introduction to the revised uk offshore safety legislation as impacted by the eu offshore safety...
TRANSCRIPT
Working together for a safer world
Introduction to the Revised UK Offshore Safety Legislation as Impacted by the EU Offshore Safety Directive Ian Mackay - Technical Manager, Compliance Operations Aberdeen How technology and innovation drive optimisation AND safety.
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Agenda
• Introduction
• Legislation
• Major Accident Hazards and Major Environmental Incidents
• Major Changes
• Threats & Opportunities
Brief History of Goal Setting Offshore Safety Legislation
• Introduced in UK in 1992 following Lord Cullen’s enquiry into Piper Alpha disaster
• Applied to all oil & gas producing installations on the UKCS through the full
lifecycle
• Replaced previous prescriptive legislation
• Offshore Installations Safety Case Regulations (OSCR) revised in 2005
• EU Directive on safety of offshore oil & gas operations 2013/30/EU
• New Offshore Installations (Offshore Safety Directive) (Safety Case etc.)
Regulations 2015 (SCR) replaced OSCR in UK 19th July 2015
• Methodology increasingly adopted globally, such as Validation requirements in
Australia and voluntary company schemes.
Piper Alpha – before and after
Timescale for New Regulations
Associated UK legislation
HSAW
SCR
PSR DCR MAR PFEER
EU DIRECTIVE
Goal Setting Offshore Safety Legislation - key features
• Safety case • Concept of duty holder/ responsible operator/owner • As low as reasonably practicable (ALARP) principle • Identification of major accident hazards and major environmental incidents • Identification of safety & environmental critical elements (SECEs) • Concept of ‘suitability’ • Setting of performance standards for SECEs • Verification schemes • Independent and competent person • Matching of assurance and verification effort to risk
Prescriptive vs Goal Setting Legislation
• Prescriptive Industry must comply with regulation Little alignment between risk and effort to comply Little flexibility in interpretation and compliance requirements Can inhibit industry innovation Responsibility can be seen to sit with the regulator Can instil a false sense of security
• Goal Setting Responsibility sits firmly with the owner/operator Achieves desirable outcomes through thorough risk assessment Requires reliable management systems Aligns effort to comply to risk
Key features
Verification Scheme
Performance Standards
Safety & Environmental Critical Elements
Major Accident Hazards/ Major Environmental Incidents
VER
IFICA
TION
Gulf of Mexico, April 2015 Pemex, Abkatun A-Permanent platform explosion At least 4 dead , 16 injured
Pemex
AP
Gulf of Mexico, Bay of Campeche , May 2015 Jack-up rig Troll Solution tilted due to a fault in one of its legs 2 dead, 10 injured
@InforMedia_mx
What are the Major Changes in the UK?
• Formation of a new regulatory Competent Authority (HSE & DECC) known as the Offshore Safety Directive Regulator (OSDR)
• Requirement for inclusion of major environmental incidents as a result of MAH • Identification of SECEs • Additional major hazard indicator reporting requirements under the EU
Implementing Regulation 1112/2014
Major Accident Hazard (MAH) – UK definition
(a) Fire or Explosion
(b) Structural Damage
(c) Diving Life Support System Failure
(d) any other event involving death or serious personal injury to five or more persons
(e) any major environmental incident resulting from any event referred to in
paragraph (a), (b) or (d)
Safety and Environmental Critical Element (SECE) – UK definition
Such parts of an installation and such of its plant
(including computer programmes), or any part thereof
• the failure of which could cause or contribute substantially to, or
• the purpose of which is to prevent or limit the effect of
a major accident or a major environmental incident
What are the Risks?
• Doing nothing and facing enforcement from the Regulator
• Failing to incorporate environmental protection requirements
• Not taking account of the additional major hazard indicator reporting requirements
of the Implementing Regulations
• Loss of reputation for organisation and the UK O&G industry.
What are the Opportunities to Drive Optimisation & Safety?
• Use the next 5 yearly SC resubmission as a vehicle for change
• Update MAH for your installation in light of production & technology changes
• Ensure that your list of SECEs is up to date and doesn’t include ‘gold plating’
• Review SECE performance standards to ensure that they include the requirements
for environmental incident mitigation
• Refresh your inspection and maintenance strategies to ensure that they align with
the performance requirements and verification schemes
• Balance of assurance to risk mitigation in light of any MAH & SECE changes
Summary
• Legislation
• Major Accident Hazards and Major Environmental Incidents
• Major Changes
• Threats & Opportunities