Defining the “H” in HSE
I can remember attending my first SPE Health, Safety and Environment (HSE) Conference many years ago. The focus then was on safety and protecting the environment. I remember getting my first “Stop Work” card—each and every employee had the authority to stop an operation, if there were concerns about unsafe practices. I can remember changing casing and cementing designs to better protect shallow aquifers. I can remember adjusting drilling schedules to be more in line with the natural cycle of wildlife. But, where was the discussion on the “H” in HSE? How was “H” different from “S”?
Earlier this year, I had the opportunity to attend an SPE Forum Series entitled, “Health and Social Responsibility: The role of the oil and gas industry in community health.” The HSE acronym had changed to HSSE-SR, which stands for Health, Safety, Security, and Environment – Social Responsibility. For me, it was an unusual conference, because there were only four petroleum engineers in attendance. I have never been around so many health professionals.
It was obvious from this forum, that large producers and service companies are very much engaged in community health. Several of these companies had taken a lead position in their operating areas during the Ebola scare. But most of these people were employed or engaged with the “BIG” companies. For those of us who are not with a BIG company, where do we get information? How do we find out about the “H” in HSE?
Every day in the press, some article discusses the negative health impacts of oil and gas development near a community. These health impacts can be noise, emissions, water contamination and vibrations from operations. Sometimes, studies are identified within the article. Have you ever tried to read one of these studies to determine its credibility? I have.
Epidemiological studies are most definitely not my area of expertise. Therefore, I have to try and find a credible interpreter who can translate the information into language that I can understand; who can also judge the merits of the assumptions upon which the study was based, and then who can provide operational solutions.
To date, I have not found this information source. Yes, there are places where a person can get a bit of information here and a bit more there—universities, regulatory bodies, health departments, environmental groups, trade associations, research hospitals, and some company websites. However, this is an enormous endeavor that cannot be done by a lone person, who is still trying to do an engineering job. There is definitely an industry need for such a credible organization.
Operator performance. Companies can benchmark their progress on “H.” The joint Health Committee of the International Association of Oil & Gas Producers, and International Petroleum Industry Environmental Conservation Association, published “Managing health for field operations in oil and gas activities.” This report developed a tool to assess leading health performance indicators within companies. There are eight elements within the analysis. Two of the elements deal with external issues.
Element 6 is entitled, “Health impact assessment,” and gauges a company on whether HIAs (Health Impact Assessments) are initiated during the development stage of all new projects and expansions. Key environmental factors affecting human health, including air, soil and water quality, are assessed. These tools are very useful, especially in areas where the regulatory framework for oil and gas is not as mature as some producing regions.
Element 8 is entitled, “Public health interface and promotion of good health,” and gauges whether an effective interface exists between public health and occupational health is maintained, to identify key sources of epidemiological information. Again, in mature oil and gas areas, regulatory bodies may maintain this information already.
The regulatory angle. Some of you may wonder why I am so concerned about the “H” in HSSE-SR. Truth be told, I am concerned about all elements of the acronym and how the individual parts come together in meaningful regulations that optimize E&P with HSSE-SR.
For the last 71/2 years, it has been my privilege to be a member of the Colorado Oil & Gas Conservation Commission (COGCC), which is the state’s regulatory body for oil and gas. Regulation is the intersection of oil and gas drilling and production with HSSE-SR for all stakeholders. Much like project teams within companies, the COGCC is a team of specialists. Our mix includes three engineers, one PhD environmentalist, one environmental attorney, one elected official, one royalty owner, the head of the Colorado Department of Public Health, and the head of the Colorado Department of Natural Resources’ Oil & Gas Division.
Regulations change with new technology. If members of the COGCC do not have particular expertise, we are fortunate to have so many stakeholders who do have that information—companies and organizations—that come before us and share their knowledge. But, if a company or group or stakeholder isn’t present during these presentations, where is the credible clearinghouse that stores the information?