asset integrity 6th october 2015 - step change in safety · asset integrity steering group ......

Asset Integrity 6th October 2015 SPONSORED BY

LES LINKLATER, STEP CHANGE IN SAFETY

Welcome & safety brief

SPONSORED BY

HOW ARE WE DOING? INDUSTRY HCR PERFORMANCE

No. of leaks

0

50

100

150

200

250

300

Minor

Significant

Major

Total

2014-15 preliminary data

Agenda 08:30-08:40 Welcome and safety brief

08:40-09:00 Introduction from AISG co-chairs

Alan Chesterman (Apache) / Alan Johnstone (Amec Foster Wheeler)

09:00-09:30 A contextual from the Health and Safety Executive

Rog Thomson (HSE) / Andrew Taylor (DECC)

09:30-10:15 Learning and Sharing Work Group Update and Case Study

Ian Wright (Petrofac) / Hugh Bennett (Amec Foster Wheeler) / Roddy Smith (RGU)

10:15-10:45 Coffee Break

10:45 – 11:30 HCR Improvement and Implementation Work Group Update and Case Study

Andy Ewens (Amec Foster Wheeler) / Alan Blacklaw (Nexen) / Damon Bowler (Shell)

11:30 – 12:15

Major Accident Hazards Understanding Work Group Update and Case Study

Peter Hepburn (Maersk Oil) / Stuart Taylor (Apache) / Stephen O’Neill (Bilfinger Salamis)

12:15 – 12:30 Q&A All

12:30 Closing comments and networking Les Linklater 12:45 Lunch

ALAN CHESTERMAN (APACHE) ALAN JOHNSTONE (AMEC FOSTER WHEELER)

Asset Integrity Steering Group

SPONSORED BY

“Demonstrate that best practice is being identified and spread in an effective and transparent way and on an ongoing basis” “Secure a more strategically coordinated approach for the gathering and dissemination of lessons from incidents and standards of good/best practice within the UK regime and internationally”

Recommendation 4.2 Maitland Report (Dec 2011)

Aims

• promote and support hydrocarbon release (HCR) reduction

• help industry maintain facilities’ integrity and condition in compliance with performance standards

• promote application of best practice and industry learning from past major accidents

HCR Improvement & Implementation • Drive and support company / asset by asset

improvement actions • Identify & share MAH/HCR good practice • Monitor plan execution and performance impact

Learning & Sharing • Better sharing of information • Continuous application of past learning


Major Accident Hazard Understanding • Pan-industry education in “Major Accident Hazard

management” • Map how everyone plays their part, tailor learning

content to suit

Assurance & Verification • Update the existing guidance in line

with European Safety Directive

* Any learning from other industries? Visit to Sellafield

ANDREW TAYLOR, INSPECTORATE TEAM LEADER, DECC ROG THOMSON, PRINCIPAL INSPECTOR, HSE

Offshore Safety Directive (OSD)

SPONSORED BY

11 Offshore Safety Directive – DECC/HSE Presentation to AISG – 6th October 2015

Setting the Scene

Deepwater Horizon – 20 April 2010 – 11 workers killed. Pollution – 4.9 million barrels

EU Directive 2013/30/EU

• Commission's initial aim was a European Regulation covering offshore oil and gas

operations

• The decision to move away from a Regulation was due, in large part, to the

collaborative efforts of HSE, DECC and Industry

• Directive published 28 June 2013, and objective is to reduce as far as possible the

occurrence of major accidents relating to offshore oil and gas operations and to limit

their consequences

• Directive requires the establishment of a Competent Authority, and in the UK this

will be delivered by OSDR, a regulatory partnership between DECC and HSE

governed by an enhanced MoU

• Scope of Directive is vital to understanding the partnership Competent Authority and

the regulatory regime that has been introduced in the UK to transpose the Directive


Scope of Directive

Article 2(1) ‘Major Accident’ means, in relation to an installation or connected

infrastructure:

a) an incident involving an explosion, fire, loss of well control, or release of oil gas or dangerous substances

involving, or with significant potential to cause, fatalities or serious personal injury;

b) an incident leading to serious damage to the installation or connected infrastructure involving, or with a

significant potential to cause, fatalities or serious personal injury;

c) any other incident leading to fatalities or serious injury to five or more persons who are on the offshore

installation where the source of danger occurs or who are engaged in an offshore oil and gas operation

in connection with the installation or connected infrastructure; or

d) any major environmental incident resulting from incidents referred to in points (a), (b) and (c).

Article 2(37) ‘Major Environmental Incident’ means an incident which results, or is

likely to result, in significant adverse effects on the environment in accordance with

The Environmental Liability Directive

Scope doesn’t cover all of DECC’s or HSE’s regulatory responsibilities


Partnership Competent Authority


HSE Competent Authority DECC

Health and Safety at Work Design / Relocation Notification SEA

Occupational Safety Production Safety Case Environmental Impact

KP4 / Step Change Non-production Safety Case Habitats and Species

COSHH Well Operations Notification Chemical Use and

Discharge

RIDDOR Combined Operation Notification Hydrocarbon Discharge

COMAH Material Change Notification Geological Surveys

(Seismic)

GMO Verification Scheme Marine Licensing

Explosives CMAPP Etc., etc.

Etc., etc. Safety / Environmental

Management

Internal Emergency Response

Navigational Safety

DECC OGED Regulatory Framework


The Offshore Petroleum Activities (Oil Pollution Prevention &

Control) Regulations 2005 (as amended)

The Mercury Export and Data

(Enforcement) Regulations 2010

REACH Enforcement Regulations 2008

The Offshore Installations (Emergency Pollution Control)

Regulations 2002

The Merchant Shipping (Oil Pollution Preparedness, Response

and Co-operation Convention) Regulations 1998 (as amended) The Environmental Protection (Controls on Ozone–Depleting

Substances) Regulations 2011

The Fluorinated Greenhouse Gases Regulations 2015

The Offshore Chemicals Regulations 2002 (as

amended)

Pollution Prevention & Control Act 1999

The Offshore Combustion Installations (Prevention and

Control of Pollution) Regulations 2013

The Greenhouse Gas Emissions Trading

Scheme Regulations 2012

The Energy Act 2008, Part 4A Works

Detrimental to Navigation

The Offshore Petroleum Activities

(Conservation of Habitats) Regulations 2001

(as amended)

The Marine & Coastal Access Act 2009

The Environmental Assessment of Plans and Programmes

Regulations 2004

The Food and Environmental Protection Act

1985, Part II Deposits in the Sea

The Offshore Petroleum Production and

Pipelines (Assessment of Environmental Effects)

Regulations 1999 (as amended)

The Offshore Marine Conservation (Natural Habitats, &c.)

Regulations 2007 (as amended)

The Energy Savings Opportunity Scheme

Regulations 2014

The Energy Act 2008 (Consequential Modifications) (Offshore

Environmental Protection) Order 2010


OSPAR EMS

Legislative Changes Main changes to the offshore oil and gas environmental regulatory regime to

implement the Directive requirements are: • New Offshore Petroleum Licensing (Offshore Safety Directive) Regulations 2015; and

• Amendment of the Merchant Shipping (Oil Pollution Preparedness, Response and Co-

Operation Convention) Regulations 1998.

Main changes to the offshore oil and gas safety regulatory regime, to be

discussed by HSE, are: • The introduction of the Offshore Installations (Offshore Safety Directive) (Safety Case etc)

Regulations 2015;

Additional environmental requirements now included in such safety cases: • Assessment of consequence of a major accident

• Safety and Environmental Management Systems and Safety and Environmental Critical

Elements

• Internal Emergency Response Plan (including arrangements for oil pollution)

• Corporate Major Accident Prevention Policy (including environmental protection)


New OGA Licensing Regulations - Licensing

• Licensing Authority will be the Oil and Gas Authority (OGA)

• Licenses will continue to be granted under the Petroleum Act 1998, but the Directive

introduces new environmental and safety requirements, and the Competent

Authority will have to be consulted

• OGA, via the Competent Authority, will be required to consider:

– Safety and environmental performance of applicant

– Safety and environmental management systems and structure

– Sensitivity of local and adjacent environment, and potential cost of degradation of that

environment

– Where details can’t be provided at application stage, commitments will be checked prior to

commencement of operations, including Financial Responsibility submissions relating to

well operations


New OGA Licensing Regulations –

Appointment of Operators

• Licensees will be required to appoint operators with respect to any offshore

petroleum operations

• Proposed appointments must detail functions relating to the appointment

• Licensees will be able to appoint installation operators and well operators, for all or

different phases of operations

• Licensing Authority will be required to consult the Competent Authority who will

consider:

– Safety and environmental performance of applicant

– Safety and environmental management systems and structure

– Sensitivity of local and adjacent environment, and potential cost of degradation of that

environment

– Capacity to comply with relevant statutory provisions


New OGA Licensing Regs - Capacity of Operators

• The Competent Authority will assess the capacity of operators to undertake their

duties, and notify OGA if the performance of the operator is considered

unacceptable

• OGA must notify licensees of the Competent Authority’s determination

• Where licensees are informed of a determination, the operator’s appointment must

be terminated

• Where an operator’s appointment is terminated, the licensee becomes responsible

for carrying out the operator’s functions

• Where an operator’s appointment is terminated, the licensee must propose a new

operator

• Draft guidance on the safety and environmental requirements for licence

applications and the appointment of operators will be circulated to industry around

the end of May 2015


OPRC 1998 Amendments • The new Safety Case Regulations require an Internal Emergency Response Plan,

which must include arrangements for responding to oil pollution

• The Merchant Shipping (Oil Pollution Preparedness, Response and Co-Operation

Convention) Regulations (the OPRC Regulations) have been amended in relation to

operations in external waters

• Oil Pollution Emergency Plans (OPEPs) remain essentially consistent with previous

guidance, but certain changes have been made and include:

– Requirement for Non-Production Installations to hold an approved OPEP;

– Requirement to include / reference an inventory of response equipment and an assessment of the

effectiveness of oil spill response measures;

– Changes to who is required to hold an OPEP (e.g. well operator, NPI owner, installation duty holder);

– New terminology. Temporary Operations OPEP (TOOPEP) replaces ‘drilling addendum’.

– Concept of a Communication & Interface Plan (CIP) introduced replaces ‘Comms Annex’;

– A 21 day regulatory review period for certain TOOPEPs and CIPs; and

– Amended worst case modelling requirements.


Other Environmental Controls

• Safety and environmental management should be the responsibility of approved

persons in charge of day to day operations

• Environmental permits etc. will therefore be held by installation and well operators

• Responsibility and accountability for complying with the regulations will fall to

installation and well operators

• OSPAR EMS reporting requirements will also fall to the installation and well

operators

• Liability for environmental and economic damage, and financial security

requirements will remain with licensee(s)


The OSDR Partnership • The European Offshore Safety Directive took effect on 19th July 2015

• In the UK, the ‘Competent Authority’ required for the regulation of major offshore

hazards is DECC and HSE working in partnership

• The Competent Authority is called the Offshore Safety Directive Regulator (OSDR),

and referred to as ‘the OSDR Partnership’

• OSDR is not a new body, or separate legal entity, but it will have branding and

presence

• The OSDR partnership delivers the government’s commitments made in response

to the legislative consultation

• From a stakeholder perspective, the OSDR organisational arrangements should

provide a single, consistent regulatory interface with the UK oil and gas industry for

major safety and environmental accident hazards covered by the Directive.


Single Regulatory Interface In practice, building the single, consistent regulatory interface for stakeholders includes:

• Creating a website for information relating to the OSDR partnership and an online portal for all

regulatory notifications and submissions, regardless of whether the submissions relate to

safety or environmental issues

• Developing a new on-line portal, to integrate with OGA licensing system (LARRY), the OGA

and DECC register of installations (DEVUK) and the OGA well consents system (WONS)

• Building a single, coherent set of submission, assessment and acceptance procedures for

safety cases, oil pollution emergency plans and the various other regulatory notifications and

submissions that are required, including major hazard incident reporting.

• Providing a single intervention plan for each owner or operator of offshore installations covering

all planned OSDR interventions, with the presumption of joint DECC / HSE visits where

appropriate

• Coordinated investigations, with decisions made at an early stage as to which regulatory

partner should lead, with aligned principles of enforcement covering safety and environment


OSDR Governance • OSDR is established through an enhanced Memorandum of Understanding,

supported by an Articles of Governance & Management document.

• OSDR has a single, high level strategy on prevention and control of major accident

hazards, which brings together existing DECC\HSE strategies.

• OSDR is governed by a joint DECC / HSE Senior Oversight Board (SOB)

• OSDR operations are managed by a joint DECC / HSE Operational Management

Team (OMT)

• Operational management arrangements are described in a range of publicly

available OSDR business process frameworks and supporting documents that

detail the competent authority functions (already online).


Safety Case Regulations 2015 • SCR2015 replaces SCR2005 in relation to external waters, to provide for the

preparation of safety cases to meet the Directive requirements

• All installations operators have received letters stating when to submit a revised

safety case for assessment under the new 2015 Safety Case Regulations. The

main changes are inclusion of:

– CMAPP – Corporate Major Accident Prevention Policy

– SEMS – Safety and Environmental Management System description

– IERP – Internal Emergency Response Plan (PFEER+OPEP) descriptions

– SECEs – Safety and Environmental Critical Elements descriptions

– Environmental Information, & consequence assessment of a major environmental incident.

– Well Examination Scheme & Verification Scheme descriptions

• First transitional cases submitted April 2015. Coming in at roughly 10 per month for

the next three years. Jointly assessed by DECC and HSE


Major Accidents & Environmental Incidents

Major Accident

• An event causing, or with significant potential to cause death or serious injury

arising from fire, explosion, loss of well control or release of dangerous substance,

major damage to installation structure, plant, loss of stability.

• Any other event arising from a work activity involving death or serious injury to five

or more persons

• Failure of life support systems for diving operations in connection with an

installation, detachment of diving bell, trapping of a diver in a bell or subsea

chamber

• Any major environmental incident resulting from any of the above

Major Environmental Incident

• An incident that results in, or is likely to result in significant adverse effects on the

environment in accordance with the Environmental Liability Directive


New Reporting Requirements - Dutyholders

• The new EU Implementing Regulation affects incident reporting. It expands what

was already required in UK law and makes compulsory, some of what was in the

voluntary hydrocarbon release reporting scheme. Duty holders must report:

– All major accidents, or situations where there is an immediate risk of a major accident

– When suitable measures are taken to address a significantly increased risk of a major

accident

– On request, when a licensee or operator that is a UK registered company with operations

outside the EU, details of any major accidents they, or their subsidiaries, have been

involved in outside the EU.

• The EU Implementing Regulation reporting requirements take effect when

installations transition to the 2015 Safety Case Regime:

• HSE and DECC are working to integrate all offshore incident reporting into a single

tool for installation owners and operators to use from January 2016


PON

2

PON

10

New Reporting Requirements - Dutyholders

• Ministers approved a policy decision not to alter or remove RIDDOR. We will

therefore have overlapping health, safety and environmental reporting regimes.


PON

1

RIDDOR OIR

12

EU

Implementing

Regulation

DCR MAR

• One single reporting tool to

cover all the reporting

requirements.

• Report of an Oil and Gas

Incident (ROGI)

• Available now for

transitioned installations

• Whole industry to use from

Jan 2016

• Final version web-based

• There are new requirements surrounding what Member States must report to the

European Commission

– This involves the type and number of major accidents, and normalised data on reported

incidents.

– The purpose is to share information across Member States to learn lessons and prevent

recurrence.

– First reporting year is January to December 2016

• OSDR must make similar information available to the public, including summary

information on major accident investigations.

• Similarities to information that could be released under freedom of information

requests.


New Reporting Requirements – to EU & Public

Further Information • DECC and HSE have jointly provided a series of industry briefings

• Advice is available to companies from DECC and HSE focal-point inspectors

• Information is available online at:

The Offshore Directive website

http://www.hse.gov.uk/offshore/directive.htm

The OSDR website

www.hse.gov.uk/osdr


http://www.hse.gov.uk/offshore/directive.htm

http://www.hse.gov.uk/osdr

HUGH BENNETT (AMEC FOSTER WHEELER) IAN WRIGHT (PETROFAC) RODDY SMITH (RGU)

Sharing and Learning

SPONSORED BY

WHY SHARE? Hugh Bennett – Amec Foster Wheeler

“prior to any disaster there will nearly always be information somewhere within an organisation that trouble is brewing....critical information must not be allowed to lie around unrecognised, ignored or buried like some landmine waiting to be triggered. The challenge is to find ways to assemble this information and move it up the hierarchy to the point where it can be understood and reacted on responsibly.”

Andrew Hopkins (Lessons from Longford)

WHY SHARE? Hugh Bennett – Amec Foster Wheeler

Improvements in the learning culture and processes for spreading best practice

Where incidents are potentially high in impact but occur very infrequently, it

is particularly important to extract and promulgate, quickly and

comprehensively, valuable learning to prevent a recurrence with more severe

consequences.

Sharing learning from previous incidents and events is also vitally important.

Thorough post-event analysis enables identification of lessons which, if

widely implemented, can prevent recurrence elsewhere. In a major hazard

industry such lessons should not be proprietary to any one organisation;

they must be shared for the safety of all and for the protection of the

environment.

Geoffrey Maitland (FREng), Professor of Energy Engineering, Imperial College London

Our opportunity

27 150 1 48,600

WHY ARE WE NOT SHARING?

Sharing Lessons

Information can be shared by any registered and logged-in user

Search for Lessons

WHY ARE WE NOT LEARNING? Ian Wright – Petrofac

A Lesson Learned!

So what if we asked them?

We learn from our

experiences

https://www.google.co.uk/imgres?imgurl=http://thehumbledhomemaker.com/wp-content/uploads/2014/05/We-All-Have-a-Story-to-Tell.jpg&imgrefurl=http://thehumbledhomemaker.com/2014/05/legacy-of-tyndale-house-founder-ken-taylor.html&docid=Kzbv9rNY1jGgqM&tbnid=5ZowFfsichNdvM:&w=640&h=640&ei=uzrfVfzYJ8mka9PUjZAP&ved=0CAUQxiAwA2oVChMIvKLHr9fJxwIVSdIaCh1TagPy&iact=c&ictx=1

There are no new incidents!

We can learn without having to experiencing incidents if we ask others and share our own

• Pose a problem

• Ask others

• Create curiosity

• Tell stories and share experience

• Be surprised what you learn!

SAFETY ALERT

Improved! Continues!

JUT Videos

New!

SAFETY MOMENT

LESSON SHARED

http://www.google.co.uk/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCI696qKonMgCFYGzFAodQe4Jyw&url=http://www.iconshut.com/microsoft-powerpoint-icons/dT1hSFIwY0RvdkwzVndiRzloWkM1M2FXdHBiV1ZrYVdFdWIzSm5MM2RwYTJsd1pXUnBZUzlsYmk4eEx6RXlMMUJ2ZDJWeWNHOXBiblJmYldGalh6SXdNRGhmYVdOdmJpNXdibWN8dXI9aHR0cDovL2VuLndpa2lwZWRpYS5vcmcvd2lraS9NaWNyb3NvZnRfUG93ZXJQb2ludHx3PTY0fGg9NjR8dD1wbmd8/&psig=AFQjCNEFJPlmy5TdoG8Pg-qHldubAK6P_A&ust=1443618536805954

• Basic level of Information sharing

• Ideally short, relevant and valuable

• “It happened to us, check its not going to happen to you!”

Safety Moment

What hazards are there? What could go wrong? What might be the consequences?

Reciprocating gas compressor with small bore tubing for instrument connections.

DISCUSS

Small bore tubing failure

Following maintenance work, a helically coiled tubing was re-instated upside down. The tubing was left with a pre-load stress and tool marks suggesting it was re-fitted using force.

Vibration from the compressor led to fatigue cracks emanating from the tool marks.

Full through thickness failure occurred. An estimated 1.67 Tonnes of gas was released over 83 min. Due to the open module configuration the gas was not detected by fixed detectors and the leak was manually detected by a routine inspection.

No ignition occurred.

Fatigue failure of instrument tubing following reinstatement of an incorrect orientation using incorrect fitting practices


What behaviours and steps could prevent this from occurring?

What might you do differently today in your work?


DISCUSS

Help and advice It is important that people are aware of causes of previous failures which could re-occur. Competence and knowing your limitations is essential when dealing with hazardous equipment. You will get more respect from people if you ask for their help when you are unsure. Making yourself open to help encourages others to ask, and helps protect us all. Useful resources: Joined-up Thinking training packages – Competency Mechanical joint integrity – Route to competence


https://www.stepchangeinsafety.net/safety-resources/joined-up-thinking/joined-up-thinking-resources

https://www.stepchangeinsafety.net/safety-resources/publications/mechanical-joint-integrity-competence-guidance





https://www.stepchangeinsafety.net/jut2015

Which of the 7Cs are involved in this safety alert?

• Change management

• Communication

• Complacency

• Control of work

• Competence

• Culture

• Commitment

Did this presentation result in discussion that could lead to creating another alert to share with industry? Please contact: [email protected]


WHY ARE WE NOT LEARNING? Roddy Smith – Robert Gordon University

What hazards are there? What could go wrong? What might be the consequences?

Reciprocating gas compressor with small bore tubing for instrument connections.

DISCUSS


Following maintenance work, a helically coiled tubing was re-instated upside down. The tubing was left with a pre-load stress and tool marks suggesting it was re-fitted using force.

Vibration from the compressor led to fatigue cracks emanating from the tool marks.

Full through thickness failure occurred. An estimated 1.67 Tonnes of gas was released over 83 min. Due to the open module configuration the gas was not detected by fixed detectors and the leak was manually detected by a routine inspection.

No ignition occurred.

Fatigue failure of instrument tubing following reinstatement of an incorrect orientation using incorrect fitting practices


What behaviours and steps could prevent this from occurring?

What might you do differently today in your work?


DISCUSS

Help and advice It is important that people are aware of causes of previous failures which could re-occur. Competence and knowing your limitations is essential when dealing with hazardous equipment. You will get more respect from people if you ask for their help when you are unsure. Making yourself open to help encourages others to ask, and helps protect us all. Useful resources: Joined-up Thinking training packages – Competency Mechanical joint integrity – Route to competence


https://www.stepchangeinsafety.net/safety-resources/joined-up-thinking/joined-up-thinking-resources






https://www.stepchangeinsafety.net/jut2015

Mechanical Joint Integrity – Route to Competence Guidance

or effectively:

Training and competence guidance for all personnel involved making and breaking hydrocarbon joints

This guidance reflects current industry practice guidance as well as a definition of minimum standards of competency for working on mechanical joints. It has been developed by a working group including members from industry and standard setting bodies. The guidance sets out a structured approach to the principles of managing competence for those involved in mechanical joint operations. It describes how to train, develop and assure competence, reducing the risk of personal injury and hydrocarbon and non-hydrocarbon release when working with mechanical joint related activities such as construction, maintenance and disassembly operations. Summary: The guidance sets out a structured approach to the principles of managing competence for those involved in mechanical joint operations.

Summary

ALAN BLACKLAW (NEXEN) ANDY EWENS (AMEC FOSTER WHEELER) DAMON BOWLER (SHELL)

HCR Improvement & Implementation

SPONSORED BY

7 Key Themes:

Performance

Operational activities

Investigation

Competence Integrity

management

Communication

Human factors

2015 Timeline

Q1 Q2 Q3

Developing framework

1. Performance Best in Class

Nexen – FLIR camera

Areas for Improvement

Common classification of weeps/seeps o Clarify language/definitions around fugitive

emissions, weeps, seeps, leaks etc o Common thresholds allow formal recognition

of smaller HCRs, and therefore consistent management

Sharing of KPIs o KPIs and dashboards are widely used, but

KPIs are specific to each organisation o Much re-invention of KPIs exists o Cross-industry reporting is impacted by

differences in KPI definitions o Propose a ‘dictionary’ of KPIs with agreed

definitions, and pros and cons of application o Reduces invention phase, and better

supports cross-industry reporting

2. Operational Activities Best in Class

Apache – Operational Risk Assessments Comprehensive (ORA) process in place o Remedial action plan assigned to each

ORA o Technicians sign-off on safety critical

ORA’s within 48 hr of arriving on platform

o Daily control checks part of morning calls/reports

o Overview of Safety Critical ORAs provided at heli-brief for new crew


Start-up assurance Shell and WGPSN identified as BIC: Robust start-up assurance process in place for an asset which had been shut down for a considerable time There is an opportunity to develop industry wide guidance on what start-up assurance should consider.

3. Communication Best in Class

Chevron – internal safety alerts o Two-tier alert system in place

o Immediate single page alerts issued

o Incident bulletins include formal actions

o Actions tracked in the Corporate

Incident Management System

o Learning is formalised


Post Incident Feedback and Learning o Too often comms breaks down at

onshore / offshore interface

o Pace & efficiency of learnings - low Procedures o Effective design of procedures

o Efficient roll out of procedures

4. Investigation Best in Class

Shell – Investigation & Action Management o Cross-discipline Incident Review Panels

(IRPs) used to ensure sharing of learnings, challenge actions to ensure they are robust and SMART

o Resulting actions managed within corporate assurance tool

o Incident Investigation Tool recently developed to include human factors considerations


Cross Industry Learning Learning from events: SADIE review and learning isn’t in the DNA WHY? Learning from best practices: Now integral to AISG work groups Events like this one…..more of them!

5. Competence Best in Class

Wood Group PSN – 3rd party contractor competencies o Compliance with WGPSN base level

discipline competence, where applicable

o Provision of demonstrable evidence to assure competence prior to approval to mobilise

o Individual assigned a buddy for initial site visit as a minimum, to restrict lone working

o Quality assurance audit/check on provider prior to inclusion on supplier list


3rd party competence o Establish minimum levels of

“understanding” for all offshore personnel

o Greater awareness of potential impact across all trades

• Eg –impact to scaffolding on LoS gas detectors

o Better use of industry leading training • Bespoke SBT course • Spadeadam

o Overreliance on 3rd Party competency management processes.

6. Human Factors Best in Class

Chevron o Documented HF processes, supported

by internal expertise. o HF is part of all incident investigations

and is formalised within investigation handbook.

o Standardised re-write of SOPs for key equipment, with HF focus.

o Cultural programme to be rolled-out offshore from Jan 2016.

o HF & coaching are competence driven. o Fatigue modelling & overtime impact

assessments conducted with support from Keil Centre.


Simplification and embedding

7. Integrity Management Best in Class

Apache – Anomaly Management o Integrated anomaly management across

assets within a single application

o Simple, logical, anomaly creation workflow

o Complete access to all anomaly data within a centralised application


Adopting / designing technology There is a lot more to integrity than pipes and vessels – where are the technology advances?

7. Integrity Management Best in Class

BG Group – Small bore tubing o Training encapsulates SBT, flexible hose

assemblies and flange management.

o 2 tiered approach for SBT; • Tier 1 creating new pipework with

a focus on experienced practitioners,

• Tier 2 for dismantling and reassembly focused more on people with little knowledge or infrequent use of skills.

o SBT joints are captured using GOC,

treated and managed like flanges.


Doing the basics right: o Flange / joint management

o Small bore tubing

o Flexible hose assemblies

What’s Next? Q4 2015

• 4 more operator assessments

• Develop assessment for tier 1 & 2 contractors

• Extend the assessment offer to drilling companies

• Working group sustainability

2016 • Continue assessments of Ops Co.'s + tier 1 & 2 contractors

• Extend further through the supply chain

• Publish best practice documents

Assessment Case Study Damon Bowler UK Hydrocarbon Release Prevention Lead

The assessment

• Assessment undertaken 2nd June 2015 (pilot)

• Step Change assessors – Alan Blacklaw ( ) & Andy King ( )

• Facility approach rather than by themes – 7 facilities (10 onshore & offshore installations)

• 1 hour assessment for each facility on a subset of the 7 key themes

• Wide cross-section of people interviewed – Asset Managers, Facility Managers (OM’s), OIM’s,

Operations Leads, Maintenance Leads

What the assessors found Strengths

• Open and comprehensive reporting culture

• Facility-focused organisation (facility Hydrocarbon Release Prevention plans)

• Robust incident investigation process

• Comprehensive Authorised Persons Register

• Facility Risk Review to manage high risk threats

• FLIR cameras in routine inspections

• ‘Goal Zero’ ambition (no harm, no leaks)

• Leadership commitment (to bring about performance improvement)

• Human Factors Incident Investigation Tool

Opportunities

• Standardised reporting (to remove confusion)

• Re-energise some facility Hydrocarbon Release Prevention plans

• Better use of cross-asset learnings

• Make more of Major Accident Hazards awareness offerings

• Consolidated approach to leak detection technologies

• Make HCR prevention message clearer at the working level

• Bring process safety into Mind Safety

• De-mystify human factors into tangible activities

What did Shell get out of it?

Need to set some context first…

Shell was receptive to getting something out of it

• Shell’s HCR performance was improving – but not quick enough compared to its peers

• Relative stagnation in performance a revelation and fostered a strong desire to look at how others do things

• Willingness to have an external perspective to hold the ‘mirror held up’

• New facility-focused organisation provided new opportunities for improvement

• HCR data well understood and a prevention plan in place – in the process of being reviewed in the light of the new organisation

How Shell has benefited

• Direct benefits of being assessed – Comprehensive, on-the-day feedback across the spectrum of key HCR

vulnerabilities (the 7 key themes)

• Shell currently reviewing its plans to incorporate key opportunities from the assessment

e.g. clarifying the prevention message, making human factors more tangible

• Indirect benefits of assessing others – Unique insight into Best-in-Class practices (learning opportunities)

• MAH Tool (management visit arranged)

• Small-Bore Tubing management

• approach to Operational Risk Assessments

STUART TAYLOR (APACHE) PETER HEPBURN (MAERSK OIL) STEPHEN O’NEILL (BILFINGER SALAMIS)

Major Accident Hazard Understanding

SPONSORED BY

Purpose:

• To develop a step change in the understanding of Major Accident Hazard Management across all onshore and offshore organisations working in the UKCS.

• To give everyone in the industry a clear line of sight between their role and prevention of a Major Accident.

• To develop a more informed workforce.

Major Accident Hazard Understanding

• Peter Hepburn Maersk Oil (Co-chair)

• Stuart Taylor Apache (Co-chair)

• Fiona Fitzgerald DNV GL

• Melanie Taylor HSE

• Imogen Hutchcroft Apache

• Tony O’Shea WG Kenny

• Mark Stagg Sea Energy

• Iain Wright Total

• Glen Sheppard Nexen

• Alasdair Smith Oceaneering

• Mark Anderson Amec Foster Wheeler

MAH Understanding workgroup

https://www.google.co.uk/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCNv4xPfCnsgCFYhYGgod268FyA&url=https://twitter.com/nexenenergy&psig=AFQjCNHqy52lkxOFuKK5gJ4SV4hNuQ98lw&ust=1443694411828848

http://www.google.co.uk/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCPyQ6MSLq8gCFQpvFAodrfEIPw&url=http://meopar.ca/network/ajax-partner-info/wood-group-kenny&psig=AFQjCNHdHxh1OMFOR_WoBIhamOZyyvVO_w&ust=1444126219341867

• A reduction in hydrocarbon releases

• Improved workforce engagement and understanding of MAH & MAH barriers

• Improved asset integrity and reliability

• Promotion of a MAH management culture

• Provision of an industry-agreed minimum scope & learning outcomes for MAH understanding

The aim is to prevent major accidents by:

• Define “the entire workforce” into populations

• Define MAH management and publish a common language/framework

• Identify each population’s learning needs and objectives

• Produce a MAH understanding Gap Analysis tool for self-assessment with an accompanying guide for use

• Produce a roadmap to resources for each group so gaps can be closed

• Identify OSD opportunities

Objectives

OIM

Technicians

& Operatives

All

MD

Senior

Leadership

Managers

Engineering

Supply Chain

HR MIST 2 (Complete)

Technician Training

Frontline Supervisor Training

Managers Training

Leadership Training

Frontline

Supervisor

Population Framework

HSE

The offshore and onshore populations

Process Safety Management – AICE: A management system that is focused on prevention of,

preparedness for, mitigation of, response to, and restoration from a major accident hazard.

– HSE from HG254: The term ‘process safety management system’ is used to describe those parts of an organisation’s management system intended to prevent major incidents arising out of the production, storage and handling of dangerous substances.

– Layman’s terms: Process safety management is about how we manage the risk associated with major accident hazards. Can also be referred to as Major Accident Hazard Management.

Common language/framework guide

Prevention of a MAH is not just offshores responsibility –

procurement / logistics / HR etc. all have a part to play

Everyone has a part to play – MIST 2 (light)

Learning Outcome Main Categories

• Major Accident Hazards • Barrier Management

• Major Environmental Incidents • Hazard and risk Identification

• Safety and Environmental Critical Elements • Risk Assessment

• Safety and Environmental Critical Elements, maintenance, verification and assurance

• Impact of Behaviours on Major Accident Hazards

• Safety Case • Communications

• Major Accident Hazard Management • The 'So What?'

Item Objective Context Suggested Training

Activities

Major Environmental Incidents

Define a major environmental incident

Use HSE definition and Step Change terms to give clear understanding of what a Major environmental Incident is and how it relates to a MAH

Consider Major Environmental Incident examples and a case studies

Learning outcomes

Gap analysis tool (technicians / supervisors / managers)

> Safety resources > MAH gap analysis tool

Gap analysis tool

Roadmap to resources

Understanding Bow ties

Item Objective Context Suggested Training Activities

Major Accident Hazards

Define a Major Accident Hazard

Use HSE definition and Step Change terms to give clear understanding of what a Major Accident Hazards is

Consider using examples of Major Accident Hazards on your site and also industry examples (Texas City, Deepwater Horizon etc.)

Describe Major Accident Hazard identification process

Provides an understanding of how Major Accident Hazards were identified through HAZID based on the scenarios that have the potential to cause a major accident

Consider Major Accident Hazard examples and case studies

• Learning Outcomes developed for senior managers

• Lunch and Learn sessions to be arranged throughout 2016

• Included in the HCR Improvement and Implementation questionnaire

• At be discussed at Operator and Contractor forums

• Link to HSE strategic plans

Senior Management engagement

Timeline

Action By when

Technician gap analysis tool (Pilot) Today

Roll out and promote implementation Oct ->

Supervisor gap analysis tool Nov 15

Leadership breakfast roll out Nov 15

Manager gap analysis tool Dec 15

Develop resources roadmap and identify resources Dec 15

Senior Management lunch and learn sessions 1Q 2016 ->

Monitor uptake through the Improvement & Implementation group 2016

Introduce to EITB and O&G academy for input into their syllabus 2016

Leaders should: • Educate themselves to become better

informed • Be advocates for better MAH

management through education of the workforce

• Ask probing MAH question of others • Challenge each other • Defend the line

How do we develop a better MAH management culture?

Everybody needs to play their part

Major Accident Hazard Management:

A Contactor‘s Perspective Stephen O‘Neil HSEQ Manager | Step Change

Bilfinger Salamis

October 2015

The traditional management of MAHs

▪ Safety Case

▪ Operators

▪ Duty Holder

▪ Regulators

▪ Contractors?

Bilfinger Salamis UK Ltd page 95

Image obtained from google. Undefined

source

Bilfinger Salamis a major provider of support services

▪ Scaffolders

▪ Rope Access Technicians

▪ Painters

▪ Blasters

▪ Insulators

▪ Specialist cleaning

▪ Inspection services

▪ Architectural outfitters

▪ Deck/Helideck operators

▪ Asbestos removal

page 96 Bilfinger Salamis UK Ltd

Bilfinger Salamis cont’d

▪ 2000 personnel on 70 client

assets

▪ Work in places often outwith

normal access


Contractors influence on Process Safety issues

page 98

Contractors’ negative impact

Contractors' positive

influence

Process safety awareness

Protection of safety critical equipment

Joined up approached

Prompt reporting

Bilfinger Salamis UK Ltd

Bilfinger Salamis’ approach

▪ Process Safety is everyone’s

responsibility

▪ Bilfinger Salamis working to make

all trades aware of Process Safety

issues

▪ Everyone can keep the assets and

personnel safe


Process Safety Awareness – keeping it simple


We should all be familiar with this as it is drilled into us

• Do not turn of lights

• Open windows and door

• Get out

• Call emergency number etc

Proving awareness and a reporting mechanism

page 101

Process Safety Cards

provided to every

operative

Training package being

developed

Process Safety

Handbook

Bilfinger Salamis UK Ltd

Process Safety pocket form and e-form

Bilfinger Salamis UK Ltd.

Process Leak

Unusual Noise

Unusual Smell

Surface Corrosion

Damage Insulation

Damage Fireproofing

Damage/Missing

support

Structural Failure

Missing Faulty Bolts

Damage Joint Face

Failed Paint system

Corroded

Bolts

Impact Damage

Unapproved

Modification

Collapsed

Cover/surface/structure

Other

page 102

Reporting mechanism


1) Operative finds an issue

2) Reports immediately for serious finding in accordance

with clients procedure

3) Fills in paper Process Safety Card

4) Arranged for card to be electronically logged on platform

via Act Safety SharePoint portal

5) Onshore gets automatic notification. Client notification if

required

6) Data collation and trending

7) Lessons learned/ shared

page 103

Case Study 1: Process Safety intervention

May 2015 - Bilfinger Salamis :

• Bilfinger Salamis’ scaffolders working on bridge between the accommodation

and compression jacket

• Smell gas and reported

• Work stopped

• Lines purged and depressurized

• Crack found at the connection between 2 ‘’ and 16 ‘’ line

• Potentially serious incident averted


Case Study 2: Process Safety intervention

2014 Bilfinger Salamis:

• Rope Access Team working fabric maintenance campaign on live asset

• While working, discovered a hole in pipework which they reported

• Live condensate line

• Praised by client for intervention and process safety award given by Bilfinger

Salamis


Bilfinger Salamis

• 2000 noses to smell

• 2000 mouths to taste

• 4000 eyes to see

• 4000 ears to hear

Provided with the knowledge, awareness and a

reporting culture, contractors are a powerful additional

resource in process safety and MAH management.

page 106

Contractors have a role to play in MAH

management


Act Safely


Summary and closing comments

• The purpose, structure and direction of travel have been overhauled to better serve the industry in the management of MAH

• Workgroups staffed by experts and committed people have delivered excellent work

• The challenge of moving forward is for industry to make use of the work to better manage MAH

What you can expect from us • HCR Improvement:

– Keep the peer assists going and promote transfer of learning between companies

– Identify areas that industry struggles and act on them

– Track how company HCR plans are working and offer support

• Learning and Sharing: – Continue work on website, roll out new learning and sharing process

– Take learning info, turn it into a form that’s easy for industry to use

• MAH Understanding and Education – Finish defining MAH learning needs for the entire workforce, roll out to industry

– Hold seminars on MAH understanding and education with key leaders

– Follow up longer term education opportunities e.g. technician MAH training

• Look at nuclear industry to ensure we’re not missing something

What we ask of industry • Get involved in the HCR peer assessments

• Share how your HCR plans are working, what’s working well and your improvement areas

• Use the new learning format & info and hold engaging conversations at all levels to learn lessons by asking questions

• Share your lessons with Step Change in the new format

• Use the MAH learning needs to look at the depth of MAH understanding in your organisation

• Take action to get everyone involved and playing their part

Q & A


SPONSORED BY

LES LINKLATER, STEP CHANGE IN SAFETY

Wrap up & close

SPONSORED BY

asset integrity 6th october 2015 - step change in safety · asset integrity steering group ......

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