Inspecting oil spill response service providers and equipment stockpiles
Article published in the Regulator | Issue 1: 2017
Significant offshore oil spills are very rare events that can require rapid deployment of large amounts of specialist response equipment to mitigate oil spill impacts. It is impractical for each company to separately hold all this equipment and considerable benefits exist in sharing these resources.
To this end, NOPSEMA recognises and supports the offshore petroleum industry adoption of cooperative arrangements with external oil spill response organisations (OSROs) to hold and maintain this equipment in a constant state of readiness on its behalf. Australia has a long-standing system for sharing oil spill resources with access to OSRO equipment stockpiles typically based on a scaled membership system offering different levels of response services.
Given the cooperative nature of oil spill response arrangements and the dependency of titleholders on OSROs to supply critical response equipment specific to their particular needs, NOPSEMA recently undertook an inspection program across a cross-section of titleholders focusing on their arrangements and assurance processes with two of the largest OSROs; the Australian Marine Oil Spill Centre (AMOSC) and Oil Spill Response Limited (OSRL). The inspection program also looked at the status of response equipment and management systems at AMOSC which is the principal non-government OSRO based in Australia.
Over the course of several weeks, NOPSEMA inspected the premises of seven titleholders as well as AMOSC premises in Victoria and Western Australia. The inspectors examined the assurance processes put in place by titleholders to verify OSRO capability in addition to the availability and maintenance process of AMOSC held response equipment. Taking this approach allowed NOPSEMA inspectors to holistically examine industry practice and broadly identify where cooperative approaches to develop joint solutions may require improved oversight by titleholders in line with their environment plan commitments.
NOPSEMA inspectors issued several common recommendations to titleholders aimed at enhancing oil spill preparedness and response. Recommendations focused on strengthening assurance processes between titleholders and their OSROs, for instance:
• clarifying service delivery requirements
• improving systems for testing and exercising OSRO arrangements and capability
• enhancing systems used to track the availability and maintenance of OSRO response equipment
NOPSEMA will monitor how titleholders respond to the authority’s recommendations and will look to implement similar approaches to inspections in the future as a more efficient means to identify and seek resolution of compliance issues.