New EU Directive Safety Case Compliance with Marex support
Incidents, in particular the Deepwater Horizon incident in the Gulf of Mexico in April 2010, have raised public awareness of the risks involved in offshore oil and gas operations and have prompted a review of policies aimed at ensuring the safety of such operations. The Macondo incident highlighted the offshore oil and gas industry’s lack of universal mandatory safety procedures. In particular, it suggested a fragmented regulatory structure and lack of any overarching, cohesive legislative framework. The European Commission (EC) concluded that the existing divergent and fragmented regulatory framework applying to the safety of offshore oil and gas operations in Europe, along with current industry safety practices, did not provide adequate assurance that risks from offshore accidents were minimised throughout the Union. The EU, therefore, adopted the Offshore Safety Directive on 10 June 2013.
The implementation of the EU directive means that organisations will have to revise their safety cases over the next few years to allow them to comply with the updated regulations, which have more environmentally focussed considerations. As far as the UK is concerned, the majority of the Offshore Safety Directive’s requirements have been transposed into national law by the Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015. The new regulations came into force on the 19th of July, 2015 and are set up to reduce, as far as possible, the occurrence of major accidents relating to offshore oil and gas operations and to limit their consequences.
The new directive changes the way the regulators are set up to allow for a more unified level of response throughout the European Union. The directive also required the creation of an offshore competent authority. DECC and HSE, working in partnership, have now established the Offshore Safety Directive Regulator (OSDR). HSE and DECC’s legislation has been updated to fully implement the directive. This includes changes to existing legislation, as well as introducing new requirements.
The main changes between the new regulations and the existing UK offshore safety and environmental regime include:
- The creation of an independent offshore competent authority
- Integrating the management of safety and environmental risks, which impacts on the safety case, well notification, independent verification scheme and well examination requirements
- Introduction of independent verification for environmental critical elements
- Requirements for the production of a corporate major accident prevention policy
- Specific requirements for oil pollution emergency plans
- New requirements on liability for environmental damage
- Duties on operators to report a range of new incidents and dangerous occurrences to the competent authority
- Requirements on the competent authority to report a range of information, including the findings of their major accident investigations, to the EC
- Duties on operators registered in the Member States to report major accidents that occur outside of Europe
- Transitional arrangements covering existing installations and wells
In so far as the safety regime is concerned, a transitional period has been granted for existing installations, allowing parties involved with ongoing operations until 19 July 2018 to comply with the new regulations. Otherwise, the regulations will apply from 19 July 2016.
Preparation of safety cases to comply with the regulations requires great amounts of planning and preparation. Many of the major drilling contractors in the UKCS prefer to utilise the services of specialist risk consultancy companies, such as Marex Marine and Risk Consultancy, for the compilation of the safety cases and to facilitate the risk studies required. Risk studies can be categorised into qualitative and quantitative.
BowtieXP is one such program utilised in providing qualitative risk assessments. The software allows highly skilled employees to thoroughly analyse, with input from the client’s workforce, all potential hazards that could impact offshore assets. The software allows the tailoring of barriers to the possible threats that could initiate an event and the measures in place to prevent an event from escalating into a disaster. Through this, operators can ensure that concerns on safety aboard their offshore fleets are adequately addressed, while simultaneously providing a point of reference for the workforce. The software allows for several levels of information to be provided with each barrier, from those responsible for the actions described by a barrier, to lists of safety critical equipment associated with a prevention mechanism. Identification of Safety and Environmental Critical Elements (SECEs) can be one of the outcomes from this process, which is referred to as Major Accident Hazard Risk Assessment (MAHRA). The duty holder is responsible to create performance standards for the SECEs and develop a Written Scheme of Verification for the installation or the well. An independent verification body should be appointed by the duty holder to carry out the verification process to ensure that the SECEs are fit for purpose and continue to be so throughout the life of the installation.
Some cases might require an in-depth quantitative analysis of the impacts of fires, gas releases or explosions using complex modelling software. These programs operate on the principles of fluid mechanics to compute the fluid dynamics of the spread of gases, explosion overpressures and radiant energy released by fires. The software used includes PHAST and Kameleon FireEx (KFX), depending on the level of detail required by the duty holder. The results of these analyses are used in safety cases, and can also be used in producing risk analyses, either as supporting material or as standalone documents.
In some instances, availability studies, Failure Mode and Effects Analyses (FMEAs) and its extension, Failure Mode and Criticality Effects Analyses (FMECAs) would also be required. These assessments statistically analyse vital equipment offshore, such as the fire detection systems, to ensure that no one risk factor will dominate the equation or disrupt critical systems during an emergency.
The professional expertise of risk specialist companies can be utilised beyond the confines of the office and conference rooms. Carrying out compartment studies, human factors assessments and PUWER assessments on board vessels and installations are all essential parts of compliance with the regulatory structure surrounding offshore operations in the North Sea.
Due to the pace that the industry moves, it can be easy to overlook potential events that have an extremely low level of probability but potentially high consequences. A company that has not had a major incident for an extended period of time is no more or less at risk of a major incident, hence preparation is the key. Since its inception nearly 20 years ago, Marex has completed over 200 safety cases (new submissions, thorough reviews and material changes) for major drilling contractors in the industry. Marex’s highly skilled team members are already assisting companies with the revision of safety case changes that have to be made, courtesy of the new EU directive. Ian McDougall, MD, said, ‘In doing this, Marex are providing a system of documentation to their client that will enable informed decisions to be made concerning all aspects of worker and workplace risk and safety and assist in identifying, minimizing and eliminating risk to their employees, their assets and the environment.’ For more information, please visit the website www.mmass.co.uk or contact Marex directly.