A top offshore safety watchdog has “deep concern” that barriers to prevent potentially deadly hydrocarbon releases (HCRs) from North Sea platforms have been “degraded” amid the pandemic.
Chris Flint, director of the Health and Safety Executive’s energy division, said the problem was linked to a maintenance backlog which has further built up during the lockdown.
Flint said his team and operators are in “constant dialogue” to make sure the backlog is addressed and that safety critical equipment is prioritised.
He did say industry’s response to Covid-19 was a “real positive” and boded well for its efforts to address HSE’s concerns — if the same energy levels can be carried over.
Statistics also indicate that reported HCRs did go down in 2020, though progress in this area is rarely linear and Flint and his team are, as ever, on high alert.
One of the first things which likely comes to mind when people in North Sea circles hear Flint’s name is the strongly-worded letter he wrote to industry in 2018.
He warned there had been several major leaks that had come “perilously close” to causing a “disaster” and ordered operators to explain how they would get HCRs in check.
Flint said the concerns he raised in 2018 hadn’t gone away.
The pandemic caused the year-long deferral of the Forties Pipeline System (FPS) shutdown.
This held up many firm’s plans to carry out extensive maintenance work on their installations while the system was offline.
The FPS shutdown eventually started in May 2021 and completed last month, giving companies a chance to catch-up.
Vaccination rollouts and the general easing of lockdowns also meant operators could increase offshore manning back to March 2020 levels.
More bodies offshore means the drive to tackle the backlog can accelerate.
However, it is still there and remains a “key focus” for HSE.
“If you’ve got this backlog building up, that’s not going to make things any easier,” Flint said.
“We’ve had meetings with industry recently to reiterate the fact we’re still seeing incidents and are very much aware of the backlog and the need to maintain a chronic sense of unease.
“There are still incidents occurring, which suggests that the letter I wrote in 2018 still holds true.”
© SYSTEMCovid-19 also “got in the way” of industry’s work on a range of objectives aimed at addressing the challenges set out in the letter.
In November 2019, the UK oil and gas industry signed up to adhere to eight Process Safety Leadership Principles.
Those include requiring senior leadership team involvement and competence in safety management, putting process safety leadership at the core of a business to ensure risks are properly managed, and engaging and involving the workforce in managing safety.
Flint said this commitment led to a lot of work for operators and stakeholder groups.
Industry is now “getting back after” that work, with the pandemic abating.
Initiatives include the formation of workgroups to share good practice for maintenance, venting and flaring, operational risk, management of change, and isolation and reinstatement of plant.
Each of these can lead to major accident hazards (MAHs) like HCRs. Flint highlighted isolation and reinstatement of plant as a particularly thorny area.
“When we see major turnarounds like FPS, it means isolating a lot of equipment and plant,” he said.
“Then, at some point, you have to reinstate it, so you need to make sure processes and procedures around that are tight and well managed otherwise we do see HCRs.”
On HCR occurrences, Flint said there had been a 25% decrease to 94 last year, based on provisional statistics.
This reversed the increase of around 25% to 126 in 2019.
None of last year’s HCRs have been classified as “major”, so far, while the number of “significants” dropped to 39 from 53.
Flint said it was a bad idea to get “fixated” on the statistics or categories, as all HCRs can escalate and lead to catastrophe.
He pointed out that the “initiating event” that resulted in the Piper Alpha disaster of 1988, which claimed 167 lives, would have been classified as significant, not major, which is the worst category.
“Majors are a big concern, but significants are still important, so you need to manage those down as well,” Flint said.
“The backlog and activity going on out there now could all result in incidents if the work is not carefully managed.
“HCR performance is not just about the numbers, it’s about the strength of barriers the operators have got in place and making sure they work when called upon.
“Through our inspections we are seeing a degradation of HCR barrier strength and are feeding that back to industry.
“We’re focusing a lot of effort around that.”
Examples of barriers include hardware, software, procedures and policies, and training and competence of staff.
Having multiple barriers in place means that if one is weak, it might not lead to an issue.
If two or three are down, it could lead to a MAH.
Flint said: “Because of the backlog, some of the barriers are impacted and we are finding failings in those areas when we go out there, so we have got deep concern.
“We need industry to stay focused on maintenance activities, in the right places.
“It’s about prioritisation. You could spend a lot of time and energy on things that are great to do, but might not have positive impact on the safety critical equipment we need to see maintained.”
Reflecting on the pandemic, Flint said the early formation of a dedicated steering group by OGUK was crucial and that he would hope to see the same response if something similar happened again.
He said industry had shown “dynamic leadership” in crisis and a “can-do attitude”.
There are lessons from the pandemic that he expects to become part of regular North Sea operations, such as hygiene arrangements for maintaining a healthier workforce.
As for HSE, the organisation initially had to pause physical offshore inspections to give operators time to review their measures.
Flint was pleasantly surprised by how much could be achieved using communication platforms like Teams to optimise front-end planning for offshore visits, and post-trip feedback.