have we Done to Deserve This
Deepwater Horizon - After the BP Report
Deepwater Horizon - The Investigation
The Deepwater Horizon and the Late MMS.
The Deepwater Horizon - PR and Politics
The Deepwater Horizon - Forces at Work
The Deepwater Horizon - Where Are We Now?
ROVs, Risers and Mud
The Deepwater Horizon - Later
Something about the Deepwater Horizon Accident
Channelling the Oil Leak
Preventing Fires and Explosions on Offshore Installations

OTHER ACCIDENTS
The Costa Concordia Grounding
The Loss of the Normand Rough
The Bourbon Dolphin Accident
The Loss of the Stevns Power
Another Marine Disaster
Something About the P36
The Cormorant Alpha Accident
The Loss of the Ocean Express

OPERATIONS
The Life of the Oil Mariner
Offshore Technology and the Kursk
The Sovereign Explorer and the Black Marlin

SAFETY
The ALARP Demonstration
PFEER, DCR and Verification
PFEER and the Dacon Scoop
Human Error and Heavy Weather Damage
Lifeboats & Offshore Installations
More about PFEER
The Offshore Safety Regime - Fit for the Next Decade
The Safety Case and its Future
Jigsaw
Collision Risk Management
Shuttle Tanker Collisions
A Good Prospect of Recovery

TECHNICAL
The History of the UT 704
The Peterhead Connection
Goodbye Kiss
Uses for New Ships
Supporting Deepwater Drilling
Jack-up Moving - An Overview
Seismic Surveying
Breaking the Ice
Tank Cleaning and the Environment
More about Mud Tank Cleaning
Datatrac
Tank Cleaning in 2004
Glossary of Terms

CREATIVE WRITING
An Unusual Investigation
Gaia and Oil Pollution
The True Price of Oil
Icebergs and Anchor-Handlers
Atlantic SOS
The Greatest Influence
How It Used to Be
Homemade Pizza
Goodbye Far Turbot
The Ship Manager
Running Aground
A Cook's Tale
Navigating the Channel
The Captain's Letter

GENERAL INTEREST
The Sealaunch Project
Ghost Ships of Hartlepool
Beam Him Up Scotty
Q790
The Bilbao OSV Conference

THE UK OFFSHORE SAFETY CASE AND ITS FUTURE

THE PUBLIC ENQUIRY

As a result of the accident on Piper Alpha on 6th July 1988 when 165 people died a Public Enquiry was held under the chairmanship of Lord Cullen, a Senator of the College of Justice in Scotland. The enquiry sought to answer two questions

1.         What were the causes and circumstances of the disaster on the Piper Alpha platform on 6th July 1988, and

2.         What should be recommended with a view to the preservation of life and the avoidance of similar accidents in the future.

Up to that time offshore structures both mobile and fixed had operated under the “Mineral Workings (Offshore Installations) Act 1971" under which a number of Statutory Instruments were added to the original legislation, all of them being policed by the UK Department of Energy and the Department of Transport.

The enquiry’s findings are contained in two volumes and resulted in 106 separate recommendations. The first 13 of the recommendations relate directly to the provision of a Safety Case for every offshore installation whether fixed or mobile. 

Lord Cullen had borrowed the concept of the Safety Case – making the case for safety – from the nuclear industry. Here it had been deemed essential that all risks should be identified and means found to reduce them to a level considered to be as low as reasonably practicable. It was necessary in the nuclear industry since an accident could result in fall-out over a large area, with consequent deaths in the community. Subsequent to the Flixborough chemical accident in 1974 Safety Cases were also introduced for chemical plants.

The recommendations contain the following statements, which are particularly pertinent to the manner in which the risk assessment is carried out and the resulting recommendations acted on:

2.ii       that the potential major hazards of the installation and the risks to personnel thereon have been identified and appropriate controls provided.

4.ii       A demonstration that so far as is reasonably practicable the exposure of personnel on the platform to accidental events and their consequences has been minimised.

The words  “so far as is reasonably practicable” are derived from the ALARP principle which states that risks must be “as low as is reasonably practicable.”

These statements indicate the requirement for the industry to move from a prescriptive form of legislation to a goal setting form of legislation.

The Cullen Enquiry recommendations typically target SI611, which deals with fire and explosion risk and mitigation, for revision under goal setting legislation asfollows:

50.       The regulations and related guidance notes should promote an approach to fire and explosion protection:-

i.          which is integrated as between –

-         active and passive fire protection

-         different forms of passive fire protection such as fire insulation and platform layout and

-         fire protection and explosion protection.

ii.         in which the need for, and the location and resistance of, fire and blast walls is determined by safety assessment rather than by regulations.

iii.        in which the function, configuration, capacity, availability and protection of the fire water deluge system is determined by safety assessment rather than by regulations.

iv.        which facilitates the use of scenario based design method for fire protection as an alternative to the reference area method.

v.         which provides to a high degree the ability of the fire water deluge system, including the fire pump system, to survive severe accident conditions.

The above is an example of the manner in which Lord Cullen required the industry to move from prescriptive legislation to goal setting legislation. It is also an illustration of the manner in which the recommendations, and subsequently the legislation, concentrates on accidents to fixed platforms. This bias has required considerable interpretation of the legislation on the part of the operators of mobile units and also considerable interpretation by the HSE assessors of the mobile unit Safety Cases.

THE SAFETY CASE LEGISLATION

As a result of the Cullen recommendations the HSE were appointed as the single regulatory body for offshore safety, and the HSE legal departments framed the Safety Case Legislation in a manner which followed the Cullen recommendations for goal setting legislation and which also caught some existing prescriptive regulations.

The resulting statutes are as follows:

Offshore Installations (Safety Case) Regulations 1992

Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995

Offshore Installations and Wells (Design and Construction, etc) Regulations 1996.

Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995.

The Safety Case regulations require that the Safety Case should demonstrate the following:

i)          that the management system is adequate to ensure compliance with the statutory health and safety requirements.

ii)         that adequate arrangements have been made for audit and the preparation of audit reports.

iii)        that all hazards with the potential to cause major accidents have been identified, their risks evaluated, and measures taken to reduce risks to persons to as low as reasonably practicable.

In particular to deal with item iii) MMASS have developed a comprehensive means of identifying and assessing risks and determining means of reducing the risks to ALARP (As Low As Reasonably Practicable). The means involves a qualitative study carried out by a team on board the Installation and a quantitative study to calculate the level of risk for each identified major accident hazard.

The Safety Case Regulations were well in place and the first versions of all Safety Cases presented when the PFEER (Prevention of Fire and Explosion and Emergency Response) Regulations came into force in 1995.

There are some who consider that the PFEER Regulations do nothing to improve on the Safety Case Regulations, however they do emphasise certain aspects, particularly the requirement for performance standards. The introduction to the PFEER Regulations contains the following:

8.         PFEER Regulation 5 specifies requirements for a fire and explosion and evacuation escape and rescue assessment. The results of that assessment will contribute to the demonstration required by the Safety Case Regulations.

9.         In addition the PFEER Regulations specify goals for preventative and protective measures for managing fire and explosion hazards, and emergency response. Complying with these Regulations, taking into account the practical guidance contained in this publication, will facilitate HSE’s acceptance of the Safety Case. The regulations are in general expressed as broad goals rather than specific requirements, allowing the duty holders the flexibility to develop detailed arrangements in the light of hazards, plant configuration and other circumstances specific to the installation.

To summarise, the PFEER Regulations require operators to assess the measures in place to prevent, prepare for and mitigate major accidents in terms of personnel, procedures and systems.

The “systems” component is the identification of Safety Critical Elements which must be assessed in terms of functionality availability and survivability.

Broadly operators, including the owners of mobile units, are required to set their own standards for safety critical equipment and ensure that the equipment installed on their units are up to that standard. The equipment must fulfil the required function, it must be reliable and it must be able to survive. The standards used can be taken from any suitable source or can be written specifically for that equipment. For instance mobile unit operators are likely to chose API RP53 as the standard for drill through equipment, and the SOLAS Regulations as the standard for its Lifesaving equipment.

Despite initial argument by some operators that the Safety Case already contained a PFEER Assessment, due to some pressure from the HSE this document is now almost always presented separately. If the compiler rigorously follows the regulations it will contain descriptions of the scenarios and demonstrations of the relationship between the personnel, systems and procedures and suitable check-lists to ensure that all requirements are fulfilled.