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Offshore oil and gas E&P activities are, by nature, not inherently safe. These complex activities require the handling of large amounts of pressurized hydrocarbons and other produced fluids and gases. The industry has been learning the process safety lessons for more than 25 years, ever since the Piper Alpha platform accident (1988), but we still have a long way to go in effectively managing major hazards.
We believe that an offshore safety regime, which deploys performance-based regulation requiring major hazard reports—including risk assessments and independent verification, supplemented by specific prescriptive regulation for selected areas—is the most effective regime model. This view has been supported recently by the new European Union Offshore Safety Directive (Directive 2013/30/EU).
DNV GL has monitored the directive’s development over the last two years, and has provided input on it, both directly to the European Commission, and indirectly, via consultations with industry bodies. DNV GL’s evaluation of the new regulatory framework concludes that it contains many elements necessary to reduce the probability of major accidents offshore, and to limit their consequences, should they occur. However, adapting the directive into national legislation by member-states will dictate its real effectiveness.
Areas, such as Asia-Pacific, Africa and the Middle East, have yet to develop a risk-based approach, and are still formulating regulatory regimes, as local hydrocarbon industries develop. What we do have, however, are major operators that have moved into these areas, and have taken best practices from the North Sea with them.
Safety culture starts with setting the “tone from the top,” at the boardroom level. Leading-edge companies are demonstrating greater board level leadership on major hazard issues, which is to be commended. DNV GL is focused on securing boardroom commitments to process safety and major hazard management. We work routinely with customers in this respect, to increase understanding of the key levers for success, which need to be recognized, to improve performance.
What happened at Macondo was not unique; many of the elements that led to the disaster had been seen before. Media reporting of the event focused on what occurred with the subsea blowout, but some tend to forget what happened on the rig and how people, unfortunately, became fatalities. The decision-making process for Transocean’s Deepwater Horizon rig was compartmentalized excessively while drilling the Macondo well, with individuals on the rig frequently making critical decisions without fully appreciating just how essential those decisions were, to ensuring well integrity and worker safety. During the immediate post-blowout response, many rig systems and processes failed to respond correctly to the incident as it escalated, and much still remains to be learned from the incident.
There have been far too many major hazard incidents in the last 25 years, such as Macondo, Montara and Piper Alpha offshore, or Texas City onshore. Lessons we should be learning are not being embedded into risk management as much as I would like. Many decisions that we need to take, for the long-term management of risks, are often replaced by short-term decisions on profitability.
While there is plenty of focus on personal safety in the industry, and companies have done well to improve their occupational safety performance, this contrasts with a lower profile for, and reporting of, process safety issues. The situation with process safety, in comparison to occupational safety, is that the degree of understanding is different, depending on who you ask. If you ask those involved in operations and maintenance, who deal with incidents on a regular basis, they have a good understanding, not only of the incidents themselves, but of the importance of the barriers that prevent those incidents from occurring. The further you move away from the operational arena, the less awareness you get.
Occupational safety is a tangible experience for all of us. We’ve all experienced somebody who has cut a finger, or had an occupational-style accident, such as a slip or trip. Yet, few of us have experienced the aftermath of a fire or an explosion. When we talk to senior management about the potential for, or the impact of, a major hazard event, such as a fire, blowout or gas explosion, they have not all had that experience. It is more difficult for them to picture and understand the situation. This is why many oil and gas companies now send senior management teams to our Spadeadam facility for major hazards awareness training.
Those countries that surround the North Sea basin, which deal with operations in relatively harsh environments, have a good understanding of process safety, and have been much closer to understanding the lessons of Piper Alpha. A risk-based approach to legislation has grown in the North Sea as a result, as a global best practice.
Australia followed this model, as its industry grew, and it also adopted a risk-based approach several years ago that has worked well. The U.S., for a number of reasons, which include the legislative environment, has been much more based on prescriptive rules and legislation. Although prescriptive regimes have the advantage of being relatively easy to implement and monitor, they are not as effective at preventing new types of accidents, which may appear in the future and are not anticipated by the existing rules. The risk-based approach, which has encouraged many operators to go beyond regulations, wherever they operate in the world, has delivered benefits in reducing risks, while controlling costs. 
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