Life in terms of safety is not about to get easier in the North Sea oil&gas industry just because many of the boxes have been ticked in the so-called KP3 review carried out by the Health & Safety Executive.
The outgoing head of the HSE’s oil&gas division, Ian Whewell, told Energy just days before he cleared his desk that keeping the industry safe would never be anything but a relentless grind.
He warned, too, that the HSE would take all necessary steps to prevent any corporate ploys to obfuscate safety and evade responsibility (and liability) through devious, complex ownership of production capacity, particularly floaters.
“Infrastructure’s getting older and companies are looking forward 20 years and more, in some instances, with installations that, 10 years ago, were felt to have no future. This means 30 years on from when they had no future,” said Whewell.
“So with the oil price, new exploration, drilling and production technologies, the outlook has improved dramatically. It means the only way the UK industry is going to survive is to make sure the infrastructure remains in good condition.
“The long-term sustainable future, I think, lies with tie-ins to existing infrastructure. That appears to be the cheapest and most reliable option, which means that the key hubs … installations that provide that … have got to be kept in good condition if there is to be that future. And if they’re kept in good condition then they’re maintaining safety.”
On the relentless change in infrastructure ownership and trend towards using contractors as duty-holders, Whewell said that no one business model was better than others when it came to responsibility for safety.
He pointed out that the correct legislative controls are, in any case, in place to cope with at least that sort of eventuality to ensure that the operating oil company holds ultimate legal responsibility.
“We specifically changed the legislation when we introduced the new safety-case regulations in 2005 in order to make sure that there was no question of companies hiding behind a contractor.
“However, and increasingly, we have companies that are speculatively designing and constructing installations; who are then selling them on to another company … a contractor … to run that installation. Such arrangements involve complex contractual and legal arrangements.
“We’re looking at that at the moment to make sure that we always have direct line of sight to the key players and to make sure we can hold the key players responsible for the risks they create.”
Whewell warned that this was showing signs of becoming a significant issue.
“For that reason, we’re looking at the legislation we have to see what changes may need to be made.
“If we can get the legislative framework right to make sure we can target everyone who’s a risk creator, then that solves the problem.
“But the relationship between these companies and ensuring that the way we regulate and enforce appropriately will be a challenge.
“I think that’s something we’re going to have to have a look at within the organisation (HSE). It’s something my successor’s going to have to consider.”
Whewell added that another huge challenge facing both the HSE and the industry itself is sustaining the momentum that he feels has been created with KP3.
“I think they’ve (the industry) taken on that challenge, but if could very easily fade away.”