Working With your Offshore Teams
Article published in The Regulator | Issue 1: 2020
A well activity being undertaken at an offshore drilling facility is a complex and hazardous undertaking providing a direct pathway into an oil and gas reservoir which can introduce the risk of a potential loss of containment of hydrocarbons and the associated risk of a fire and/or explosion at the facility.
While it is the titleholder’s responsibility to ensure a well activity is conducted safely and without risk, it is the drilling facility operator’s responsibility to ensure all aspects of safety onboard their facility, including well control. Third party contractors involved in a well activity are responsible for the integrity of the plant and equipment they supply and the safety of their employees undertaking a well activity.
All parties have individual responsibilities under the legislation and collectively, they share the responsibility for OHS during well activities.
NOPSEMA has identified examples where operators of drilling facilities and third party well intervention contractors have undertaken well activities unaware of the risks identified in the titleholder’s well operations management plan (WOMP); the permissioning document for the well activity.
In one instance, the operator of a drill rig and third party contractor were undertaking an activity to plug and abandon a well when they unexpectedly encountered hydrocarbons. The risk of hydrocarbons being present in the well was identified in the titleholder’s WOMP, however, neither the drill rig operator or third party contractor were aware of that risk.
To manage the risk, the third party contractor supplied pressure-containing equipment not recognising that it was neither maintained nor certified. Before the equipment was deployed offshore, the titleholder completed a quality assurance check of the equipment and identified that it was neither maintained nor appropriately certified and yet, knowing this, approved the equipment’s use. When the equipment arrived at the drill rig, the operator did not verify its certification or maintenance.
In using equipment that was not certified as having been appropriately inspected, tested and maintained, all responsible parties risked a potential loss of containment of the hydrocarbons which could have sparked an associated fire and/or explosion and injured or even killed the personnel on-board.
NOPSEMA issued a general direction to the titleholder and improvement notices to the drill rig operator and third-party contractor to ensure they review their processes and procedures relating to the inspection, maintenance and certification of third-party equipment.
The titleholder also reviewed their critical interface management arrangements and committed to improving their performance. NOPSEMA strongly encourages all titleholders to do the same, and in particular, ensure management of change (MOC) processes for the interface between themselves and their offshore teams (including appropriate escalation) are described in the WOMP.
Although this incident pertains to a well activity, the lessons learned can, and should, be applied to the industry more broadly where interfaces exist between different teams