FPSO Safety Case

Cost Effective Outcomes from FPSO Safety Case By: Brendan Fitzgerald, Managing Director, Vanguard Solutions Joe Patrick, Managing Director, Hunter Oil Paul Breen, Technical Director, Vanguard Solutions FPSO Congress September 2010

Cost Effective Outcomes from FPSO Safety Case • • • • • • • •

Brief History What is a Safety Case? The Management of Safety Why do we need a Safety Case? Benefits of doing a Safety Case Safety Cases – Lessons Learned? A suggested Blue Print for success Conclusions

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A Brief History Safety Cases are required in various industries in Europe and Australasia. • European Union Major Hazard Facilities – Seveso 1 (1982) & Seveso 2 (1996) • UK Railways 2000 & amended 2003 • European Union Railway Safety Directive (2004/49/EC) • Australia Major Hazard Facilities National Standard 1996 & Updated 2002 Cost Effective Outcomes from FPSO Safety Case

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A Brief History OFFSHORE SAFETY CASE REQUIREMENTS • UK Offshore Installations (Safety Case) Regulations 1992 & Updated 2005 • Australia Offshore Facilities 1992, 1996, 2005 & 2009 • New Zealand Offshore Facilities 1993 & 1999 • Timor Leste Offshore Facilities - 2003 Cost Effective Outcomes from FPSO Safety Case

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A Brief History OTHER AREAS OF SAFETY CASE USE • UK Defence Forces • Australian Defence Forces • Some oil companies apply Safety Case worldwide, e.g. BHP, Shell and Woodside.

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A Brief History “Safety Case still represents best means of managing major hazards offshore” • International Review panel – 2008 • Bills & Agostini – 2009

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What is a Safety Case?

“A consistent and coherent set of arguments used to justify the safety of a system at all stages in its lifecycle” • H. Conlin et al, Trans IChemE, Part B, July 2004

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What is a Safety Case? A safety case is a document produced by the operator of a facility which: •

Identifies the hazards and risks;

•

Describes how the risks are controlled; and

•

Describes the safety management system in place to ensure the controls are effectively and consistently applied.

http://www.nopsa.gov.au/safety.asp under the heading "Safety Case Approach" Cost Effective Outcomes from FPSO Safety Case

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What is a Safety Case? Safety case is a process, not just a document • It introduces a need for an audit trail with documented decisions • Brings a greater awareness of hazards and their management • It always involves a culture change

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The Management of Safety

H.W. Heinrich Industrial Accident Prevention: A Scientific Approach, 1931 Cost Effective Outcomes from FPSO Safety Case

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The Management of Safety

Commonly used modification from Heinrich Cost Effective Outcomes from FPSO Safety Case

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The Management of Safety Fatal Fall

Rig Explodes

Fall from Stairs

Serious Leak

We We need need another another model! model! Not holding the handrail Jop Groeneweg, Leiden University, 2010 APPEA Safety Conference Cost Effective Outcomes from FPSO Safety Case

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The Management of Safety Rig Explodes

Fatal Fall

Serious Leak

Fall from Stairs No Handrail

Minor Leak Personal Safety

Process Safety

Jop Groeneweg, Leiden University, 2010 APPEA Safety Conference Cost Effective Outcomes from FPSO Safety Case

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The Management of Safety These are two different processes. So management systems must recognise they are two different processes ... with different drivers. Process Safety

Personal Safety Cost Effective Outcomes from FPSO Safety Case

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The Management of Safety Different elements of safety management systems address personal safety from those that address process safety

So it is not enough to say that SMS addresses safety. Cost Effective Outcomes from FPSO Safety Case

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The Management of Safety Recent observations suggest that industry focus is on slips, trips and falls … Fatal Fall

Fall from Stairs

… with reducing attention paid to maintenance of technical integrity and major hazard controls. Rig Explodes

No Handrail

Serious Leak Minor Leak

Personal Safety Cost Effective Outcomes from FPSO Safety Case

Process Safety 16

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The Management of Safety “But the more profound problem is a failure to put risks in perspective. BP and other companies tend to measure safety and environmental compliance on a day-to-day, checklist basis, to the point of basing executive bonuses on those metrics. But even if worker accident rates fall to zero, that may reveal nothing about the risk of a major disaster.” Andrew Hopkins, Energy Bulletin, 10 May 2010 Cost Effective Outcomes from FPSO Safety Case

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The Management of Safety Traditional means of the management of safety has been prescriptive in nature. Widely accepted failings of prescription include: • Quickly out of date as industry changes • Industry only performs to minimum – no incentive to exceed

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The Management of Safety Widely accepted failings of prescription include: • Industry lets regulator work out what is needed and comply verbatim – so operator fails to identify or understand the hazards and risks they are supposed to manage – controls may be inadequate or inappropriate • Prescriptive regulations become a hurdle to be cleared, with the focus on the hurdle, not on managing the hazard

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The Management of Safety Piper Alpha Inquiry report, Lord Cullen criticised attitude to management of risk from a high pressure gas fire:

The witnesses’ reliance on merely a qualitative opinion showed, in my view, a dangerously superficial approach to a major hazard. … … I consider that management were remiss in not enquiring further into the risks of a rupture of one of the gas risers and in such an event the risk of structural damage and injury to personnel.

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Why do we need a Safety Case?

Do we really understand our facilities?

Here are some you may recognise!

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Why do we need a Safety Case?

27 July 2005, Mumbai High North – 22 fatalities Cost Effective Outcomes from FPSO Safety Case

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Why do we need a Safety Case?

August to November 2009, Montara – total loss of WHP and rig - unknown environmental impact Cost Effective Outcomes from FPSO Safety Case

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Why do we need a Safety Case?

20 April 2010 – Deepwater Horizon Macondo Blowout – 11 fatalities, massive & unknown environmental impact Cost Effective Outcomes from FPSO Safety Case

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Why do we need a Safety Case?

That’s all well and good – but what has that got to do with FPSOs?

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Why do we need a Safety Case?

8 August 2010, MT Gagasan Merak FSO – Cargo tank explosion – 4 injured Cost Effective Outcomes from FPSO Safety Case

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Why do we need a Safety Case?

2009, Formosaproduct Brick Product Tanker – Ship Collision Cost Effective Outcomes from FPSO Safety Case

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Why do we need a Safety Case?

28 August 2009, Tanker Elli breaks back in ballasting error for tank entry Cost Effective Outcomes from FPSO Safety Case

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Why do we need a Safety Case?

Ship collisions don’t happen with offshore facilities, do they?

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Why do we need a Safety Case?

11 August 2010 – Kodeco Platform – unknown vessel collision Cost Effective Outcomes from FPSO Safety Case

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Why do we need a Safety Case?

8 June 2009 – Big Orange XVIII collision with Ekofisk Complex Cost Effective Outcomes from FPSO Safety Case

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Why do we need a Safety Case? – You’ve carefully thought out all the angles – You’ve done it a thousand times – It comes naturally to you – You know what you’re doing, it’s what you’ve been trained to do your whole life. – Nothing could possibly go wrong, right? Cost Effective Outcomes from FPSO Safety Case

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Think Again

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Why do we need a Safety Case? • How do you demonstrate adequacy of safety management to Company Board otherwise? • Demands of duty of care – how do you demonstrate adequacy without a Safety Case? • ISO 9000 process & ISO 31000 elements link directly to the Safety Case process • So good quality management requires a Safety Case!!

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Why do we need a Safety Case? • International companies – consistency of application across assets ( e.g. Shell, BP, Union Carbide) • How do you demonstrate safety in design without Safety Case? – Are standards / Class enough? • So if just apply codes and standards, what other hazards/ risk mitigation measures would be missed? • How else could hazards and the SMS be linked? • HAZOP is an integrity assurance process – not hazard identification!! Cost Effective Outcomes from FPSO Safety Case

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Safety Cases – lessons learned? The Enemies of Safety are : Complacency Arrogance Ignorance

Professor Nancy Leveson, MIT, “Future Trends in Process Safety”, Honeywell User Group Summit, June 2007

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Safety Cases – lessons learned? Factors in Complacency • Discounting risk • Over-relying on redundancy • Unrealistic risk assessment • Ignoring low-probability, high-consequence events • Assuming risk decreases over time • Ignoring warning signs Professor Nancy Leveson, MIT, “Future Trends in Process Safety”, Honeywell User Group Summit, June 2007

Reflecting on recent major accident events does any of the above sound familiar ? Cost Effective Outcomes from FPSO Safety Case

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Safety Cases – lessons learned? Managing Tradeoffs Good risk management requires understanding the outcomes, implications, impact and tradeoffs between: • • • •

Schedule Cost Performance Safety

Do we effectively put this into practice ? Professor Nancy Leveson, MIT, “Future Trends in Process Safety”, Honeywell User Group Summit, June 2007 Cost Effective Outcomes from FPSO Safety Case

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Example: Schedule Pressure and Safety Priority 1.4

Overly aggressive schedule enforcement has little effect on completion time (