In reply to Topic 4: Piper Alpha disaster
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Provision
and Use of Work Equipment Regulations (PUWER): this place duties on employers to
provide employees use with adequate work equipment.
Dangerous
Substances and Explosive Atmospheres Regulation: this requires employers to find
out, control the risks and reduce the effects of any incidents from dangerous
substances in their workplace.
Others are the Management of Health
and Safety at Work Regulations and Prevention of Fire and Explosion, and
Emergency Response Regulations
Unfortunately
all this legislations were coined after and as a result of piper alpha and one cannot
say of their possible existence without piper alpha.
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This is a continuation of my
earlier submission on this subject. The Offshore Safety Case Regulation 2005
requires Operators to be proactive in safety and risk management. A good safety
and risk management system will have a good risk assessment that, for example
in the case of Piper Alpha, points out among other things;
1. An
effective work permit (WP) system is in place and managed properly to ensure
that the most current WP is accessible.
2. Effective
emergency response system is in place and all crew are adequately trained.
3. Change
management is properly done when the rig is converted from oil to gas. With
this change, the firewall will be replaced with a blast wall.
4. The
pump switch that leads to the faulty valve will be locked and tagged so that
its status will be known. Etc.
The aftermath of Piper Alpha has seen a series of regulation
implemented for offshore safety. The current regulation followed is Offshore
Installation (Safety Case) Regulations 2005, which take account of experience
gained with the original set. That is this current regulation ensure the Safety
Case should be a living document & the pervious prescriptive regulations
have been replace by goal setting ones. But recent indications have shown that
it is not without its problems and has affected engineer and professionals
working in the offshore oil and gas industry. This had to a series of conflict
between the HSE and the industry leading to two most recent developments in the
field of health and safety law: The Corporate Manslaughter and Corporate
Homicide Act 2007 and the Health and Safety (Offences) Act 2008.
Ref:
Environmental and Energy Law by Karen E Makuch Chapter 10 Page 231 to 234.
The fall out form the piper alpha disaster saw a total review and update of the safety regime in the offshore industry and a move away form the prescriptive minerals working act of 1971 to a goal setting legislative environment. The regulation was also moved form the department of energy to the health and safety executive.
The introduction of the Safety case regulation meant that all operators had to produce a report that described the installations process, hazards, evaluated risk and identified what measures were taken to control or reduce those risks.
The main Legislations that now cover the offshore industry that didn’t prior to the piper alpha disaster are
The Offshore Installation (Safety Case) Regulations 2005
The Offshore Installation (Prevention of Fire and Explosion, and Emergency Response) Regulation 1995
The Offshore Installation (Design and Construction) Regulations 1996
The Offshore Installation (Management and Admin) Regulations 1995
Under the Health and Safety at work act etc 1974 there are other legislative documents such as the pipelines safety regs that are applicable to the offshore environment.
I like what Joan.C.Isichei has done with chronologically listing pre and post Piper Alpha safety legislations. I hadn’t thought to do this and was just searching specific legislation which would apply to Piper alpha. One I was specifically reading was the (PFEER) SI 1995/743.
I would, however, say that SCR SI 2005/3117 wasn’t the most important but the Prevention of fire, explosion and emergency response regulations PFEER SI 1995/743 is legislative regime that would apply if Piper Alpha disaster occurred today. This is because the emergency response plan (section 8) details the responsibility of the organisation to follow emergency response plans for different circumstances. A large organisational PFEER would have applied to the Tartan and Claymore platforms too and if the Piper Alpha disaster occurred to day I’m sure this piece of legislation would have ensured that the managers of the Tartan and Claymore had the authority to close the gas pipes preventing the second explosion.
William Wilson
MSc Subsea Engineering
In reply to Topic 4: Piper Alpha disaster
If Piper Alpha disaster occurs today most of the UK offshore legislation regime will apply. I say this because almost all the current offshore regulatory regime is direct bequest of the Piper Alpha incident – all the 106 recommendations of Lord Cullen is being implemented by offshore industry. He developed a novel and improved safety regime that focuses on goal setting approach. The Offshore Safety Case Regulation 2005 employs this legislative model. This legislation requires offshore installation operators to demonstrate management leadership and commitment to safety by producing a safety case that outlines the safety and risk management systems put in place, without infringing on other relevant regulations. With this regulation, any modification or facility upgrading will require risk assessment to be carried out
Prior to the Piper Alpha disaster, UK offshore Safety legislations in place included the following[1];
• Minerals workings act (MWA) 1971.
• Health and safety at work act (HSW) 1974.
• Offshore installations (construction and survey regulations) 1974.
• Petroleum and submarine pipelines act (PSP) 1975.
• The offshore installations (fire-fighting equipment regulations) 1977.
• The offshore installations (life saving appliances regulations) 1977.
• Gas enterprises act 1982.
Current Legislations that came into existence post-Piper Alpha include;
• Provision and Use of Work Equipment Regulations (PUWER) Statutory Instrument (SI) 1992/2932
• Prevention of Fire and Explosion, and Emergency Response Regulations (PFEER) Statutory Instrument (SI) 1995/743
• Management and Administration Regulations (MAR) Statutory Instrument (SI) 1995/738
• Design and Construction Regulations (DCR) Statutory Instrument (SI) 1996/913
• Safety Case Regulations (SCR) Statutory Instrument (SI) 2005/3117
Had the piper alpha disaster occurred today, I believe that the most important current safety Legislation that would apply is the;
• Safety Case Regulations (SCR) Statutory Instrument (SI) 2005/3117; it mandates that Safety Cases which establish that management systems are capable of assuring accordance with cognate health and safety provisions, be prepared by every operator of an offshore Installation and submitted to HSE. Also, it mandates that Hazards which pose serious accidents to personnel be identified and that Risks have been evaluated and deemed ALARP[2].
REFERENCES
1. Offshore Occupational Safety and Health, Gap Analysis between UK and Egyptian Legislations. Onsi, Ahmed (Cptn)
2. HAZARDOUS INSTALLATIONS DIRECTORATE OFFSHORE DIVISION. McLaren, Tom.
The Piper
Alpha introduced new laws/regulations and changes to existing laws/regulations
which govern Health and safety in the oil and gas industry. If Piper Alpha were to happen today, here are
lists of the laws which would govern it:
1.
The Health and Safety at work etc. Act 1974, UK
2.
The Management of Health and Safety at Work
Regulations 1999 (MHSWR)
3.
Emergency planning, Control of Industrial Major Accident
Hazards Regulations 1999 (CIMAH).
4.
The provision and Use of Work Equipment
Regulations 1998 (PUWER).
5.
The Reporting of Injuries, Diseases and
Dangerous Occurrences Regulations 1995 (RIDDOR)
6.
The Control of Substances Hazardous to Health Regulations
1994 (COSHH)
7.
Supply of Machinery Safety Regulations 1992 (EEC
Machinery Directive 89/392/EEC).
8.
Electromagnetic Compatibility (amendment)
Regulations 1994
9.
The Equipment and Protective systems Intended
for Use in Potentially Explosive Atmospheres Regulations 1996 (S.I 1996/192),
(ATEX Directive 94/9/EC).
10.
Provision to ensure safety in the work place where
potentially explosive atmospheres could be present (ATEX Directive 99/92).
11.
Construction (Design and Management) (CDM)
Regulations 1994.
12.
Occupational Safety and Health Act (OSHA) 1970.
13.
Noise at work Regulation 1989.
14.
Workplace (Health, Safety and Welfare)
Regulations 192,
15.
Vibration of Manually Operated Machines, ETC.
I don’t think this is an
exhaustive list but it covers most of the areas. An important fact that has been mentioned by
my colleagues is the requirement to install an SSIV on the pipeline before the
platform as the as resort protection uncontrolled flow.
W Wong, “How Did That Happen”.
Engineering Safety and Reliability.
Professional Engineering Publishing. 2002.
uchenna onyia 51232632
MSc Subsea Engineering
In reply to Topic 4: Piper Alpha disaster
There is another offshore fatal event, similar to Piper Alfa disaster in terms of human losses, which I consider to be important incident for those interested in safety engineering. This occurred in 1980, approximately 250 km far from the city of Aberdeen at a Norwegian offshore location. Alexander L. Kielland, the semi-submersible drill rig owned by Stavanger Drilling Company and being hired by U.S Phillips Petroleum Company was used as a floating hotel (flotel) to serve production oil platform Edda 2/7C. The drill rig was built in France and delivered in 1978. So as it was decided to use it actually as an accommodation, after two years there had been added more living blocks and finally the flotel could accommodate up to 386 persons.
The fatal event happened at half past six on the evening of 27th March 1980, when one of the leg braces failed due to the strong wind and wave activity. This failure which is believed to have begun from 6mm defective welding, led to the failure of the remaining five braces and finally to the whole leg failure. The rig lost its balance and immediately sagged to the one side submerging the main deck and the living blocks. It remained in an angle of 35 degrees for about 15 minutes. During this time crew was attempting to release safety equipment like lifeboats and rafts but only a few were successfully launched on the water due to the damaged condition of the equipment and the significant wave activity. After this short period of time the last anchor failed with a result of entire capsize of the rig.
As many people were out of duty, they were trapped in their rooms. There were 212 people and only 89 survived making huge efforts to stand the extremely cold and wavy conditions of the sea without any protection. Some of them managed to swim to Edda platform while others swam to supporting ships and finally, many were rescued by using the lifeboats and rafts. Thus it was an event with the consequence of 123 people perished. This was the most significant incident in Norway after the Second World War.
In conclusion, I should mention there is a thought that this was not a random event of mechanical failure, but there is a sabotage theory. Below, I am providing my sources where is also included the link regarding this theory. Finally, I believe that these incidents played more than major role in forming safer constructions and legislations, although causing very high cost of human's life.
References: http://home.versatel.nl/the_sims/rig/alk.htm,
http://www.multinet.no/~falk/Falk1.0.htm,
http://en.wikipedia.org/wiki/Alexander_L._Kielland_%28platform%29
In reply to Topic 4: Piper Alpha disaster
The Piper Alfa disaster in North Sea provided significant information for designers of offshore facilities of next generations. One of the first constructions after this fatal event was the Norwegian oil platform named Troll A which was at the designing stage when Piper Alfa disaster occurred. Thus engineers gained a lot of essential information from this incident and started rechecking every detail, trying to reduce any hazardous probabilities and making some important changes.
Engineers were searching for ways in order to reduce effectively the consequences during unpredicted blow out or explosion circumstances. They constructed models at 1/12 of the original size of the platform for experimental reasons and then 80 explosions were performed providing additional important information. The first outcome during planning phase was that living blocks should be designed in a way that maximum safety could be achieved. Constructing the platform long and narrow they approached a shape which provided adequate safety distance of accommodations from the operation’s area. This could provide an immediate separation of living blocks from the rest deck, during explosion or blow out on the platform. Also the main hazardous areas, for example where drilling would be performed and BOPs or well heads would be mounted, were isolated. This was achieved by locating barriers of heavy steel layers around these areas and thus separating them in order to provide increased safety working conditions to the platform’s crew.
Finally, the platform’s Troll A construction was completed in 1996. It is the tallest construction of the world towed to the location which was its final offshore destination, where it is producing natural gas until today. In conclusion, I would like to mention again the importance of major disasters, study of which provided essential information for the next generations.
Approximately 470 m height
Destination towed over 170 miles
The operator company is Statoil
References: Discovery Channel Documentary Film: Troll A Platform
Most of today’s offshore regulatory regime is a direct
legacy of Piper Alpha. The HSE assumed responsibility for regulating the
industry with new sets of regulations being introduced, including the Offshore
Installations (Safety Representatives and Safety Committees) Regulations and
the Offshore Installations (Safety Case) Regulations
If Piper Alpha occurs today all of Lord Cullen’s key recommendations
below will be applied:
·
New legislation requiring safety cases
·
Goal-setting legislation
·
A single regulator
·
Offshore safety reps and safety committees
·
Revision of permits to work
·
Process
control
·
Mandatory
incident reporting
·
Hydrocarbon inventory
·
Fire and
gas detection and emergency shutdown
·
Fire and
explosion protection
·
Emergency
centres and system
·
Pipeline emergency procedures
·
Evacuation, escape and rescue plans and equipment
·
Standby vessels
·
Command in emergencies and training
If this event reoccurred, the knowledge from the
inquiry as well as the HSE study which addresses safety in a unique way and makes
the offshore oil and gas industry safe will apply. The awareness of the
potential of safety, the benefits and the application of a safer environment
will suggest ways in which it will be further prevented.
If the Piper Alpha disaster occurred today, the implemented 1992 Safety Case regulations submitted and approved by the Health and Safety Executive would be questioned and the inquiry would be critical for Piper Alpha's operator, Occidental Petroleum (Caledonia) ltd, having found guilty of inadequate maintenance and safety procedures. Also, criminal charges will be brought against it for breach of the safety case.
'The Safety case as one of the Lord Cullen recommendations which required the operator of an offshore installation to compile a large report that described each installation the processes, identified the hazards, evaluated the risks and what measures were taken to reduce those risks as low as reasonably practicable'(1).
In today's regime, goal setting environment allowing Operators of offshore installations to tailor the necessary risk reduction measures to the particular hazards on their installations, taking advantage of changes in technology and approaches. This implies that the operator of Piper Alpha platforms were not in compliance wiith its safety case. (Evident 1: Initial condensate leak as a result of maintenance work being carried-out simultaneously on a pump and related safety valve. This was done without proper evaluation of the risks involved, measures on how they can be mitigated and effective hand-over system in place for next shift/crew making them updated with current state of activities).
Also, Prevention of Fire and Explosion Evacuation Regulations (PFEER 1995) would play a dominant role in evaluating the fire water system in a more effective and reliable way. (Evident 2: Automation of the pumps as recommended for the fire water system was completely ignored and was never developed or implemented for the Piper Alpha Platform).
The Management Administration Regulations (MAR) also has a major role to be played in scrutiny the hierarchy of Authorization for effective communication and decision making with feedback system. (Evident 3:The Claymore and Tartan platform continued pumping until the second explosion because the manager had no permission from the Occidental control centre to shut down. Also, no attempt was made to use loudspeakers, or to order an evacuation for the control room which had no allowances from being destroyed).
Design & Construction Regulations (DCR) also has major role to play in verification of the platform design. (Evident 4: The Piper Alpha Platform had design-error with the control room having no allowance (absence of blast walls) of being destroyed).
In conclusion, reviewed, updated or new legislations are generated and implemented when learning/investagations have been done from historical events such as near-miss, accident or incident to identify new trend of emerging risks. If the above legislations existed (prior to 6 July, 1988) and were implemented with proper monitoring, the Piper Alpha disaster would most likely not have occurred especially in such magnitude.
References:
(1) "An Overview of Regulating Offshore and Onshore Major Hazards" EG50S1-Fundamental Safety Engineering & Risk Management Concepts, HSE Lecture 1 note.
(2) Piper Alpha - Oil Rig Fire Disaster http://www.youtube.com/watch?v=hqjUifxYxJ8
Deinyefa Stephen Ebikeme IBIYF
In reply to Topic 4: Piper Alpha disaster
Piper Alpha disaster is an offshore disaster which occured in the North Sea in July 1988. It was caused by, according to reports, a leakage of gas condensate which was ignited causing an explosion which erupted into large fires. According to safety standards of the time, there was a recommended 106 new pointers by Lord Cullen and his committee.
Additionally, the HSE also made recommendations which are now in place to ensure less exposure to such risks.
The owner (employer) is supposed to produce and submit a safety case to the HSE. This document must contain full details of arrangements for managing health and safety, and controlling major accident hazards on the installation. In this light, it would have been expected that the Occidental group which managed the platform would produce this document.
Safety procedures are now being enforced for most activities which are performed in the work environment offshore. In the light of this crisis, the permit to work would have been expected to have been available with adequate hand-oevr notes over the shift periods. Inability to produce such a report would serve to be a very damaging point on the part of the companies involved.
A Corporate Manslaughter and Corporate Homicide Act 2007against the operator would have been raised. It would have been so as there were lives lost on the Piper Alpha. This would have resulted in a publicity order as the Operator was really found guilty in the surrounding circumstances of the incident, which would be very damaging to the reputaion of Occidental.
http://www.oilandgasuk.co.uk/cmsfiles/modules/publications/pdfs/HS048.pdf
http://ilj.oxfordjournals.org/content/20/3/176.full.pdf
Health and Safety_ An Introduction to the UK Legal Framework
Yaw A. Boakye-Ansah
In reply to Topic 4: Piper Alpha disaster
The current legislative regime that will apply if the Piper Alpha disaster occurs today is GOAL SETTING LEGISLATIVE REGIM instead of the PRESCRIPTIVE LEGISLATIVE REGIM.The disaster took place on July 6 1988, as of this era, only the prescriptive legislative which was enacted as a result of the public inquiry into the sea gem incident of 1965.
This legislation ties the hands of the duty holders to their back because it only allows them to strictly adhere to the safety steps stated in the law to reduce risk in implementing their work. As such all what the duty holder had to do is to adhere to all the safety measures prescribed by law in order to reduce risk. It does not give room forinnovative initiatives from other bodies and the duty holders.
In 1988, Lord Cullen (one of the senior members of the Scottish judiciary) set up another public inquiry.
In 1990, the result from the inquiry was published by Lord Cullen with several recommendations.All the recommendations were implemented.This changed the PRESCIPTIVE REGIME to GOAL SETTING REGIME.This era brought about flexibility on the path of the duty holders to choose whatever safety measures necessary to reduce the risk to As Low As Reasonably Practicable (ALARP).
Bassey, Kufre Peter
M.Sc-Subsea Engineering-2012/2013
University of Aberdeen.
In reply to Topic 4: Piper Alpha disaster
Piper alpha offshore disaster was the worst accident in terms of lives lost in the oil and gas industry that resulted to the death of 167 men and $3.4billion of environmental damage in the North Sea on the 6th of July 1988. If the disaster occurs "today", the current safety legislation that will apply will be the Health and Safety at Work ACT (HSWA) of 1974 and Corporate Manslaughter and Corporate Homicide ACT 2007.
The main aim of HSWA legislation is to protect occupational health and safety. The Health and Safety Executive (HSE) is responsible to put into effect the ACT and a number of other Acts and statutory instruments important to the working environment. The agenda is centred on self-regulation ethics, with targets or goal setting rather than a prescriptive approach that targets to give strict rules for all possible work situations failure. The Health and Safety at work 1974 has a reverse weight of proof that means that, if prosecuted, the duty holder must prove that it reduced risk to a level As Low As Reasonably Practicable (ALARP).
Also, the result of the Corporate Manslaughter and Corporate Homicide ACT 2007 has improved the profile of safety obligations. Nonetheless, the 2007 ACT does highlight the importance of senior management and executive participation in safety. A Corporate Manslaughter prosecution will simply be successful if the gross breach of duty is due substantively to the way in which senior management has planned its activities.
References:
1. http://www.drivingforbetterbusiness.com/how/legislation.aspx
2. http://www.inhouselawyer.co.uk
Kingsley ENEM
It is regrettable that safety rules are not actually followed wholly until an unfortunate scenario occurs. The Piper Alpha tragedy exposed major failures in the manner in which operations were being carried out offshore.
Today there are Safety Recommendations and Regulations for offshore production.
a) Most significant of these recommendations was that the responsibility for enforcing safety in the North Sea should be moved from the Department of Energy to the Health and Safety Executive, as having both production and safety overseen by the same agency was a conflict of interest.
b) The North Sea installation is mandated to present a safety case to the Health and Safety Executive to show that the production companies have ample safety management system to ensure conformity with the HSE guidelines.
c) Also, an operator has to categorize all assets that have the potential for Major Accident Hazards (MAH). This is necessary to make obvious that apt and suitable controls have been set to the running of Major Accident Hazards.
d) HAZID and HAZOP study to assess risks associated with equipments and ensure measures to manage such risks.
e) Companies are required to continually demonstrate to the HSE that they are taking measures to minimize the risk of health and environmental hazards to As low As Reasonably Practicable (ALARP).
f) Inspection plan to test and verify industry conformity with the condition of the SI971 Offshore
Installations Safety Representatives and Safety Committees Regulations 1989.
Reference:
www.smd.qmul.ac.uk/risk/yearone/casestudies/piper-alpha.html
www.ecademy.com/node.php?id=80465
www.healthandsafetyatwork.com/hsw/piper-alpha-lessons
Adesunloye-Oyolola O.
MSc Oil and Gas Engineering
Lord Cullen's Inquiry:
Lord Cullen official Public Inquiry into the disaster comprised
two parts. The first was to establish the causes of the disaster. The second
made recommendations for changes to the safety regime. The inquiry began in
November 1988; report was published in November 1990.
Lord Cullen's Report:
Lord Cullen made 106 recommendations within his report,
responsibility of implementing them were spread across the regulator and the
industry as following
All of the Lord Cullen recommendations was accepted by the
industry, so they acted urgently to carry out their 48 recommendations and by
1993 all had been implemented.
Similarly the HSE developed and implemented Lord Cullen
recommendations which ended to the introduction of safety regulations requiring
the operator/owner of every fixed and mobile installation operating in UK
waters to submit to the HSE, for their acceptance, a safety case.
Mostafa Tantawi
Masters Of Subsea Engineering, University of Aberdeen
In reply to 2008 lessons learnt
I think this has to do with the division of responsibilities between role players in the implementation of the recommendations. After Piper Alpha, the whole safety methodology was changed (as you know, prescriptive to goal setting).
Prior to the Piper Alpha disaster, the responsibility for enforcing safety in
the North Sea resided with the Department of Energy, who also benefited from
production. After Lord Cullen’s enquiry, as a measure to separate the
production authority from the safety overseer, this was moved to the
Health and Safety Executive. This probably created a lot of new
uncertainties. Furthermore, industry was represented by UKOOA (today Oil
& Gas UK) in the 2nd part of the enquiry – how to prevent the
reoccurrence of such a disaster.
I think the idea was to create a collective approach,
where both the regulator and the duty holder work together to create a
safe environment. If they don’t work together, one will always
hide something from the other and you create an environment of blame
shifting when things go wrong. The duty holder compiles a safety case, which is evaluated and
approved/endorsed by the HSE. This basically makes them both responsible.
One important thing to keep in mind though, is that if you have a collective approach you need to be perfectly clear on the division of responsibilities.
Does anyone know what exactly the 106 recommendations were?
Hello folks
Even as late as 2008 I read with interest updates on the lessons learned from Piper Alpha. We tend to discuss the main recommendations from the Cullen report such as the Obligation for the Duty holder to present a safey case (or as otherwise known these days as a safety management system) for HSE review, the implementation of subsea and topside isolations, Evacuation improivements permit to work maitenance schemes etc. Infact there are 106 recomendations with the introduction of new regulations introduced initially by the department of energy but resposibility passed on to the HSE in the early 1990's. What I found interesting; or rather suprising, from the article referenced by O & G UK is that the HSE were responsible for overseeing only 57 of the recommendations. Perhaps I haven't interpreted this correctly. Can anyone clarify
Ref http://www.oilandgasuk.co.uk/cmsfiles/modules/publications/pdfs/HS048.pdf
Regards
Trevor
In reply to Topic 4: Piper Alpha disaster
SI-913 {The Offshore Installations and Wells (Design and Construction, etc.) Regulations -1996} has been mentionned a couple of times in previous comments as applicable if the Piper-Alpha happens today . This is correct but in this post , I would like to commnet on the boundary of application of the two commonly used schemes as per SI-913 :
1) Well Examination Scheme (SI-913 regulations 13 to 21)
2) Installation Verification Scheme (SI-913 regulations 4 to 12)
Regulation 18 Guidance , of the Offshore Installations and Wells (Design and Construction , etc ) Regulations [SI 1996/913] explains the relationship between the requirements for a well examination scheme and the installation verification scheme : " When a well is connected to a fixed or a mobile installation , there may be an overlap between the well examination scheme and the verification scheme for the installation."......"The well examination scheme does not cover equipment that falls outside the pressure boundary of the well . Where such equipment is deemed to ba safety critical , it would need to be included in the installation verification scheme.".
So what does that mean ?
As per SI-913 , the well is defined in terms of its pressure containment boundary. Any equipment that is vital to controlling the pressure within the well is therefore covered and defined as Safety Crtical Equipment (SCE). This would include the downhole pressure containing equipment and the pressure containing equipment on top of the well (BOP, Xmas Tree...) but excludes well control equipment downstream that can be isolated from the well by valves.
So for Piper -Alpha the well examination scheme is not applicable a) above the top of the BOP stack and outside the choke and kill valves b) downstream of the swab and wing valves of a Xmas Tree c) at the top of the stuffing box of a wireline BOP .
Please note that those schemes are applied differently if we have a MODU over a subsea well in a drilling mode or a well test / production mode.
Reference :
Health and Safety Executive: A guide to the well aspects of the Offshore Installations and Wells (Design and Construction, etc) Regulations 1996 , second edition ( 2008 ).
In reply to Topic 4: Piper Alpha disaster
HSE legislatives that would be used if the Piper Alpha disaster occurred today are as follows:
Since Piper Alpha the industry has learnt a great deal about designing facilities to withstand major incidents through fire, explosion and layout research.
A operator company has to identify for all assets (Existing/Future) that have the potential for Major Accident Hazards (MAH).
The intention is to demonstrate that the appropriate controls have been allocated to the management of MAH such that the risks have been reduced to As Low As Reasonably Practicable (ALARP)
A operator should knows what technical and human activities occur, how they are managed, and how safety will be managed in the event of an emergency.
It must also identify methods to be used for monitoring and reviewing all activities in connection with the facility, with a view to the continual improvement of the safety arrangements of the facility.
Inspection programme to check industry compliance with the provision of the SI971 Offshore Installations Safety Representatives and Safety Committees Regulations 1989.
For offshore installation a company has following requirments (The Offshore Installations (Safety Representatives and Safety Committees) Regulations 1989 (SI 1989/971)
There must be saftey representative for a installation, well trained on aspects of safety representative functions.
Safe maintenance, repair and cleaning procedures (HSE ,Dangerous Substances and Explosive Atmospheres Regulations 2002)
Workplace health, safety and welfare. Workplace (Health, Safety and Welfare) Regulations 1992
The piper alpha disaster is one of the worst offshore accidents in the history of oil and gas with 167 lives lost. During the time when the incident happened, the safety legislative regime in place was the prescriptive legislative regime.
The prescriptive legislative regime was born out of the public inquiry into the sea gem incident of 1965. The prescriptive regime prescribes necessary safety steps to be taken to reduce risk. As such all the duty holder had to do was adhere to all the prescribed safety measures. After the piper alpha incident in 1988, another public inquiry was set up under Lord Cullen and it published its result in 1990 with several recommendations all of which were implemented. As a result the legislative regime changed from the prescriptive regime to a goal setting regime. In the goal setting regime, the process is prescribed but not the outcome as against the prescriptive regime where the outcome is prescribed. That is to say that in the prescriptive safety legislative regime, what the duty holder has to do to avoid the occurrence of accident is stated in the legislation while it is not stated in the goal setting regime. The goal setting safety legislative regime rather states the process the duty holder is to follow which is that he should prepare a report about the installation that identifies the hazard, evaluate the risk and what measures were taken to reduce those risks as low as reasonably practicable. This allows the duty holder to choose whatever safety measure necessary to reduce the risk thus allowing for more flexibility.
The goal setting regime has since then been the safety legislative regime that is applicable. In conclusion, if the Piper Alpha disaster were to occur today, the goal setting safety regime will apply.
It has been mentionned in this Blog that if the Piper Alpha disaster occured today, then SI-2005 No 3117 : Offshore Installations (Safety Case) Regulations would apply . I agree with this statement .
The reason is that the safety case is the way used by the Duty Holder (the Operator in most of the cases ) to formally document and demonstrate to the UK HSE that the unit or installation is safe over its life cycle (i.e. design , construction and operation). In the case of Piper Alpha , and assuming it was designed and installed back in 2003, the Duty Holder should have demonstrated to the HSE that " all hazards with the potential to cause a major accident have been identified and all major accident risks have been evaluated and measures have been , or will be, taken to control those risks to ensure that the relevant statutory provisions will be complied with ". (SI-2005 No 3117 secion 12 page 10).
For fixed offshore installations (as Piper Alpha) , the Duty Holder shall seek the HSE ascceptance of the operational safety case 6 months prior of operation and it is recommended by DNV that the "Duty Holder should ensure that any HSE issues are addressed prior to submission of the operational safety case " (DNV-OSS-202 page 11).
Assuming the Piper Alpha disaster happens today , there will be a very thorough revision of the previously accepted safety case to ensure that that the Operator have followed all the procedures and arrangements described in the safety case and which had been accpted by the HSE. If that is not the case, then the Operator can face legal consequences and " criminal proceedings".
Moreover , and assuming the Piper Alpha remained in an operating condition after the disaster, it is most probable, that a revised safety case was going to be re-submitted to the HSE and that the Operator was not allowed to re-operate the platform without the HSE approval of the revised safety case that eliminates the root cause of the incident.
As explained in my previous post, flaws in
the design guidelines and design practices contribute to the disaster. The
design philosophy of emergency, protection and safety systems was generally
faulty. The layout of the platform allowed the fire to propagate quickly. Most
of the FPSO and platform today has blast wall which is installed in front of
the accommodation to segregate the production zone (hazard) and separating
personnel from fire and explosion hazards. Sufficient protection against and
mitigation of fire (A60 insulated bulkhead/panel) in engine room, control room,
electrical room as well as accommodation are required by classification. Model
tests like wind tunnel test, explosion testing and simulations are performed
during the engineering design phase. The objective of these tests is to improve
the design of the platform/rig.
The evacuation routes were blocked and the
lifeboats, all in the same location, were mostly inaccessible in the Piper
Alpha platform. The platform design today is strictly required to follow the
classification regulations. For example, there are at least two lifeboat
platforms (forward and aft) in a drilling platform. The safety route must be
cleared from obstructions and it is at least 1m width.
Loss of electric power and there is no
adequate redundancy in the power system. Electrical power is needed to active
most of the emergency shutdown, fire-fighting and evacuation operations. All
drilling platforms today has emergency power source on board, eg. emergency generator
which is located far away from main generators. UPS, battery activated power
sources must be provided for each of the critical systems in case of failure of
the central supply.
The given examples above are to highlight
the importance of implementing correct design guideline and design philosophy in
a platform/drilling rig design.
Soo Chyi, Lee
The Piper Alpha
disaster revealed the potential of operation failures with respect to
dramatically destroying an entire offshore installation.
The main contributors
to the Piper Alpha Disaster are:
1)Poor design
and layout (eg, absence of blast wall, and the layout of the platform did not
take into account safety in the design philosophy.
2)Failures
to comply with Occidental’s Permit to Work (PTW) procedure
3) Inadequate
staff training
4) Inadequate
monitoring
5) Lack of
emergency preparedness
6) Prioritization
of production over safety
7) Regulatory
issues.
Today we have a Safety Case Regulations,
which requires each North Sea installation to submit a safety case to the HSE
demonstrating that the operator has an adequate safety management system in
place to ensure compliance with the regulation; HAZID & HAZOP study to identify
all hazards with the potential to cause a major accident; evaluates the risks
and has put in place measures to control these risks and ensure compliance with
the relevant statutory provisions. Companies are required to continually demonstrate
to the HSE that they are taking measures to minimize the risk of health and
environmental hazards to ALARP.
Regards,
Lee, Soo Chyi
Piper Alpha disaster occurred on July 6 1988 during the regime of prescriptive legislation.
During this regime were the mineral working Act and health and safety working act used to regulate offshore health and safety.
This legislation on its own as draw backs in its application due to the prescriptive nature :it does not provide room for improvement or use of initiative, it only requires compliance among others.
The major ingredient for piper Alpha accident which are inadequate maintenance and safety procedure, poor risk assessment as well as poor integrity management procedures could have been avoided or the aftermath of the disaster would have been mitigated if it occurred today with the regime of goal setting legislation.
With the use of goal setting legislation, the design of the piper Alpha platform itself would have been reviewed to cater for the inadequacies such as inclusion of SSIV (subsea safety isolation valve) in the flow lines and blast walls in the design among others.
Furthermore, the situation in piper Alpha were the gas compression was close to the control room which killed everybody in the room and prevented instruction being giving out on emergency evacuation procedure would less likely happen because the goal legislation requires that the subsea production system (dangerous operation) should be offset some distance away from the facility so as not to jeopardise safety of offshore facility and personnel and the PFEER (1995) would also help to contain the explosion as well enlighten workers on the proper emergency response.
However, we cannot completely rule out the fact that even with goal setting legislation we do have disaster in offshore facility which is attributed directly or indirectly to integrity loss by we humans.
But the advantage with the advent of goal setting is that integrity loss associated to human can be managed by putting in place different safety procedures, Risk assessment procedure as well as design and construction integrity procedures which will mitigate the risk of disaster to ALARP.
Olamide Sherifah Ajala
Student ID:51230562
Course:Sub sea Engineering
olamide.sherifah.ajala@aberdeen.a.uk
Following the Lord cullen’s recommendations on the Piper Alpha Disaster that took place on 6th of July 1988 with scores of lives, a disrupted supply chain, and billions of dollars lost, several modifications were put in place to arrive at more refined safety legislative regimes that applied to the offshore oil and gas sector. The legislative emphasis was concentrated on three major areas based on cullen’s public enquiry:
· Shift from prescriptive laws to goal setting laws.
· Requiring Operators to compile reports outlining the various components of the offshore installation, identify possible hazards and define mitigative steps for attaining ALARP conditions.
· Changing the governing body from the Department of Energy to the Health and Safety Executives.
Although, these were tremendous steps in the right direction, they were considered insufficient to meet the safety standards in the 21st century Oil and Gas industry. Additional steps were taken to fine-tune and upgrade the 1992 ‘Safety Case regulations’ (which were generated based on Lord Cullen’s report), producing the “New Safety Case regulations” in 2005. It was decided that the offshore safety regulations would be reviewed and upgraded every 10 years, with the next upgrade slated for the year 2015.
The Offshore environment is forever evolving, and the ALARP region is becoming more difficult to attain, with safety bars being raised higher. Precautions and safety are not just a company’s prerogative, but are the Law, and must be adhered to or risk license seizures. The European Commissions’’ plan to control European offshore safety from a single centralized EU regulatory body is a horrible idea, and would only serve to undermine and backtrack a sizeable amount of improvement that has been made in the UK oil and gas industry. To avoid a reoccurrence of the Piper Alpha accident today, “The New Safety Case regulations- 2005” and goal setting “European directives” must operate in synergetic combination.
References;
http://www.gov-news.org/gov/uk/news/new_offshore_safety_regulations_become_law/38930.html
http://www.legislation.gov.uk/uksi/2005/3117/pdfs/uksi_20053117_en.pdf
http://www.oilandgasuk.co.uk/cmsfiles/modules/publications/pdfs/HS048.pdf
Oluwatosin Oyebade
In
addition to the necessary legislation as stated in my previous post, the duty
holder would have been subjected to prove or show that it had complied with the
statutory provisions as stipulated by the health and safety Executive (HSE)
offshore division's regulations. Assuming that all the regulations were met,
the risk and issues therein now lies at the operational stage of the
installation. The question will now be: to what extent has these measures which
have been put in place adhered to? - (this was not the in a positive light with
the piper alpha accident.
The
assessment principle for offshore for offshore cases (APOSC) would have also
applied. The duty holder would have provided sufficient details to show that
prior to the accident, it complied to the best safe work practice which
includes that: the management system/organisational structure and reporting
lines were adhered to; that there was control in each phase of the maintenance
procedure which resulted to the explosion; that a risk analysis was done prior
to the planned maintenance; and that human factor was taken into consideration.
If the failed to show all of these, the sanctions and associated fines as
stiputed therein will apply.
Dike
Nwabueze Chinedu
Student Number: 51123954
MSc
Subsea Engineering
...Engineering
Sustainably.
If the piper alpha accident occurred today, the legislation that
will apply will be: Offshore installation (safety case) regulation 2005 (SCR);
the offshore installation (prevention of fire and explosion and emergency
response) regulation 1995 (PFEER); and management administration regulation
1995 (MAR). These regulations requires the duty holder to identify all possible
risk, evaluate them and plan measures to reduce them as low as reasonably
practicable (ALARP) [1]. The PFEER also places responsibility on the duty
holder to protect persons on the installation from fire and explosion and the
responsibility for securing effective emergency response [1]. In general, the
practice of safe work environment and prevention from hazard is placed on the
duty holders by these legislation, infact, the duty holders are required to
submit a report in this regard [1].
A critical look at into the piper alpha accident that occurred on
6 july 1988 at the North Sea killing 167 men shows that the following factors
were responsible: safety was compromised for continues production; systems
reliability issues were involved; exposure to hazard as a result of human error
factor; plant modification issues. Other factors which culminated to and
escalated the fatality rate include: poor firefighting equipment and inadequate
evacuation system. These facts all point fingers to the duty holder.
Official enquiry into the accident by the Lord Cullens committee
in 1990 indicted Occidental Petroleum for having inadequate maintenance
procedures but no criminal charges were brought against them, just maybe
because as at that time the PFEER and SCR which stipulates the penalties for
non compliance or bridge of the regulations was not yet on board.
But if it were to be today, the penalties for non compliance and bridge of the provisions of the offshore SCR, PFEER and MAR legislations will be enforced.
REFERENCES:
[1] The Offshore Installation (prevention of fire and explosion
and emergency response) regulation 1995. [Online] Available from: http://www.legislation.gov.uk/uksi/1995/743/made
[accessed 5 October 2012].
Dike Nwabueze Chinedu.
Student Number: 51123954
MSc Subsea Engineering
...Engineering Sustainably.
If the Piper Alpha disaster
occurred today, discuss the current safety legislative regime that will apply.
If the piper Alpha disaster
occurred today, the current safety legislative regime that would be applied is
the Health and Safety Executive (HSE) through its offshore division. The
offshore division of Health and Safety Executive is responsible for carrying
legislative duties in the offshore oil and gas sector in the united kingdom.
Some of the safety case regulation that would have been used if the piper Alpha
disaster occurred today are:
·
The
Offshore Installations (Prevention of Fire and Explosion, and Emergency
Response) Regulations (PFEER): this regulation provide guidelines for the
protection of offshore workers from fire and explosion, and for securing
effective emergency response. This regulation covers the personnel level of
assessment to identify event which could give rise to fire or explosion,
preparation for emergency, equipment for helicopter emergency, emergency
response plan, prevention of fire and explosion, detection of incident, communication,
control of emergency, mitigation of fire and explosion, muster area,
arrangement for evacuation, means of escape, arrangement for recovery and
rescue, Suitability of personal protective equipment for use in an emergency, Suitability
and condition of plant, Life–saving appliances, Information regarding plant and
Certificates of exemption
·
The
Management of Health and Safety at Work Regulations: this regulation provide guidelines
for Risk assessment of offshore workers, Health and safety arrangements, Health
surveillance, Health and safety assistance, Procedures for serious and imminent
danger and for danger areas, Information for employees, Co-operation and
co-ordination, Capabilities and training, Employees' duties, Temporary workers
and Exemption certificates.
Reference:
http://www.legislation.gov.uk/uksi/1992/2051/made/data.pdf