OFFSHORE SAFETY CASE AND ITS FUTURE
result of the accident on Piper Alpha on
6th July 1988
when 165 people died a Public Enquiry was held under the
chairmanship of Lord Cullen, a Senator of the College
Justice in Scotland. The
enquiry sought to answer two questions
What were the causes and circumstances of the disaster on the Piper Alpha
platform on 6th
What should be recommended with a view to the preservation of life and
the avoidance of similar accidents in the future.
that time offshore structures both mobile and fixed had operated under the
“Mineral Workings (Offshore Installations) Act 1971" under which a number
of Statutory Instruments were added to the original legislation, all of them being
policed by the UK Department of Energy and the Department of Transport.
enquiry’s findings are contained in two volumes and resulted in 106 separate
recommendations. The first 13 of the recommendations relate directly to the
provision of a Safety Case for every offshore installation whether fixed or
Cullen had borrowed the concept of the Safety Case – making the case for
safety – from the nuclear industry. Here it had been deemed essential that all
risks should be identified and means found to reduce them to a level considered
to be as low as reasonably practicable. It was necessary in the nuclear industry
since an accident could result in fall-out over a large area, with consequent
deaths in the community. Subsequent to the Flixborough chemical accident in 1974
Safety Cases were also introduced for chemical plants.
The recommendations contain the following statements, which are particularly
pertinent to the manner in which the risk assessment is carried out and the
resulting recommendations acted on:
that the potential major hazards of the installation and the risks to
personnel thereon have been identified and appropriate controls provided.
A demonstration that so far as is reasonably practicable the exposure of
personnel on the platform to accidental events and their consequences has been minimised.
words “so far as is reasonably
practicable” are derived from the ALARP principle which states that risks must be “as low as is reasonably practicable.”
statements indicate the requirement for the industry to move from a prescriptive
form of legislation to a goal setting form of legislation.
Cullen Enquiry recommendations typically target SI611, which deals with fire and
explosion risk and mitigation, for revision under goal setting legislation asfollows:
The regulations and related guidance notes should promote an approach to fire and explosion protection:-
which is integrated as between –
and passive fire protection
forms of passive fire protection such as fire insulation and platform layout and
protection and explosion protection.
in which the need for, and the location and resistance of, fire and blast
walls is determined by safety assessment rather than by regulations.
in which the function, configuration, capacity, availability and
protection of the fire water deluge system is determined by safety assessment rather than by regulations.
which facilitates the use of scenario based design method for fire protection as an alternative to the reference area method.
which provides to a high degree the ability of the fire water deluge
system, including the fire pump system, to survive severe accident conditions.
above is an example of the manner in which Lord Cullen required the industry to
move from prescriptive legislation to goal setting legislation. It is also an
illustration of the manner in which the recommendations, and subsequently the
legislation, concentrates on accidents to fixed platforms. This bias has
required considerable interpretation of the legislation on the part of the
operators of mobile units and also considerable interpretation by the HSE
assessors of the mobile unit Safety Cases.
THE SAFETY CASE LEGISLATION
result of the Cullen recommendations the HSE were appointed as the single
regulatory body for offshore safety, and the HSE legal departments framed the
Safety Case Legislation in a manner which followed the Cullen recommendations
for goal setting legislation and which also caught some existing prescriptive
resulting statutes are as follows:
Installations (Safety Case) Regulations 1992
Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995
Installations and Wells (Design and Construction, etc) Regulations 1996.
Installations and Pipeline Works (Management and Administration) Regulations 1995.
Safety Case regulations require that the Safety Case should demonstrate the
that the management system is adequate to ensure compliance with the statutory health and safety requirements.
that adequate arrangements have been made for audit and the preparation of audit reports.
that all hazards with the potential to cause major accidents have been
identified, their risks evaluated, and measures taken to reduce risks to persons
to as low as reasonably practicable.
particular to deal with item iii) MMASS have developed a comprehensive means of
identifying and assessing risks and determining means of reducing the risks to
ALARP (As Low As Reasonably Practicable). The means involves a qualitative study
carried out by a team on board the Installation and a quantitative study to
calculate the level of risk for each identified major accident hazard.
Safety Case Regulations were well in place and the first versions of all Safety
Cases presented when the PFEER (Prevention of Fire and Explosion and Emergency
Response) Regulations came into force in 1995.
are some who consider that the PFEER Regulations do nothing to improve on the
Safety Case Regulations, however they do emphasise certain aspects, particularly
the requirement for performance standards. The introduction to the PFEER
Regulations contains the following:
PFEER Regulation 5 specifies requirements for a fire and explosion and
evacuation escape and rescue assessment. The results of that assessment will
contribute to the demonstration required by the Safety Case Regulations.
In addition the PFEER Regulations specify goals for preventative and
protective measures for managing fire and explosion hazards, and emergency
response. Complying with these Regulations, taking into account the practical
guidance contained in this publication, will facilitate HSE’s acceptance of
the Safety Case. The regulations are in general expressed as broad goals rather
than specific requirements, allowing the duty holders the flexibility to develop
detailed arrangements in the light of hazards, plant configuration and other
circumstances specific to the installation.
summarise, the PFEER Regulations require operators to assess the measures in
place to prevent, prepare for and mitigate major accidents in terms of
personnel, procedures and systems.
“systems” component is the identification of Safety Critical Elements which
must be assessed in terms of functionality availability and survivability.
operators, including the owners of mobile units, are required to set their own
standards for safety critical equipment and ensure that the equipment installed
on their units are up to that standard. The equipment must fulfil the required
function, it must be reliable and it must be able to survive. The standards used
can be taken from any suitable source or can be written specifically for that
equipment. For instance mobile unit operators are likely to chose API RP53 as
the standard for drill through equipment, and the SOLAS Regulations as the
standard for its Lifesaving equipment.
initial argument by some operators that the Safety Case already contained a
PFEER Assessment, due to some pressure from the HSE this document is now almost
always presented separately. If the compiler rigorously follows the regulations
it will contain descriptions of the scenarios and demonstrations of the
relationship between the personnel, systems and procedures and suitable
check-lists to ensure that all requirements are fulfilled.
the Design and Construction Regulations, which rest uneasily next to the PFEER
Regulations require that the Safety Critical Elements already identified be
formed in to a “Verification Scheme,” which will ensure their continued
operational efficiency during the lifetime of the rig. This Verification Scheme
takes the place of the Certificate of Fitness.
Introduction to the Regulations states:
The overall objective of the offshore verification scheme is to set in
place independent and competent scrutiny of those parts of an installation which
are critical to safety (referred to in these Regulations as Safety Critical
Elements). The purpose of this scrutiny is to obtain assurance of the
achievement of the satisfactory condition of such items.
operators and owners chose to combine the Performance Standard requirements of
the PFEER Regulations with the Verification requirements of the Design and
Construction Regulations. This is often known as a "Combined Scheme."
Safety Case Regulations require the Duty Holders to put in place means of
identifying and reducing risks using the latest available technology, and so it
is expected that, at each three year revision there will be recommendations
made, although it is likely that they will become less costly as time passes.
operators present identical Safety Cases at the time of the three year review on
the basis that nothing has changed since their presentation of the last one.
Patently this cannot possibly be true, or if it is true then surely they cannot
have applied the latest technology in order to maintain risks at ALARP, which
you will remember stands for "As Low As Reasonably Practicable."
it has seemed to many professional safety case practitioners that the pursuit of
risk reduction in terms of major accidents has been sacrificed due to the
regulator's and therefore the operator's, preoccupation with occupational hazards.
It is a
laudable objective to reduce the possibility of injury or death by improving day
to day work practices, but the increasing tendency of operators to hire or fire
subcontractors on the basis of their occupational safety record has resulted in
the preoccupation of the majority of safety departments with day to day safety
statistics, and the development of complex risk reduction programmes and
impenetrable procedures. And here it is difficult not to mention the tendency
for teams of HSE inspectors to swoop on installations after any reportable
incident at a cost of £110 per hour each.
recruits its inspectors from all areas of industry, and with the greatest
respect for their commitment to safety, there are some in the offshore industry
who feel that they cannot evaluate risks within the marine environment,
particularly on mobile units, without a professional marine background. This and
the constant cost cutting exercises which result in a lack of professional
expertise on floating units has caused some to believe that there are major
accidents just waiting to happen out there, but that it will take an Ocean
Ranger incident in the North Sea to wake up the operators, the owners and, most
importantly, the regulator.
for Marex Offshore Review August
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