Strengthening the Safety Culture of the Offshore Oil and Gas Industry (2016) / Chapter Skim
Currently Skimming:
Pages 89-137
The Chapter Skim interface presents what we've algorithmically identified as the most significant single chunk of text within every page in the chapter.
Select key terms on the right to highlight them within pages of the chapter.
From page 89... ...
89 No regulatory framework for offshore oil and gas operations existed until the 1950s, when growing concerns regarding off-shore jurisdiction led to the passage of two key pieces of legislation. The Submerged Lands Act (SLA)
|
From page 90... ...
90 Strengthening the Safety Culture of the Offshore Oil and Gas Industry Materials Safety Administration (PHMSA) , created within the U.S.
|
From page 91... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 91 has the authority to assess civil penalties.
|
From page 92... ...
92 Strengthening the Safety Culture of the Offshore Oil and Gas Industry When accidents or events that threaten people or equipment occur in the offshore industry, BSEE, USCG, and PHMSA all have roles and duties designed to mitigate loss of life, damage to the environment, and loss of offshore oil and gas production. Hurricane preparedness and response are well practiced and coordinated in the Gulf of Mexico because of the frequency of hurricanes in the area.
|
From page 93... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 93 TABLE 4-1 (continued)
|
From page 94... ...
94 Strengthening the Safety Culture of the Offshore Oil and Gas Industry remainder of this chapter first reviews in turn federal safety management and safety culture initiatives, industry self-regulation and thirdparty initiatives, and international regulation of offshore oil and gas operations. It then considers approaches for advancing safety culture.
|
From page 95... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 95 in which safety is integral to the way the industry does business, and all employees in each company, from roustabouts in the field to executives in the board room, make a total commitment to achieving safety.
|
From page 96... ...
96 Strengthening the Safety Culture of the Offshore Oil and Gas Industry performance reviews of every offshore operator.4 These mandatory performance reviews examined the operator's compliance with safety regulations and its incident record, assessed its progress in implementing SEMP, and addressed topics of concern such as hurricane preparedness and crane safety. In 2002, in response to a request by MMS, members of API and the Offshore Operators Committee (OOC)
|
From page 97... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 97 2.
|
From page 98... ...
98 Strengthening the Safety Culture of the Offshore Oil and Gas Industry SEMS requirements or a SEMS-based regulatory system. Other commenters, however, most notably offshore safety regulators from Norway, Australia, and the Netherlands, recommended a complete SEMS approach.
|
From page 99... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 99 standing of the importance of safety management in minimizing process safety risks during drilling operations (well control)
|
From page 100... ...
100 Strengthening the Safety Culture of the Offshore Oil and Gas Industry the Deepwater Horizon accident,10 with much worse consequences. The root causes of the Montara and Macondo well blowouts were similar.
|
From page 101... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 101 BOX 4-1 Cementing Standards Among well control incidents occurring during 1971 to 1991 and 1992 to 2006, the greatest problem area was cementing operations (see the figure below)
|
From page 102... ...
102 Strengthening the Safety Culture of the Offshore Oil and Gas Industry and actions rather than documentation and paperwork. All of the elements of SEMS must be addressed, but it is much more important that those who are actually doing the work understand and implement SEMS than it is that SEMS documentation be verified with a checklist.
|
From page 103... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 103 BOX 4-2 BSEE SEMS II The SEMS II final rule expanded and revised the existing 30 CFR Part 250, Subpart S, regulations for SEMS and added several new requirements.
|
From page 104... ...
104 Strengthening the Safety Culture of the Offshore Oil and Gas Industry internationally. In addition, COS's influence is limited by the extent of its membership at this point in time.
|
From page 105... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 105 Gas Release Incident Reporting Another requirement that MMS considered was the reporting of gas release incidents, which are important leading indicators of process safety issues.
|
From page 106... ...
106 Strengthening the Safety Culture of the Offshore Oil and Gas Industry In contrast with deepwater production facilities, deepwater drilling operations have been regulated in a more traditional manner, and their performance record has not been exceptional. The overall fatality rate for deepwater wells has been higher than that for shelf drilling -- 0.0072 versus 0.0048 fatalities per well (see Table 4-2)
|
From page 107... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 107 on December 20, 2012.
|
From page 108... ...
108 Strengthening the Safety Culture of the Offshore Oil and Gas Industry agencies. Most of the regulatory changes in the immediate aftermath of the Deepwater Horizon accident reinforced this traditional compliance culture instead of emphasizing management systems, risk assessment, operator responsibility, and safety culture.
|
From page 109... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 109 to those that do occur with prompt and appropriate regulatory action.
|
From page 110... ...
110 Strengthening the Safety Culture of the Offshore Oil and Gas Industry It addresses the responsibilities of those who manage and operate ships and MODUs and prescribes international standards for carrying out those responsibilities, including pollution prevention, safely. To this end, the code requires that ships, MODUs, and offshore support vessels have safety management systems.
|
From page 111... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 111 concept is extremely valuable, particularly in its balanced approach to risk management and its emphasis on partnership.
|
From page 112... ...
112 Strengthening the Safety Culture of the Offshore Oil and Gas Industry 147 [Federal Register 2013]
|
From page 113... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 113 average from 1991 to 2000)
|
From page 114... ...
114 Strengthening the Safety Culture of the Offshore Oil and Gas Industry Act of 2002 (P.L.
|
From page 115... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 115 BOX 4-3 Core Elements of Integrity Management Programs for Pipeline Operators • Identifying all locations where a pipeline failure might impact an HCA.
|
From page 116... ...
116 Strengthening the Safety Culture of the Offshore Oil and Gas Industry Building on the RP 75 experience, members of the RP 1173 committee added new elements, most notably safety culture, to the PSMS. RP 1173 includes indicators of a positive safety culture within an organization and also addresses evaluation of a safety culture29: The pipeline operator shall establish methods to evaluate the safety culture of its organization.
|
From page 117... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 117 • The organization is fair and consistent in responding to safety concerns.
|
From page 118... ...
118 Strengthening the Safety Culture of the Offshore Oil and Gas Industry company HSQE personnel audit records on each offshore platform or rig regularly. After the Deepwater Horizon accident, BSEE made API RP 75 mandatory for all offshore operators by incorporating it into the SEMS regulations.
|
From page 119... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 119 COS could be even more effective in encouraging safety management practices across the industry if its members and associate members represented a larger cross section of the industry.
|
From page 120... ...
120 Strengthening the Safety Culture of the Offshore Oil and Gas Industry Shortly after the commission issued its report in 1979, the leaders of the nuclear industry created INPO as a nonprofit organization. INPO's mission is "to promote the highest levels of safety and reliability -- to promote excellence -- in the operation of commercial power plants."35 The immediate past chief executive officer (CEO)
|
From page 121... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 121 these criteria, but it is not independent and does not represent all offshore operators (see Box 4-4 for the COS mission and objectives)
|
From page 122... ...
122 Strengthening the Safety Culture of the Offshore Oil and Gas Industry Role of Third-Party Organizations The U.S. government recognizes certain third-party organizations, including classification societies, independent training institutions, and testing laboratories, as capable of acting on behalf of the government regulators.
|
From page 123... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 123 of the operating companies and contractors, the presence of national oil companies and the manner in which such public entities are regulated, the respective roles of existing agencies, the role of labor organizations, the government's familiarity with the maritime industry, the presence of onshore energy and mineral development activities, cultural factors, and outside influences (neighboring countries, foreign assistance programs, trade organizations, and international companies)
|
From page 124... ...
124 Strengthening the Safety Culture of the Offshore Oil and Gas Industry So, since 1985 we have systematically worked on revising our detailed regulatory specifications. We introduced a new kind of regulatory portfolio with just a few regulations mainly stating what should be accounted for by the duty holders.
|
From page 125... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 125 the importance of management systems, performance standards, skilled regulators, and active communication between operators and regulators: In many countries the offshore industry is developing faster than the government's ability to regulate them [sic]
|
From page 126... ...
126 Strengthening the Safety Culture of the Offshore Oil and Gas Industry or international regulations. PSA also created a pamphlet40 intended to be a useful tool for the industry in developing an effective HSE culture.
|
From page 127... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 127 • Government and industry should promote an improvement mentality, not a compliance mentality.
|
From page 128... ...
128 Strengthening the Safety Culture of the Offshore Oil and Gas Industry factors that inspectors may observe in the field that are indicators of strong safety culture."42 Internationally, much work remains to be done to enhance the safety culture of the offshore industry. Continuous improvement is dependent on timely, comprehensive, and verified international incident data that can be used to answer such important questions as the following: • Where are incidents occurring and why?
|
From page 129... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 129 APPROACHES FOR ADVANCING SAFETY CULTURE How Regulators Can Best Influence Safety Culture in the U.S.
|
From page 130... ...
130 Strengthening the Safety Culture of the Offshore Oil and Gas Industry regulators collectively as "the government," but when introducing safety culture initiatives, regulators also will need to assume the role of participants in the effort to strengthen safety cultures across the industry. The respective roles of operators and regulators need to be clearly delineated, as well as part of an overarching vision for the regulatory program.
|
From page 131... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 131 Elsewhere in the world, classification societies perform most of the compliance and auditing duties that have been reserved for USCG and BSEE in the United States.
|
From page 132... ...
132 Strengthening the Safety Culture of the Offshore Oil and Gas Industry To this end, the following specific steps should be taken: • Required participation in an independent industry organization dedicated to safety leadership and achievement. COS has made excellent progress in establishing data gathering and SEMS support programs, and could fulfill this role.
|
From page 133... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 133 Recommendation 4.2.2: Because accident, incident, and inspection data all are needed to identify and understand safety risks and corrective actions, the committee recommends full transparency such that regulators make all these data readily available to the public in a timely way, taking into consideration applicable confidentiality requirements.
|
From page 134... ...
134 Strengthening the Safety Culture of the Offshore Oil and Gas Industry and methods, such that operators with good performance records are subject to less frequent or less detailed inspections. Inspectors should consider shifting from traditional compliance inspections to inspections that follow the safety management approach outlined in the SEMS rule.
|
From page 135... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 135 or would industry be accountable for making membership a condition for participating in offshore work?
|
From page 136... ...
136 Strengthening the Safety Culture of the Offshore Oil and Gas Industry RP 1173, that includes safety culture elements. The inclusion of safety culture elements will encourage companies to fully integrate cultural considerations into their management programs.
|
From page 137... ...
U.S. Offshore Safety Regulation Pertaining to Safety Culture 137 (P.
|
Key Terms
This material may be derived from roughly machine-read images, and so is provided only to facilitate research.
More
information on Chapter Skim is available.