APPEA HSR Forum Industry Health and Safety Performance and decision - PowerPoint PPT Presentation

APPEA HSR Forum Industry Health and Safety Performance and decision ‐ making Simon Schubach Regulatory General Manager August 2010

NOPSA’s functions Investigate Promote Co-operate Report Monitor & Enforce Advise A130621 2

Australian offshore OHS laws: • Schedule 3 to the Offshore Offshore Petroleum Petroleum and Greenhouse Gas and Greenhouse Gas Storage Act 2006 Storage Act (OPGGSA) • Offshore Petroleum (Safety) Regulations 2009 Schedule 3 Available at www.comlaw.gov.au Offshore Petroleum and Greenhouse Gas Storage (Safety) Regulations 2009 A130621 3

What does the regulator do? Challenge the operator • Safety Case Assessments ‐ targeted • Facility Inspections ‐ sampled • Incident Investigation ‐ depending on severity • Enforcement ‐ verbal / written and prosecutions Independent oversight • Facility health and safety risks are properly controlled by operators of facilities through securing compliance with OHS law A130621 4

Facilities Facility Group Jan ‐ June 2010 Platforms 56 Normally attended 28 Not normally attended 28 FPSOs 14 MODUs 13 Vessels 11 Pipelines 70 TOTAL: 164 A130621 5

INDUSTRY NOPSA 2009 ‐ 10 33 Operators 33 OHS Inspectors activities 164 Facilities 20 Support staff 180 Assessments 180 Assessments 366 Incidents 94 Inspections 38 Accidents 328 Dangerous Occurrences 6 Major Investigations 93 Minor Investigations 267 Incident reviews 28 Enforcement actions A130621 6

Montara A130621 7

Montara Incident ‐ Uncontrolled hydrocarbon release ‐ 21 August 2009 • Failure of well integrity: � Inadequate barriers � Primary cementing � Management System issues: Risk Assessment, Communications, Records Management, management oversight � Titleholder ‐ Drilling Contractor Interface • NOPSA has investigated for a potential contravention of OHS laws by the operators • NOPSA has referred a brief of evidence to the CDPP A130621 8

Australian Offshore Injury Rate TRC Rate per million hours 16 12 Rate 8 4 TRC = LTI + ADI + MTI 0 2005 2006 2007 2008 2009 1/1/10 to 30/6/10 A130621 9

Hydrocarbon Releases Uncontrolled PL release >12 500L Number of Hydrocarbon Releases Uncontrolled PL release >80 ‐ 12 500L Uncontrolled HC gas release >300 kg 35 Uncontrolled HC gas release >1 ‐ 300 kg 30 9 25 6 1 1 3 Number 2 20 3 1 3 5 3 15 1 21 10 18 17 15 15 11 5 0 2005 2006 2007 2008 2009 1/1/10 to 30/6/10 A130621 10

International Comparison 12 Gas Release Rates (per million BOE) 8 Australia Rate 4 IRF Countries 0 2005 2006 2007 2008 Injury Rates 8 (per million hours ) 4 Rate 0 2005 2006 2007 2008 2009 1/1/10 to 31/5/10 A130621 11

Incident Root Causes 1/1/10 to 2005 2006 2007 2008 2009 30/6/10 Procedures - Preventive Preventive Preventive Procedures - Procedures - Not Followed Maintenance Maintenance Maintenance Not Followed Not Followed Preventive Mgmt System - Procedures - Design Specs Design Specs Design Specs Maintenance SPAC Not Followed Procedures - Procedures - Preventive Preventive Design Specs Design Specs Not Followed Not Followed Maintenance Maintenance A130621 12

MAE Prevention “it is essential to create a corporate atmosphere or culture, in which safety is understood to be and is accepted as, the number one priority” Lord Cullen – Piper Alpha Inquiry 1990 A130621 13

BP Texas City Refinery 2005 • People can forget to be afraid • Maintain vigilance and operating discipline A130621 14 Baker Panel Report: BP Refineries Independent Safety Review Panel, 2007

NOPSA Promotion Process Safety Culture 1. Survey of senior management - Onshore Process Safety Leadership Principles 2. Survey of workforce - Offshore Process Safety Culture A130621 15

Workforce Survey Context • Process safety awareness • Shared at 2009 HSR Forum • Safety culture perceptions • Industry benchmarks used • Responses confidential • Small number of responses • 9 surveys A130621 16

Benchmarking No. Facilities TOPIC AREA BELOW benchmark Supervisory Involvement 3 Worker Professionalism/Empowerment 3 Reporting 4 Safety Values/Commitment 3 Procedures and Equipment 2 Training 5 n = 8 A130621 17

Opportunities for Improvement Most common issues scoring in the bottom ten TOPIC AREA survey question responses Safety Values / Pressure to work overtime - loyalty to work unit Commitment Hazard identification, control and reporting Reporting training not adequate Safety Values / Process safety programmes don't have Commitment adequate funding Contractors don't receive adequate training to Training do their job safely Professionalism / Workers don't actively participate in incident Empowerment investigations A130621 18

Safety Promotion and Advice by NOPSA Safety Case Guidance Notes A130621 19

Learning from history “The past seldom obliges by revealing to us when wildness will break out in the future.” A130621 20 Against the Gods, the Remarkable Story of Risk, P Bernstein 1996

Learning from history War, depressions, stock ‐ market booms and crashes, and ethnic massacres come and go……. But they always seem to arrive as surprises. A130621 21 Against the Gods, the Remarkable Story of Risk, P Bernstein 1996

Learning from history After the fact, when we study what happened….. • the source of the wildness appears to be so obvious • it’s hard to understand how people on the scene were oblivious to what lay in wait for them. A130621 22

Consider this scenario… • The quality of a cement job is uncertain and you are faced with either: a) a loss of 4 days rig time b) a small chance of a loss of well integrity sometime in the future. Pause for thought ! What would you do? A130621 23

Making decisions, taking risks … • Decisions involving losses – we are risk ‐ takers • Experiment – you have a choice between: 1. 100% chance of losing $3000 2. 80% chance of losing $4000 and 20% chance of breaking even expectation of loss = $3200 92% of subjects chose the second option with • the greater expectation of loss! The risky choice ! A130621 24 Kahneman & Tversky, 1979

Think again Going back to the cement job • If the quality of the cement job is uncertain and you are faced with a loss of 4 days rig time, compared with a small chance of a loss of well integrity sometime in the future… What would you do? A130621 25

Lets try again Job: change filter elements in filter vessel with leaking isolation valve. How many times do you think you can get away with this? Option 1: 99% of the time? Simply change out the filter elements. With an experienced crew you can do this quickly and they just need to ensure no sources of ignition are present. Time to change ‐ out: 30 minutes. Option 2: Fix the core problem of the leaking valves. Time to repair: Several days. What would you do? A130621 26

Lets try another question? Job: If you are asked to perform a quick man ‐ riding job in the derrick that will take <2 minutes, and nobody was watching, would you: Option 1: Just jump in the man ‐ riding harness and go? Option 2: Carry out a JSA, spend 15 minutes setting up an inertia reel secondary fall protection device. Carry out all the pre ‐ job safety checks then perform the job following the approved man ‐ riding procedures?

Individual decisions – safety culture at every level "It is easy to point the finger at the management and assume that a culture of cutting corners started at the top, and was motivated by money. It's worth remembering that the same culture can also originate at the bottom, driven by a desire to get things done. The task of management is to know this and insist it is done properly". Trevor Kletz, The Chemical Engineer, August 2010 A130621 28

Black Swan event 1. Outlier – doesn’t happen very often 2. Extreme impact 3. After the event, it is explicable and predictable A130621 29 The Black Swan: The Impact of the Highly Improbable, Nassim N Taleb 2007

Vulnerability + decision risk = black swan If you reach a step that doesn’t meet the required conditions, or where circumstances have changed…… Pause and Reflect A130621 30

So, what can you do? Understand Specific hazards of materials ‐ ‐ Safe ‐ handling responsibilities ‐ Specific hazards of operations Understand your role in process safety activities ‐ Hazards analysis ‐ Management of change ‐ Incident reporting and investigation ‐ Maintenance & testing ‐ Following safe work practices Maintain operating discipline and vigilance A130621 31

don’t forget your HSR A130621 32 handbook! Thank you And …