The Risk Management Tool Box Blog

NOPSEMA has published a report prepared by an independent expert witness in relation to the Montara wellhead platform blowout on 21 August 2009 involving PTTEP AA.

Colin Stuart provided an expert opinion to assist in the investigation of the incident and to support the brief of evidence referred to the Commonwealth Director of Public Prosecutions.

The report provides comprehensive consideration and analysis of the events leading up to, and immediately following, the incident and has been published by NOPSEMA to allow industry to benefit from key lessons learned, in particular improving barrier integrity awareness.

 

The report is available for download in three volumes via the Safety resources web page at NOPSEMA.

 

 

The National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) has recently released its latest HSE performance report for Australia’s offshore petroleum industry.

The report contains data of inspections, investigations and information collected from 35 operators and 209 facilities operating in Commonwealth waters (and relevant coastal waters) to December 2011.

Health and safety categories covered in the report include injuries, complaints, investigations and enforcements.

The authoritative report identifies signs of progress in industry safety performance.

For example:

   No fatalities were recorded during the 18-month reporting period from July 2010 to December 2011; and

   The rate of major injuries has been decreasing since 2008.

But the industry cannot afford to be complacent at any stage of offshore petroleum exploration and production.

And the NOPSEMA report goes on to identify that problems with design, SOPs and preventive maintenance are the top three root causes of accidents and dangerous occurrences.

The NOPSEMA report documents 57 incidents which have been investigated during the reporting period to December 2011, including a number of high-potential incidents that could have caused fatalities.

The report also reveals there were three major hydrocarbon gas releases reported in 2011.

For further information about the Offshore Health and Safety Performance Report, contact Alison Carter at NOPSEMA Communications,  ph: +61 (08) 6188 8752, mob: +61 (0)407 076041.

In Australia, the National Offshore Petroleum Safety Authority (NOPSA) recently reported the results of an inspection program it undertook in 2010-11 on the issue of Preventative Maintenance Management (PMM) systems in use on MODUs, FPSOs, production platforms, and unattended wellheads.

According to NOPSA (The Regulator Bulletin, December 2011), the inspections covered onshore interviews with Integrity and Maintenance Engineers and offshore interviews with Maintenance Supervisors.

Although Preventative Maintenance Management systems were found to differ in quality, they were found to be fit for purpose.

There were, however, areas in which PMM systems could be improved, and the following issues are worth considering further:

•   Lack of appropriate auditing and independent verification was the most significant failing identified;

•   Some of the PMM systems inspected had limited supporting documentation available;

•   Variation between the documented PMM and how maintenance is actually conducted;

•   Formal deferrals processes are not always in place and do not always include consideration of the risks of deferral and assess the impacts/consequences of not performing preventative maintenance on safety critical equipment;

•   PMM systems that differentiated between ‘critical’ and ‘non-critical’ temporary repairs with no common understanding on the definition of ‘critical’.

•   A lack of assessment of 3rd party service-providers as part of a contractor prequalification process; and

•   A tendency for the Maintenance Supervisor’s position to become an administrative function; and

•   A lack of supervision by the Maintenance Supervisor of the workforce, technical support and worksites.

Alongside NOPSA, we at the Risk Tool Box  recommend that Operators consider their PMM system in the context of the issues outlined above.

Any organization may experience emergencies in the form of unplanned events.

For that reason, an emergency management system should be in place to ensure that such events are able to be contained and controlled.

The emergency management system should be designed  to safeguard people first and to minimise the damage caused to the environment.

In Australia during 2011-11, the National Offshore Petroleum Safety Authority (NOPSA)  conducted audits of the emergency management systems of 14 separate offshore petroleum facilities.

The inspections found that facility operators had implemented emergency management systems that were generally functional and maintained with personnel who were trained in emergency response.

The audits also revealed, however, a number of findings which can be used to highlight the need to improve emergency response capability in an industry.  These points include:

•  Drills undertaken which do not always cover all emergency controls;

 •  Drills which were overdue;

•  Mustering-points with inadequate location signage;

•  Emergency escape routes which were not clearly marked or had material obstructing the exit path;

•  Documented emergency response performance standards often are not comprehensive in terms of response times and sometimes are not tested during emergency drills; and

•  There were instances of inadequate debriefing following emergency drills.

It is clear from NOPSAs audits that opportunities for improvement exist for many facility operators.  Any facility may also review the list above in terms of their own operations and look for areas of improvements.

Workers employed in the offshore petroleum industry in Australia who may have safety concerns are advised as a first step to raise their issues with their line management.

If the issues are not resolved, it may then be appropriate to raise concerns with the Health and Safety Representative (HSR) or the safety committee for the work place.

If these approaches fail to produce a satisfactory outcome, then the issue can be raised with a NOPSA inspector.

You can contact NOPSA’s incident reporting number (08) 6461 7090 or email NOPSA on: information@nopsa.gov.au.

All voluntary reports made by workers on offshore facilities are treated in confidence and can be made anonymously.

NOPSA will examine the nature of the report and decide on an appropriate course of action.

And don't forget, operators of offshore petroleum facilities are required by law to notify NOPSA as soon as practicable after any accident or dangerous occurrence at or near their facility.

 

 

Please be advised that the National Offshore Petroleum Safety Authority (NOPSA) has now moved to a new office location at:

Alluvion Building

58 Mounts Bay Road

Perth

Western Australia 6000

NOPSA’s new telephone number is (08) 6188 8700.

 

The NOPSA incident notification telephone number will remain the same until further notice – (08) 6461 7090. 

The Australian Senate has passed legislation which establishes a single nation-wide regulator for the offshore energy sector covering exploration and production.  The new regulator will be called the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) and there will also be a new National Offshore Petroleum Titles Administrator brought into being.

NOPSEMA will replace the existing Australian National Offshore Petroleum Safety Authority (NOPSA), which a report into the Montara oil spill on the NW shelf of Western Australia in 2009 partly blamed for the accident. 

The Government aims to have the new NOPSEMA regulator fully operational by January 1 2012, Resources Minister Martin Ferguson said in a statement recently.

The legal definition of the term "Reasonably Practicable" was established in English courts by Lord Justice Asquith in the case brought by Edwards against the National Coal Board in 1949.
 
Lord Justice Asquith said:

"To imply that a computation must be made by the owner, in which the quantum of risk is placed on one scale and the sacrifice involved in the measures necessary for averting the risk (whether in money, time or trouble) is placed in the other; and that if it be shown that there is a gross disproportion between them the risk being insignificant in relation
to the sacrifice the defendants discharge the onus on them.  Moreover, this computation falls to be made by the owner at a point of time anterior to the accident".

This decision of the English courts has since been confirmed by the Australian High Court (in 2001) in the case Slivak v Lurgi (Australia) Pty Ltd.

If Lord Justice Asquith's judgment leaves you none the wiser, in simple terms demonstrating that risk is reduced to a level that is reasonably practicable means that the duty-owner (e.g., an owner or operator) has to show, through reasoned and supported arguments, that there are no other practical measures that could reasonably be taken to reduce risks further.

Hope that's clear enough but if not, feel free to get in touch with your questions.

The National Offshore Petroleum Safety Authority (NOPSA) has identified a marked increase in the number of hydrocarbon releases and spills occurring in Australia in 2010 compared to previous years.

In the period January to July 2010, NOPSA received 22 reports about hydrocarbon releases.

Twenty of these incidents involved gas releases with 16 of these occurring on Floating Production, Storage and Offtake (FPSO)  Tanker ships.

Three of the uncontrolled gas releases involved over 300 kilograms of gas.

According to NOPSA, the most common root-causes of these hydrocarbon releases included:

• A lack of an appropriate level of preventative maintenance;
• A lack of a routine inspection regime;
• Inadequate training and competence amongst operators, supervisors and managers for hazard and risk management;
• Inadequate procedures; and
• Procedures not being following on site.

 

All the usual suspects really.

To read a NOPSA safety alert relating to this issue, simply click here.

Because of the international nature of oil-field work, expatriate workers are at particular risk from deep-vein thrombosis (DVT) due to the travel demands of the job.

Long international flights from homes in the USA, Europe or Australia for oil-patch workers are quite common as they travel to fields across the globe.

In Australia, the National Offshore Petroleum Safety Authority (NOPSA) has noted a growing trend for workers traveling on long-haul flights to Australian oil and gas facilities to be reporting sick with DVT. 

DVT occurs when blood clots in a deep vein within the body - usually in the upper or lower legs.

DVT typically occurs when a person sits for a long time without contracting the muscles in the legs - as is typical on long-haul flights.
 
Blood then moves quite slowly and pools in the veins resulting in clotting and DVT.

It is suspected that the twin threats of keeping legs stationary combined with dehydration whilst flying interrupts the blood flow which causes clots.

The symptoms associated with DVT are not always obvious and a blood clot is not necessarily fatal.

But in some circumstances, however, the clots can become dislodged from the legs and travel to the lungs or brain causing strokes, organ damage, or death.

The good news, however, is that simple control measures are readily-available to most oil-field workers and other international jet-setters.  Here are some ideas for reducing the risk of DVT:

• Periodically stretch out and move your legs and ankles and massage your calves while seated to stimulate blood circulation;
• Don't cross your legs;
• Remain hydrated, drink plenty of water or other non alcoholic fluids during your flight;
• Reduce or eliminate alcohol consumption during flights as it causes dehydration;
• Unless you can lie horizontally (i.e., in business or first-class), minimize the time you spend sleeping as you're less likely to be moving around;
• Wear loose, non restrictive clothing during air travel; and
• If safe to do so, get up and walk around a least once every hour.

 

Finally, upon arrival at your destination, if you feel in any way unwell report immediately to medical practitioner and let them know you've been flying recently.