Preventing major accident events
The Regulator I Issue 3 I October 2021
NOPSEMA expects the day-to-day safety of the workforce to be at the forefront of all operations. A crucial aspect of safe operations is recognising the importance of process safety and its focus on preventing major accident events (MAEs).
The Piper Alpha disaster in the North Sea in 1988 remains the world’s deadliest offshore petroleum MAE, killing 167 workers. It led to a sea change in offshore safety which shaped the industry and regulatory regime in many parts of the world, including Australia.
The probability of a MAE is extremely low, however, history has taught us that when they do happen, the consequences are catastrophic. Given the relative rarity of a MAE, operators may become complacent, and prevention can wane and receive less attention as focus is directed to the management of day-to-day operational issues. More recent MAEs including the Petrobras P36, Mumbai High, Montara, and Macondo disasters demonstrate the importance of operators remaining vigilant and taking all the necessary steps to plan for and prevent a MAE.
NOPSEMA’s role in the prevention of MAEs is frequently highlighted as our regulatory activities (assessment, compliance monitoring, enforcement, promotion and advice) continue to identify situations where inadequate or failed barriers and systems are likely to lead to a MAE.
A basic tenet of the objective-based regulatory regime administered by NOPSEMA is the premise that the ongoing management of safety is the responsibility of the operator. This allocation of responsibility recognises that the operator should have the knowledge, decision-making authority, on the ground control and resources to ensure the risks they create are appropriately managed. What this means practically is that the operator must continually identify and assess all MAE risks and implement control measures to continually reduce those risks to as low as reasonably practicable (ALARP). This must be demonstrated to NOPSEMA in a safety case.
A safety case should have a coherent, integrated overall structure containing a facility description, a formal safety assessment and a description of the safety management system. There should be a logical flow to the process to create strong links between the causes and consequences of MAEs, their associated risks, the selection of strategies and measures to control the risks, and the performance required from specific measures to maintain risk levels to ALARP. It does this by applying control barriers. All barriers associated with preventing or mitigating a MAE are identified as safety critical elements, and as such must be continually maintained and tested against pre-defined performance standards to ensure they remain fit-for-purpose.
NOPSEMA recognises that assessment and compliance monitoring, which focus on individual facilities and activities, can be limited in preventing a potential MAE. That is why NOPSEMA employs experienced personnel to identify trends and establish valuable insights. This work has resulted in NOPSEMA establishing four strategic compliance focus areas, of which the prevention of MAEs is one. Improvement programs under this focus area currently targets human factors, maintenance management, and safety management systems.
A safety management system that prevents MAEs requires a robust and well managed process safety management framework based on industry good practice and subject to continuous improvement. As an example, the Energy Institute has developed a process safety management framework, in collaboration with industry, setting out twenty elements of process safety to reduce MAE risks. The framework isn’t intended to replace existing safety management systems, rather provide a benchmark for good practice.
Good practice in the prevention of MAEs is driven by a high standard of leadership that is committed to promoting a positive safety culture that informs and involves the whole workforce in the identification, assessment, and management of MAE risk. In this issue of The Regulator, NOPSEMA has looked in greater detail at the process safety elements of leadership, workforce involvement and management of change. In future issues, NOPSEMA will seek to highlight more good practice process safety elements in the prevention of MAEs.