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As a 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 of Justice in ScotlandThe enquiry sought to answer two questions

1.         What were the causes and circumstances of the disaster on the Piper Alpha platform on 6th July 1988, and

2.         What should be recommended with a view to the preservation of life and the avoidance of similar accidents in the future.

Up to 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.

The 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 mobile. 

Lord 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:

2.ii       that the potential major hazards of the installation and the risks to personnel thereon have been identified and appropriate controls provided.

4.ii       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.

The 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.”

These statements indicate the requirement for the industry to move from a prescriptive form of legislation to a goal setting form of legislation.

The Cullen Enquiry recommendations typically target SI611, which deals with fire and explosion risk and mitigation, for revision under goal setting legislation asfollows:

50.       The regulations and related guidance notes should promote an approach to fire and explosion protection:-

i.          which is integrated as between –

-         active and passive fire protection

-         different forms of passive fire protection such as fire insulation and platform layout and

-         fire protection and explosion protection.

ii.         in which the need for, and the location and resistance of, fire and blast walls is determined by safety assessment rather than by regulations.

iii.        in which the function, configuration, capacity, availability and protection of the fire water deluge system is determined by safety assessment rather than by regulations.

iv.        which facilitates the use of scenario based design method for fire protection as an alternative to the reference area method.

v.         which provides to a high degree the ability of the fire water deluge system, including the fire pump system, to survive severe accident conditions.

The 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.


As a 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 regulations.

The resulting statutes are as follows:

Offshore Installations (Safety Case) Regulations 1992

Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995

Offshore Installations and Wells (Design and Construction, etc) Regulations 1996.

Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995.

The Safety Case regulations require that the Safety Case should demonstrate the following:

i)          that the management system is adequate to ensure compliance with the statutory health and safety requirements.

ii)         that adequate arrangements have been made for audit and the preparation of audit reports.

iii)        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.

In 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.

The 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.

There 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:

8.         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.

9.         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.

To 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.

The “systems” component is the identification of Safety Critical Elements which must be assessed in terms of functionality availability and survivability.

Broadly 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.

Despite 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.

Finally 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.

The Introduction to the Regulations states:

4.         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.

Most 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."


The 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.

Some 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."

Indeed, 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.

The HSE 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.  

Written for Marex Offshore Review  August 2002.



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