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 On 27th November 2003 the Oil Industry in the UK held a one day conference to consider the future of the Safety Case. 

It started with breakfast. Disappointingly there were no fried eggs, and so those of us who now normally eat a healthy breakfast due to pressure from our partners or sheer laziness, were unable to experience the delights of an egg yoke running over, and soaking the fried bread . Indeed it is possible that this risky activity had been banned on health grounds. Never-the–less some of us were able to have scrambled egg, sausage and bacon and consume them while listening to Des Brown, Minister of State, Department for Work and Pensions. Apparently his is the department ultimately in charge of the HSE and so has an interest in the way in which the regulations may change, and therefore the proceedings of the conference. Unfortunately Mr Browne himself had urgent appointments elsewhere and had to leave after the breakfast, but other very important people from the HSE remained to generally support the safety case regime and to take the flack from the members of UKOOA and IADC who were present. 

The conference itself actually took the form of four separate sessions with panel members speaking on a topic and then questions and comments being encouraged from the floor. 

First of all some-one from the HSE spent half an hour telling us the regulations were going to change, and then telling us what the changes would be. The delegates also had a revised set of regulations to look at. There are really two big changes proposed. The first is that the safety case review periods should be changed from three to five years, and the second is that the combined operations safety case should be a part of the normal safety case. 

After this presentation we heard four discussions from the podium, the first titled “Is the Safety Case Regime Fit for Purpose?”, the second entitled “Who is the Safety Case For?”, the third entitled “Accountabilities and Working Together” and the fourth “Making the Safety Case Regime Work”. 

“Hang on!”, I hear you say, “what’s happened to the new regulations. Is no-one going to discuss them?”

 Surprisingly the answer is no, apart from various remarks by HSE personnel about how the reduction in the frequency of review would give the HSE inspectors more time to get out there and meet people and keep up with what was going on. And probably nothing much would be different in three years anyway. In truth it was quite difficult to relate the proposed new rules to the conference. 

Mind you, we were impressed by the presence of a number of very important people including Timothy Walker, Director General of the HSE, who chaired one of the discussions, and Margaret Burns Commissioner, Health and Safety Commission, who chaired another. 

The discussions themselves really dealt with two themes, the first that there was insufficient worker consultation and the second that there were too many Issue Notes, and if you have read this far without already having an intimate knowledge of the issues and the safety case regime in general it would seem appropriate to offer both congratulations and a bit of information about the background. 

The Safety Case Regulations and their Guidance have always prompted the owners of Installations to consult with the workforce on the various aspects of the safety case, but the problem is that the safety case is a very technical document and its development has become very specialized, to the point that most operators find that it is essential to use safety professionals – probably on a subcontract basis. The two main parts of the document, the technical description and the risk assessment, take research and calculation respectively and neither task can be taken on lightly. Describing the components of offshore installations in words is often difficult and even though drawings are always included, even reading a drawing takes practice.

 The risk assessment process is even more difficult. Lord Cullen required that “suitable and sufficient QRA” should be undertaken to determine the level of risk to persons on the installation, and doing QRA is even more specialized. The results, expressed in terms such as “10E-3” are even less accessible than the technical description. Hence it seems unrealistic not to use specialists and it is difficult to consult with the workforce.

 The second problem – Issue Notes – relates more to the cost of the HSE services than the Issue Notes themselves. All Safety Cases must be reviewed by each of the specialist topic units in the HSE and so a dozen Safety Cases will be printed by the dutyholders and taken to the HSE Offshore Safety Division headquarters, Lord Cullen House. Subsequently the assessors will start to ask questions about the safety case. These are Issue Notes. Answering Issue Notes used to be the only cost for the dutyholders, although they found this onerous enough, requiring as it did, more specialist input. But now the HSE charge for their services by the hour, so the more Issue Notes there are, the higher the cost.  And the cost of an HSE assessor is about £160 per hour. Even the assessment of a safety case which creates no Issue Notes costs several thousand pounds.

 Several of the speakers, within the general Issue Note exchange, brought up the subject of assessor hobbyhorses, and here there does seem to be a real problem for the HSE to solve. Any of the assessors are in a position to stop the safety case acceptance process dead in its tracks if they raise a Level 1 Issue Note, and in reality it could be about anything, because there is no means of appeal for the dutyholders. This interaction goes like this:

 The assessor asks that a particular risk or problem or statement be addressed. The dutyholder is reluctant to do the required work. The assessor says that if it is not done the safety case will not be accepted. Since we would now be about five weeks from the dropdead date, after which the installation would be unable to operate due to lack of an accepted safety case, the dutyholder has no option but to comply.

 HSE hobbyhorses would probably make a separate article on their own, but a couple are the use of the personnel basket for evacuation and the 10,000 year storm. I am tempted to go further into this, but suffice it to say that Taf Powell, head of the HSE OSD said they would look into it.

 Getting back to the worker consultation then, and the spectre of the Safety Case “gathering dust” on the OIM’s office shelving instead of being thumbed through constantly be interested workers. This topic seemed to be a cue for the trades unionists to have a bit of a go at the operators, possibly the most vocal being Roger Spiller the General Secretary of Amicus who spoke from the floor. Jake Malloy of OILC also spoke from the podium within the session “Who is the Safety Case For”. Of course these guys were less inclined to talk about the safety case than about the perceived wrongs being done to the workforce which would be unlikely to be corrected even if a representative number of the installation crew committed the safety case to memory.

 It generally makes you wonder where it is all going. Correct me if I’m wrong but we seem to be advocating a reduction of HSE input, from the guys who actually understand what the safety case is about and will be able to tell whether a case for safety is actually being made, and an increase in the input from the workforce who will only know whether a case for safety is being made if they understand the numbers. If they do understand the numbers they will probably be safety engineers. If I were a member of the workforce I would be inclined to put my trust in the HSE.

 The last session was called “Making the Safety Case Work” within which Ciaran McIntyre, who is some-one very important in Lloyds Register, contrasted some of the industry golden rules with other lesser rules. He suggested that rules such as no-one carrying knives offshore, no-one carrying matches offshore are never broken, where-as rules such as not letting fire pumps go down are often broken. Absolutely no-one commented on his speech, which may have been a failure on the part of the facilitator. But it was a statement which followed up on a representation made to the HSE by the classification societies that Verification is not working.

 And if you find yourself asking what verification is, it may be best to have a look at last month’s feature about the Ghost Ships of Hartlepool because everybody seems to understand about the environment.

 As well as the large numbers of oil industry people from the UK, the conference was also attended by personnel from Norway, Australia, Denmark Holland, America, and the Faeroes.  What they made of it all I can’t imagine.

 Vic Gibson December 2003



Deepwater Horizon -The President's Report
Deepwater Horizon - The Progess of the Event

The KULLUK Grounding
The Costa Concordia Report
The Costa Concordia Grounding
The Elgin Gas Leak
The Loss of the Normand Rough
The Bourbon Dolphin Accident
The Loss of the Stevns Power
Another Marine Disaster
Something About the P36
The Cormorant Alpha Accident
The Ocean Ranger Disaster
The Loss of the Ocean Express

The Life of the Oil Mariner
Offshore Technology and the Kursk
The Sovereign Explorer and the Black Marlin

Safety Case and SEMS
Practical Safety Case Development
Preventing Fires and Explosions Offshore
The ALARP Demonstration
PFEER, DCR and Verification
PFEER and the Dacon Scoop
Human Error and Heavy Weather Damage
Lifeboats & Offshore Installations
More about PFEER
The Offshore Safety Regime - Fit for the Next Decade
The Safety Case and its Future
Collision Risk Management
Shuttle Tanker Collisions
A Good Prospect of Recovery

The History of the UT 704
The Peterhead Connection
Goodbye Kiss
Uses for New Ships
Supporting Deepwater Drilling
Jack-up Moving - An Overview
Seismic Surveying
Breaking the Ice
Tank Cleaning and the Environment
More about Mud Tank Cleaning
Tank Cleaning in 2004
Glossary of Terms

An Unusual Investigation
Gaia and Oil Pollution
The True Price of Oil
Icebergs and Anchor-Handlers
Atlantic SOS
The Greatest Influence
How It Used to Be
Homemade Pizza
Goodbye Far Turbot
The Ship Manager
Running Aground
A Cook's Tale
Navigating the Channel
The Captain's Letter

The Sealaunch Project
Ghost Ships of Hartlepool
Beam Him Up Scotty
The Bilbao OSV Conference