Environment culture - planning to respond
Article published in the Regulator | Issue 4: 2013
The challenge is set for offshore petroleum operators to mirror the leadership demonstrated in the development of an offshore safety culture, in the creation of an environment culture that properly recognises the importance of both preventing and preparing to respond to very low likelihood but credible, high consequence events.
In 1988, the Piper Alpha disaster in the North Sea claimed 167 lives and marked a step change towards the establishment of an offshore petroleum health and safety culture. It took an unacceptable loss of life before safety came under the spotlight in the offshore petroleum industry, through the development of the safety case approach.
Major loss of hydrocarbon containment events such as the PTTEP AA Montara blowout in 2009 and BP Macondo in 2010, have brought environmental management into focus. Recommendations arising from the Montara Commission of Inquiry led to the formation of NOPSEMA in January 2012 as the single national regulator of safety, well integrity and environmental management by the Australian offshore petroleum industry. The changes reflect the view held by both government and the community that severe environmental impacts resulting from offshore petroleum activities are unacceptable and that failure to prepare to respond adequately, even for very low likelihood events, will not be tolerated.
A focus on prevention of oil spills is clearly in everyone’s interests for protection of both people and the environment. It is essential, however, that companies also develop a culture that properly recognises and understands the environmental consequences that may arise if our best efforts to prevent unlikely events are unsuccessful, by placing equal focus on preparedness to respond. Such a culture is needed to ensure that adequate attention is subsequently directed to planning and preparing to respond to these events in order to do as much as possible to avoid and minimise consequences that would otherwise result in widespread environmental damage.
The Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009 outline the legal responsibilities for environmental management by the offshore petroleum industry. Industry will more efficiently and effectively meet these obligations and demonstrate their operations can be carried out in a responsible manner if a culture within industry continues to mature so that employees properly reconcile requirements for environmental planning, monitoring and reporting, particularly in relation to oil spill response.
Under the OPGGS Act, petroleum activities can commence only where there are accepted oil spill response plans that are tailored to a specific activity, designed to avoid or reduce the impacts of spilt oil and ready to be implemented. You may be aware of recent debate around the use of oil dispersants in marine and offshore incidents in Australian waters, following reports about the potential effects of particular dispersants in the response to the BP Macondo blowout in the Gulf of Mexico in 2010.
In 2013-14, oil spill contingency planning will be a focus for NOPSEMA through additional assessment, inspection and regulatory advice to ensure that industry is aware of the need for each petroleum activity to have spill response arrangements in place that are ready to go and are commensurate with the potential consequences of a ‘worst case’ credible spill scenario. This includes the need for activity operators to demonstrate, in the environment plan, that the implementation of any response plan would reduce impacts of spilt oil and would not have unacceptable impacts on the environment.
For more information see Oil pollution risk management guidance note (PDF 371KB).