Offshore Safety After the Deepwater Horizon

14 Sep 2010

As there is an increasing level of success in stemming the flow of oil into the Gulf of Mexico from the Macondo well, and as the politics now begin to dominate the scene, both the politicians and the oil men are beginning to look to the future. Already the Minerals Management Service has been consigned to the dustbin of history, and has been replaced by the Bureau of Ocean Energy Management Regulation and Enforcement. The office of the president has tried to maintain its moratorium on deepwater drilling and the Development Driller III and the Development Driller II have made steady progress with the relief wells.

Senate committees have continued to probe into the regulatory regimes under which all vessels, including dynamically positioned drilling vessels, operate and, despite attempts at explanations by Rear-Admiral Cook of the US coastguard, there has been little interest in the activities, signatories or regulations of the International Maritime Organization (IMO). So here’s the question, what now?

It could be time to look at the experience of other nations in the aftermath of major oil industry disasters, possibly excluding the US where many offshore units have sunk, exploded or been subject to some other misfortune, often with loss of life but which, maybe because there was no associated environmental disaster, have not made it to the attention of the public or the politicians. For instance, the matt supported jack-up Ocean Express sank in 1976 in the Gulf of Mexico, with the loss of 13 lives, but who remembers it now apart from those who were involved and the relatives of those who were lost?

First UK disaster in 1965

Chronologically the first disaster to make an impact on the British regulators was the loss of the jack-up Sea Gem in 1965, which by 1971 had resulted in the Minerals Workings (Offshore Installations) Act. This act required a number of things including the provision of an Offshore Installation Manager (OIM), with a specific responsibility for stability, and a standby vessel. The rig owners and the operators of the time fulfilled the requirements in the most rudimentary fashion, installing the OIM virtually as a clerk for the Toolpusher, who became “The Rig Superintendent”, and the standby vessels appeared in the form of redundant deep sea trawlers, which just happened to become available due to the Icelandic Cod War.

212 people die when Alexander Kieland capsizes

The next major disaster was the loss of the Alexander Kieland, which was a Pentagone rig being used for accommodation in the Norwegian sector of the North Sea. It suffered catastrophic structural failure and capsized, and as a result 123 of the 212 people on board were lost. The Norwegians instituted a whole range of regulatory requirements, which it was hoped would shield the workforce from further accidents, including a stability requirement which would result in a semi-submersible remaining afloat even after losing a leg, and lifeboats for 200% of the crew.

Ocean Ranger sinks in 1982, killing 83

In 1982 the Ocean Ranger sank off the coast of Canada. The whole crew of 83 died in the disaster, including those in a lifeboat which overturned. The Canadians conducted an exemplary enquiry which resulted in a whole range of regulatory requirements. The Ocean Ranger disaster is etched on the collective memory of the Canadian populace.

UK sector of North Sea explodes in 1988

In 1988 in the UK sector of the North Sea the platform designated as “Piper A” caught fire and exploded with the loss of 165 of the 226 people on board. The resulting enquiry, led by Lord Cullen resulted in a root and branch change to the manner in which offshore safety was dealt with. The Minerals Workings Act was binned, to be replaced in 1995 by the “Offshore Installations (Safety Case) Regulations. The administrators and assessors of the process also changed from the UK Department of Transport to the newly formed Health and Safety Executive (Offshore Safety Division).

"Goal Setting Legislation" in the North Sea

So the offshore installations in the North Sea, including mobile units, ceased to be regulated in the traditional manner and became subject to what was known as “Goal Setting Legislation”. The owners of these units had to work out for themselves what

the risk to their workforce might be from being out there, drilling holes in the seabed, searching for and recovering volatile, and in some cases poisonous, substances. And then, having sorted that out, they had to put in place processes and equipment which would reduce the risk of major accidents.

The idea was that companies operating offshore installations would develop whole departments, whose job it would be to keep everybody safe, initially by carrying out investigations and research and then by developing risk assessment processes. Where these processes had identified means of improving safety either by changing equipment or providing additional guidance or training, then it would be done. The whole activity was overseen by the HSE whose inspectors had been recruited from the nuclear industry, and after 1995 all safety cases had to be “accepted” by that body.

Because the business was, and still is, extremely complicated, most companies developed a relationship with specialist providers who knew most of what there was to know about safety management, technical authorship and risk assessment. And in UK, the HSE followed up the main regulations with further legislation just in case they had missed anything the first time.

Safety risk awareness in the North Sea

While one could say that the safety case regime is still a work in progress, and although its intent has tended to be subverted by the industry’s preoccupation with occupational injuries (slips trips and falls), it is likely that it has improved safety in the North Sea. There is a much wider understanding of the risks at all levels, and some owners and operators have taken the recommendations from the major hazard risk assessments really seriously, and have spent money on hardware upgrades, procedural changes and emergency training.

The process has also gained legs. In 2002 the International Association of Drilling Contractors developed a European template and this was followed in 2004 by an international template. Australia has its own regime, as do the Irish, the Falkland Islands and the Faeroes, and in other places the operators who contract the mobile rigs demand that safety cases for these units be compiled. So, the advantage is that even in places which have little or no safety regulation for offshore operations, the operators can demand that evidence that a safe unit, manned by safe people, is provided.

Safer offshore installations

So the question to all offshore installation operators, whether mobile, or fixed in one way or another to the seabed, is “Do you sincerely want your guys out there to be safe?” And the answer of course will be “yes!” The next question will relate to whether they want the regulator, whatever they are called, to fix it for them, or do they want to deal with it themselves. The signs in the US are that the new regulator is going to do it all. If the government in that country is capable of deciding, with limited evidence (despite the Deepwater Horizon accident), that no deepwater drilling should be taking place, even though the deepwater starts only a few miles off the beach, what else are they going to decide?

But a safety case regime remains worthy of consideration. Instead of a process with which people argue, and spend money avoiding, there would be one which they would of necessity have to embrace, and which would steadily make things safer in what is, let’s face it, a pretty hazardous business.

Safety management systems for the offshore industry

When the judge who presided over the Ocean Ranger enquiry was required to dot the i’s and cross the t’s of the report, he said the following: “The Ocean Ranger disaster could have been avoided by relatively minor modifications to the design of the rig and its systems and it should, in any event, have been prevented by competent and informed action by those on board. - It is the essence of good design to reduce the possibility of human error, and of good management to ensure that employees receive training adequate to their responsibilities.”

This then is the task. A well-constructed safety case will tease out any design failings in an individual unit and make recommendations for their correction. It will ensure that the safety management system a company has in place covers all aspects of its operations, and it will provide guidance for the development of effective emergency procedures and training, so that the risks of working out there will be “as low as reasonably practical”. It sounds like a constructive approach doesn’t it?

Written by Victor Gibson, July 2010.

Victor Gibson is a master mariner who commanded offshore support vessels in the North Sea before becoming a safety consultant and safety case practitioner in the early 1990s. He is a director of Marex Marine Services of Aberdeen who have developed about 100 safety cases for offshore units.