IOSH | 29 July 2015

New Offshore Industry Safety Case Regulations Backed by IOSH

Revised offshore safety case regulations in the UK will help to safeguard both workers and the environment, according to the Institution of Occupational Safety and Health (IOSH).

The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015 (SCR 2015) came into force on 19 July. They apply to all oil and gas operations in UK waters and replace the 2005 regulations. They are the UK’s response to the EU’s Offshore Safety Directive, which requires a more joined-up approach to offshore safety after it was found that the existing national regulatory frameworks were too fragmented.

SCR 2015 states that its primary aim is to “reduce the risks from major accident hazards to the health and safety of the workforce employed on offshore installations or in connected activities.”

ProAct Safety | 29 July 2015

Column: Climate and Culture Before, Not After, Behavior-Based Safety

Safety culture is not the next step after behavior-based safety efforts; it’s a determining factor on whether to implement or not implement a behavioral approach. Because culture is the most effective reinforcement tool, it will be one of the most important considerations when attempting to implement either compliance or advanced behavioral efforts.

One client recently shared, “We unknowingly decided to provide the workforce of a site we recently acquired new steel-toed boots, as we knew they wouldn’t have the resources or channels to procure them. It was, after all, a companywide safety policy, and we knew many employees didn’t currently wear shoes in the community from which they came. We found out shortly afterwards that most employees promptly sold them to friends and family for extra money.”

If it is not common to wear shoes to work, like within some cultures, mandating new foot protection will be met with minimal compliance. While an extreme example, your culture is often why improvement efforts, compliance or advanced, succeed or fail.

Oil & Gas UK | 22 July 2015

Oil & Gas UK Updates Guidelines for Safe Well Abandonment

To improve cross-industry understanding of well-related issues on the UK continental shelf, Oil & Gas UK on 21 July released updated guidelines for the abandonment of wells together with accompanying guidance on generating cost estimates to support this activity.

Oonagh Werngren, Oil & Gas UK’s operations director, said, “The first guidelines on well abandonment were produced in 1994, and the documents published today are testament to the industry’s collective and continuing commitment to regularly review and improve safety and performance in all aspects of well practices.

“Oil & Gas UK developed this fifth issue of the guidelines with well operators from member companies and other stakeholders to clarify good practice. These guidelines represent just two of over thirty peer-reviewed guidelines published to date by Oil & Gas UK to raise the professional standards of the industry—an outstanding contribution the Institute of Materials, Minerals and Mining recognized when it presented the Premier Award Medal for Excellence to the trade association last week.

“As the sector steps up its effort to tackle its cost base and improve efficiency, the guidelines on well abandonment cost estimation provide industry with a common framework in which to generate more consistent and complete cost estimates. Oil & Gas UK has now produced nine separate guidelines on aspects of well operations including competency, relief-well planning, and blowout prevention, to outline good practice to improve safety and performance throughout the life cycle of wells. In producing the guidelines, Oil & Gas UK’s intention is to provide guidance, rather than standards, to support the regulations and associated advice issued by the regulator.”

Find the guidelines for well abandonment here.

Find the guidelines for well abandonment cost estimation here.

Fuel Fix | 14 July 2015

Damaged Arctic Icebreaker’s Route Questioned

New marine tracking data shows a Shell-contracted icebreaker may have crossed through shallow waters that offered little clearance between the vessel’s bottom and the ocean floor before a 3-ft hole was discovered in its hull.

The Automatic Identification System data—location information captured every minute from the MSV Fennica—shows its 3 July route away from the Alaska Port of Dutch Harbor before a leak identified by a marine pilot and other crew onboard the icebreaker forced it to turn back.

When that AIS tracking data is overlaid over navigational charts of the area—which date back decades—it appears the Fennica crossed through waters with charted depths of as little as 31.5 ft. While an additional 3 ft may have been gained by high tide at the time, that would give the Fennica potentially scant clearance over some of the rocky shoal in those waters, because the Fennica’s recorded draft is 27 ft, giving it potentially scant clearance over some of the rocky shoal.

It appears likely the Fennica was gouged when it traveled near a previously uncharted rocky shoal that was documented by a government survey ship on 8 July and the subject of an alert to mariners a day later.

But conservation group Oceana, which conducted the analysis, said it suggests Shell’s contracted icebreaker still took a riskier path instead of a deeper alternative route around nearby Hog Island, as it trekked toward proposed drilling sites in the Arctic Ocean.

“There are safer, more precautionary ways for them to go,” said Chris Krenz, a senior scientist and Arctic campaign manager for the group. “The Fennica could have easily traveled along a much safer route instead of going over a shallow, rocky shoal in an area that (already) is not well charted.”

“This is risk-prone behavior, not risk-averse behavior,” Krenz said.

EHS Journal | 8 July 2015

EPA Releases Vapor Intrusion Technical Guidance

On 11 June 2015, The US Environmental Protection Agency (EPA) released its long-awaited vapor intrusion guidance documents.

The Office of Solid Waste and Emergency Response Technical Guide for Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Vapor Sources to Indoor Air (VI Technical Guide)

Technical Guide for Addressing Petroleum Vapor Intrusion at Leaking Underground Storage Tank Sites (PVI Guidance)

These documents present a recommended framework for addressing the vapor intrusion pathway at USEPA Resource Conservation and Recovery Act, Comprehensive Environmental Response, Compensation, and Liability Act, or Brownfield sites. Of the two documents, the VI Technical Guide is much more substantial and applies to many more sites. The PVI Guidance is limited to releases from underground storage tanks (USTs), while the VI Technical Guide applies to all other sites including petroleum hydrocarbon releases that are mixed with other volatile chemicals or are the result of releases from sources other than USTs.

CSA Group | 7 July 2015

New Version of Oil and Gas Pipeline Systems Standard Expands Requirements for Safety

CSA Group, a standards development organization and a global provider of testing and certification services, has released CSA Z662-15: Oil and Gas Pipeline Systems, the seventh edition of Canada’s primary standard for conditions typically encountered in the wide array of environments that make up the oil and gas industry.

New and extensively updated sections focus on loss-management systems, integrity-management programs, and engineering-assessment processes. A new annex has been added to provide guidance on the development of qualification and welding procedure specifications.

“CSA Group has almost 50 years of history developing standards for the oil and gas industry,” said Gianluca Arcari, CSA Group executive director for standards and vice president. “The new standard will also be our second standard available in an interactive version that can be downloaded to any mobile device and accessed remotely, on the job, when you need it. We’ve had some excellent feedback on our interactive versions, and we plan to continue to modernize and make standards easier to use and more accessible.”

CSA Z662 covers the design, construction, operation, maintenance, deactivation, and abandonment of oil and gas industry pipeline systems used for

  • Liquid hydrocarbons, including crude oil, multiphase fluids, condensate, and liquid petroleum products
  • Natural gas liquids and liquified petroleum gas
  • Oilfield water and steam
  • Carbon dioxide used in oilfield enhanced recovery schemes
  • Gas

A thorough understanding of the requirements of CSA Z662 is a critical element in the safe design, construction, and maintenance of pipeline systems across Canada. CSA Z662 is referenced in legislation by provinces, territories, and the federal government, making it a critical component for industry professionals to understand and apply this standard to help improve safety, reduce risk, and boost productivity in the field. The new edition includes expert commentary directly in the standard document, making it a comprehensive resource when working on pipeline projects in compliance with this national standard.

Key Updates to Z662 include the following:

  • Updates and revisions of the requirements for safety and loss-management systems, integrity-management programs, and engineering-assessments process
  • Expansion of Annex M to address system control, monitoring, and protection for all hydrocarbon pipelines
  • Clarification of requirements for steam-distribution pipelines and high-temperature pipelines
  • Clarification of the sour service requirements for gas-free pipeline systems for crude oil, crude oil blends, and low vapor pressure condensate
  • New Annex to provide guidance on the development of qualification of welding procedure specifications
  • Addition of reference to new standard CSA Z245.30: Field-Applied External Coatings for Steel Pipeline Systems

Read more about the standard here.

Read more about CSA here.

Oil & Gas UK | 1 July 2015

Annual Report Shows Increased Offshore Safety Performance

There have been further improvements in the management of major safety hazards offshore, according Oil & Gas UK’s Health & Safety 2015 Report published 1 July.

Based on incidents reported to the Health and Safety Executive for April 2014 to March 2015 and shared with the trade body, the total number of hydrocarbon releases—oil and gas leaks—has gone down and is at its lowest level ever.

Offshore oil and gas has a lower personal injury rate than many other sectors, including construction, transport, manufacturing, health, retail, and education, the report reveals. The nonfatal injury rate for offshore workers also continues to show a declining trend.

Securing continued effective search and rescue helicopter cover for offshore workers in the central North Sea was a major milestone for the sector. The industry remains focused on aviation safety, with the launch of measures such as a new emergency breathing system for offshore flying and changes to helicopter seating allocation based on passenger size.

Preparing for the introduction into UK law of the EU Offshore Safety Directive—the single biggest shake-up of offshore health, safety, and environment management for a decade—has also been a key focus for the industry.

However, the report did find a growing backlog of safety-critical maintenance on offshore installations.

Robert Paterson, health, safety and employment issues director at Oil & Gas UK, said, “Industry, on the whole, is performing well across a range of safety criteria. However, ours is a major hazard sector where complacency has no place.

“The overall reduction in hydrocarbon releases is to be welcomed, and we must continue our focus on curbing these even further.

“Safe offshore transport remains a priority. 2014 saw the launch of the Civil Aviation Authority’s (CAA) CAP 1145 report into aviation safety. Some of the measures proposed were already under way, but this is an area where progress continues to be made with the CAA, helicopter operators, industry, and trade unions meeting regularly to monitor progress and stimulate action.

“Industry also demonstrated its commitment to safety by funding an offshore search and rescue helicopter service for the central North Sea to ensure the same levels of rescue and recovery service following changes to previous provision.

“Our report did find a growing backlog of safety-critical maintenance offshore, and this is an area that needs close attention. However, decisions on deferring maintenance are taken following robust management systems that assess risk and involve the relevant technical and engineering authorities. All operators are also being encouraged to participate in providing data to all stakeholders to best reflect how the industry as a whole is managing safety-critical maintenance.

“Producing hydrocarbons safely, ensuring assets are operated safely, and transporting our workforce to and from installations safely is of paramount importance to the industry. Despite these difficult times, they must always remain our priority.”

Rigzone | 24 June 2015

BSEE Recognizes Center for Offshore Safety for SEMS Audits

Recent federal regulatory changes now require US outer continental shelf operators to use accredited and independent third parties to audit their safety programs.

The Center for Offshore Safety (COS), which has already certified more than 70 companies, has been recognized by the Bureau of Safety and Environmental Enforcement (BSEE) as the first and currently only official accreditation body for audit service providers.

Previously, companies either performed their own safety audits or would voluntarily use a third party auditors. The 5 June changes to BSEE regulations now means that Safety and Environmental Management Systems (SEMS) audits conducted on the US outer continental shelf must be in compliance with the SEMS II Rule, which requires that the team lead for an audit be independent and represent an accredited audit service provider. SEMS II, finalized in April 2013, is intended to enhance the original SEMS rule, or Workplace Safety Rule, issued in October 2010 in response to the Deepwater Horizon accident earlier that year. SEMS II took effect last year but did not affect the first audit cycle.

Plant Services | 24 June 2015

Column: Risk Scoring Using Your CMMS

With growing automation and more complex assets comes growing risk, where risk is defined as the probability and impact of a negative consequence. In the world of asset management, negative consequences can take many forms, such as premature failure, a more catastrophic failure than anticipated, or an incident or near miss involving an asset. This is why regulatory bodies have increased their vigilance and reporting requirements in almost every industry. It is also why accurate risk scoring using your computerized maintenance management system (CMMS) has risen in importance.

This column provides guidelines and considerations in establishing a risk score. Whatever method you use to generate a risk score must be simple to learn and use but sufficiently comprehensive to be effective in managing total risk.

Objective of a risk score
An effective risk scoring model helps you find the right balance when trying to

  • Minimize risk
  • Maximize asset performance and reliability
  • Minimize the total cost of ownership for your physical assets

Risk scoring ensures you focus on the right work on the right assets at the right time, in order to manage the tradeoffs. Too much attention spent on mitigating every risk is very expensive, but so is ignoring a risk that is highly probable and carries catastrophic consequences. These extremes are obvious, but risk scoring helps manage the more nebulous middle ground.

Occupational Health & Safety | 18 June 2015

Column: Do You Really Know Your Safety Culture?

Theoretically, there is no such thing as a safety culture, but every company has one. Safety is part of all company cultures—great, good, or bad—and we use the term “safety culture” to give it an improvement focus and bookends to manage within. To use or not use the term safety culture is an irresponsible and pointless debate. Beliefs and behaviors specific to desired safety outcomes already exist and shape decisions within an organization. Safety cultures exist; how well do you know yours?

Some believe safety culture as a stand-alone concept is wrong, as it implies safety is in addition to the operational culture. Cultures change when group behaviors and values change; thus, there must be specificity regarding which beliefs, behaviors, and experiences to take on. Depending on the maturity of safety’s role in company priorities and values, such as our best-performing clients, this argument has merit.

To say we shouldn’t view safety as separate from occupational culture when it often is in many companies is painting a picture of utopia without a plan to get there when dystopia is the current reality. Considering your current situation, is safety a shared responsibility and interest or a delegated priority and something to be done in addition to revenue-producing activities? What is common regarding safety?

The way we do things around here, why we do what we do, and what people do when no one is looking are artifacts of culture. Culture is what’s common within a group. Regarding safety, what beliefs, knowledge levels, decisions, observable behaviors, and stories overheard from peers are common within your organization? What needs to be? How clear are you on where the gaps are and the reasons for their existence?

Occupational Health & Safety | 18 June 2015

Column: Three Essentials for Elevating Safety Culture

You’ve likely heard the expression, “There’s no ‘I’ in ‘team’ “? Similarly, there are three I’s in “Global-Class Safety Culture and Performance.” Don’t see them? They’re essential but below the surface, driving significant and lasting injury reduction while winning mindset and active engagement. That’s what I’ve seen in almost 3 decades of working worldwide with a range of companies. Those that best progress from Level 1 to Level 4 safety cultures increasingly foster greater inspiration, involvement, and internalization. And they stimulate all three at the same time.

This progression is the opposite of trying to hit three targets with separate initiatives or interventions; with such a dispersed approach, different budget lines—or even staff—typically focus on their sole arena of responsibility, frequently leading to wasted energy, lack of coordination, or turf pulls. Rather, the most effective strategy aims to concurrently gain three positive results from one movement. It’s like planting a fruit tree that simultaneously provides food, shade, and mental harmony. But there’s one big difference: Planting a fruit tree typically has delayed returns, whereas stimulating involvement, inspiration, and internalization gets desired results relatively quickly, building momentum toward plummeting injury incidence and severity while seriously propelling safety mindset and other cultural improvements.

David Hatch via LinkedIn | 15 June 2015

Column: Have You Got a Tiger in Your (Storage) Tank?

You are probably well aware of the analogy that process safety management is similar to a keeping a tiger (or gorilla) in a cage [i.e., you know the tiger is dangerous (process is hazardous), but you show (operate) it to make money]. You have to care for the tiger to make sure it attracts visitors and also ensure that the containment is suitable to prevent it escaping and potentially killing personnel and public.

So, are your sure that

  • The cage/lock is strong enough (design)
  • You are maintaining the cage/lock (maintenance)
  • Nobody has altered the cage/lock (modifications)
  • The door is not left open (training/procedures)
  • Nothing can crash into the cage (protection)
  • You know what to do if it escapes (emergency response)