Effective testing of oil spill response arrangements

Article published in the Regulator | Issue 1: 2019

A major oil spill arising from a petroleum activity in Australian Commonwealth waters will never be acceptable, but in the rare event of a spill occurring, consequences can be reduced through a wellplanned and coordinated response. Practising and regularly testing individual response arrangements is fundamental to ensuring effective oil spill response capability, and helps to identify areas for improvement.
The Environment Regulations specify the requirements of testing response arrangements, including the frequency of testing, but it remains up to the titleholder to design a testing program that will meet its needs. Testing response arrangements can take place in a number of ways, however oil spill exercises are the most common form of testing utilised in the oil and gas industry. Oil spill exercises can range from short desktop drills involving a few key incident responders, to large-scale exercises running over several days across multiple locations and may include field-deployment of response equipment. Since 2015, NOPSEMA has conducted 24 environment inspections across 13 titleholders, which included examining oil pollution emergency plan (OPEP) testing arrangements. Some 40 recommendations have been made in relation to testing of response arrangements and can be classified into five main categories as shown below.

Recommendation categories No. of recommendations %
1. Schedule or frequency of tests 11 27.5
2. Scope of testing - testing external spill response service providers 9 22.5
3. Scope of testing appropriate to response arrangements 8 20.0
4. Mechanisms to address actions and recommendations from exercises 7 17.5
5. Exercise evaluation and reporting 5 12.5
Total  40 100

NOPSEMA’s inspections found that in many cases, oil spill exercise programs conducted were not consistent with training commitments made in a titleholders environment plan or did not meet regulatory requirements. For example, titleholders were found to have not tested their response arrangements frequently enough. NOPSEMA also identified a number of exercise scopes had limitations, for example, failing to include testing of critical spill response arrangements provided by external service providers. In addition to this, the focus of some exercises were too narrow and were not appropriate to the range of response arrangements identified for the activity. Limitations in systems to record recommendations or actions from oil spill exercises, as well as a failure to track them were also identified. In other cases, the evaluation or reporting on the exercises was ineffective. Together, these can restrict lessons learnt and opportunities for future improvement. 

Oil spill exercises often have a dual purpose to test response arrangements and train spill responders. In these circumstances, the exercise design should clearly identify what parts of the OPEP are being tested, define clear objectives and set appropriate performance indicators that differentiate between testing and training components. It is also important to recognise that the planning, scheduling, design and evaluation stages of an oil spill exercise are just as important as the execution of the exercise. There are a number of government and industry resources available for titleholders on emergency response exercises, including the Australian Disaster Resilience Handbook 3: Managing Exercises and IPIECA & OGP’s 2014 Oil spill exercises - Good practice guidelines for the development of an effective exercise programme.v