Deferred maintenance – a major industry challenge?

The Regulator I Issue 3 I October 2021

Timely and appropriate maintenance, particularly for safety-critical equipment, is a key safety control measure in the prevention of harm and the protection of the environment. NOPSEMA recognises that, at times, to balance unexpected and competing operational priorities operators need to defer certain maintenance activities.

These deferrals may be acceptable when done for a short period of time, where engineering or procedural processes are not feasible, and risks continue to be reduced to a level that is as low as reasonably practicable (ALARP). Deferrals are not acceptable when plant and equipment is left to deteriorate to a point where it becomes a risk to the safety of the workforce, hazardous to the environment, or it can no longer be safely removed.

Timely and appropriate maintenance is of particular importance given more than half of all offshore production facilities in Australian waters are more than 20 years old, and some exceed 50 years.

In early 2020, industry sought to proactively respond to the COVID-19 pandemic while managing the effects of sustained low oil prices. At the time, NOPSEMA raised concerns about the number of maintenance activities being deferred and the impact that would have on the level of risk.

NOPSEMA also began monitoring the application of maintenance management by operators more closely to ensure planned maintenance was carried out within an acceptable timeframe. This monitoring confirmed that the deferral of maintenance is a key compliance issue.

Where deferring maintenance is necessary, operators should have an effective strategy in place to track all the deferred maintenance activities and report each activity against its key performance indicator. Operators should assess the risk of each deferral and prioritise the highest risk for maintenance. Where maintenance cannot be completed against set key performance indicators, operators should implement mitigating actions, such as reducing other activities, to ensure the facility remains safe and without risk to the health and safety of the workforce.

NOPSEMA is currently assessing the results of an industry-wide survey on deferred maintenance. The survey findings will be shared with industry for discussion and the promotion of best practice. In the interim, operators are reminded of their duty to take all reasonably practicable steps to ensure the facility is safe and without risk to the health of any person at or near it.

NOPSEMA expects that operators will review all their deferred maintenance activities to ensure risks, particularly MAE risks, continue to be reduced to ALARP.  

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