Beyond Compliance: Strengthening the Safety Culture of the Offshore Oil and Gas Industry (2016)

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8 Beyond ComplianCe and Environmental Management Systems (SEMS) rule in an effort to improve offshore operations. The rule required operators to implement a SEMS pro- gram addressing all elements of API’s RP 75. BSEE subsequently revised the SEMS rule, and a new rule, called SEMS II, became effective in June 2013. SEMS II promotes employee participation and the empow- erment of field-level personnel. The need for a new approach: Building a Strong Safety Culture Prior to 2010, the U.S. offshore industry had not ex- perienced a catastrophic accident in many years. That trend ended in 2010. The Deepwater Horizon–Ma- condo blowout, explosion, and spill illustrated that the focus of industry and government regulators on improving equipment, design, and occupational safety and attributing accidents to human error was insuf- ficient to prevent such incidents. Several reports4 on safety in the offshore oil and gas industry issued in the aftermath of this disaster emphasized that compli- ance with government regulations alone is inadequate to create and maintain a safe working environment offshore. Rather, a fundamental transformation of the offshore oil and gas industry’s safety culture is needed to reduce the risk of accidents offshore. Characteristics of a Strong Safety Culture The term safety culture was coined by the Interna- tional Nuclear Safety Advisory Group during its 4 Reports issued by the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling; the National Academy of Engineering and the National Research Council; the U.S. Coast Guard; and the Bureau of Ocean Energy Management, Regulation, and Enforce- ment Joint Investigation Team. enDosToCk/DReamsTime

Strengthening the Safety Culture of the Offshore Oil and Gas Industry 9 investigation of the Chernobyl power plant accident in 1986. Since then, the definition of safety culture and the identification of the factors that strengthen such a culture have evolved. At its core, however, safety culture remains an aspect of the larger organizational culture, encompassing the organization’s values, beliefs, attitudes, norms, practices, competencies, and behaviors regarding safety. Safety management systems such as SEMS are necessary, but not sufficient, to foster a robust safety culture. In many respects, SEMS provides a framework, or set of processes, for moving beyond compliance with specific safety regulations. A strong safety culture embodies the commitment of the organization and of each individual em- ployee to working in a manner that truly enhances safety—a need height- ened by the technical challenges posed by the offshore environment, which are exacerbated as activities move into harsher conditions, such as those associated with deeper water. In May 2013, BSEE issued a policy statement defining safety culture as “the core values and behaviors of all members of an organization that re- flect a commitment to conduct business in a manner that protects people and the environment.” In issuing this policy statement, BSEE noted its commitment to a regulatory approach that would lead the offshore oil and gas industry beyond checklist inspections toward a systematic, compre- hensive safety regime. The statement identifies nine characteristics of a robust safety culture (described on page 11): Joel saRToRe/naTional geogRaphiC

10 Beyond ComplianCe • Leadership commitment to safety values and actions, • A respectful work environment, • An environment for raising concerns, • Effective safety and environmental communication, • Personal accountability, • An inquiring attitude, • Hazard identification and risk management, • Work processes, and • Continuous improvement. In developing its list of characteristics, BSEE relied heavily on the safety culture attributes defined by the nuclear power industry. BSEE’s list mirrors leading scholarly reviews of safety culture research and frame- works in other industries, and is grounded in empirical research. ReCommendaTion: The offshore industry and government regula- tors should adopt the Bsee definition of safety culture and its essential elements as a guide for assessment and practice. Although the offshore industry would benefit from adopting BSEE’s nine characteristics of an effective safety culture, the list is not well known in the industry. Nor does BSEE have the means to move the entire off- shore industry closer to these desired characteristics. ReCommendaTion: The secretary of the interior, in cooperation with the Commandant of usCg, should seek prominent leaders in the off- shore industry to champion the nine characteristics of an effective safety culture identified by Bsee, develop guidance for safety culture assess- ment and improvement, and facilitate information exchange and sharing of experiences in promoting safety culture. ReCommendaTion: The industry as a whole should create addi- tional guidance for establishing safety culture expectations and responsi- bilities among operators, contractors, and subcontractors. Once the industry has agreed upon steps to take to achieve safety and environmental objectives, each organization involved in the offshore oil

Strengthening the Safety Culture of the Offshore Oil and Gas Industry 11 nine Characteristics of a Strong Safety Culture leadership commitment to safety values and actions—lead- ers demonstrate a commitment to safety and environmental stewardship in their decisions and behaviors. leaders visibly demonstrate this commitment through how they allocate resources within the organization and prioritize safety relative to production. Respectful work environment—Trust and respect permeate the organization, with a focus on teamwork and collaboration. environment for raising concerns—a work environment is main- tained in which personnel feel free to raise safety and environmental con- cerns without fear of retaliation, intimidation, harassment, or discrimination. effective safety and environmental communication—Com- munications maintain a focus on safety and environmental stewardship. knowledge and experience are shared throughout the organization. personal accountability—all individuals take personal responsibility for process and personal safety, as well as environmental stewardship. inquiring attitude—individuals avoid complacency and continuously consider and review existing conditions and activities in order to identify discrepancies that might result in error or inappropriate action. Workers are expected to question work practices as part of everyday conversations without hesitation. Hazard identification and risk management—issues potentially impacting safety and environmental stewardship are promptly identified, fully evaluated, and promptly addressed or corrected commensurate with their significance. Work processes—The process of planning and controlling work activi- ties is implemented in a manner that maintains safety and environmental stewardship while ensuring use of the correct equipment, used in the correct way, for the correct work. Continuous improvement—opportunities to learn about ways to en- sure safety and environmental stewardship are sought out and implemented. source: Bsee, 2013. anTaRTis/DReamsTime