1.CHEM.E. SYMPOSIUM SERIES NO. 122 SAFETY AUDITING I N THE OFFSHORE INDUSTRY I. G. WALLACE* INTRODUCTION The offshore oil industry tends to utilise three types of safety audits: Techni ca1 Audits Safety Programme Audits Pol icy and Procedure Audits As the name imp1ies, the Technical Audit, usually called the Process Audit, looks at the design and construction standards of the equipment to ensure that the facilities meet the current company and industry design standards such as Institute of Petroleum (IP) American Petroleum Institute (API), etc. This Audit is carried out on an approximately 5 yearly cycle by re1evant di scipl i ne engineers. The Safety Programme Audit i S in fact a series of annual audits carried out to ensure we continue to meet company safety programme standards and legisl ative requirements. Typical audits cover Training, Radioactivity, Contract Drill ing etc etc. These audits are carried out by re1evant company personnel and where appropriate outside consultants. In some companies these audits are very wide ranging and utilise the International Safety Routing System (ISRS) or the British Safety Council Five Star Programme. The last facet of the audit programme is the Management Safety Audit. This annual audit i s carried out by a group of senior managers, who spend 24 hours on each facility looking in depth at a number of * Safety Manager, Sovereign Oil & Gas PLC, Aberdeen
Transcript
1.CHEM.E. SYMPOSIUM SERIES NO. 122
SAFETY AUDITING I N THE OFFSHORE INDUSTRY
I. G. WALLACE*
INTRODUCTION
The o f fshore o i l indust ry tends t o u t i l i s e three types o f sa fe ty audi ts:
Techni ca1 Audits Safety Programme Audits Pol i c y and Procedure Audits
As the name imp1 ies, the Technical Audit, usua l ly ca l l ed the Process Audit, looks a t the design and construct ion standards o f the equipment t o ensure t h a t the f a c i l i t i e s meet the cur rent company and indust ry design standards such as I n s t i t u t e o f Petroleum ( IP) American Petroleum I n s t i t u t e (API), etc. This Audi t i s ca r r i ed out on an approximately 5 year ly cycle by re1 evant d i sc ip l i ne engineers.
The Safety Programme Audit i S i n f a c t a ser ies o f annual audi ts ca r r i ed out t o ensure we continue t o meet company safe ty programme standards and l e g i s l a t i ve requirements. Typical audi ts cover Training, Radioact iv i ty, Contract D r i l l i ng e tc etc. These aud i ts are ca r r i ed out by re1 evant company personnel and where appropr iate outside consultants. I n some companies these audi ts are very wide ranging and u t i l i s e the In ternat iona l Safety Routing System (ISRS) o r the B r i t i s h Safety Council Five Star Programme.
The l a s t facet o f the aud i t programme i s the Management Safety Audit. This annual aud i t i s ca r r i ed out by a group o f senior managers, who spend 24 hours on each f a c i l i t y look ing i n depth a t a number o f
* Safety Manager, Sovereign O i l & Gas PLC, Aberdeen
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safety procedures and programmes to establish whether the p01 icy/programme is relevant, implemented properly, being effective and to identify problem areas or changes needed for the future. The audit allows the facilities to be given credit for the good things that they are doing and senior management gains an appreciation of the problems being encountered in achieving a safe operation and confidence that the facilities are in fact well managed.
2.0. SAFETY AUDITS
As already explained in the introduction, the Industry operates 3 types of safety audits:
1. Technical Audit (or Process Audit) 2. Safety Programme Audits 3. Policy and Procedure Audits (or Management Safety Audits)
The first two are fairly standard and will be familiar to many other companies so that I do not propose to go into too much detail about them. However, the Management Safety Audit is only used by one or two other North Sea Operators, as far as I am aware, and so it may be of much wider interest and I have therefore devoted the bulk of my paper to this technique.
3.0. TECHNICAL AUDIT (PROCESS AUDIT1
The Process Audit programme results from an awareness that the production process i S continually changing with changes in the reservoir characteristics. In addition technology steadily improves so that what was considered safe and satisfactory a few years ago may now not be considered prudent. In addition new techiques for assessing safety are developed as time passes. That is not to say that modern techniques are not utilised on these older facilities however the new techniques tend to be appl ied progressively to solve specific problems or in response to specific incidents. It is therefore appropriate at intervals to stop and take stock of.the overall situation and see how we would design the overall facilities at that point in time. Where we identify differences between the existing faci l i ties and the current theoretical design we assess the effect that the differences have on safety and implement them in the short term, incorporated them in the long term plan or justify why it is not necessary to implement them.
The latest audit that I have been involved in covered the following areas:
1. API RP 14C compl iance 2. Platform Logic, Cause and Effect Chart and Emergency Shutdown
Val ve Review .
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3. Area Class i f icat ion 4. Pressure Safety Val ve/Fl are Header Capacity checks 5. Operating procedures and operating l i m i t s 6. Vessel capacities 7. Piping capacities 8. El ectrical/Uninterruptabl e Power Supply (UPS) capacity 9. Ergonomi CS
P1 atform drains and atmospheric vent systems were not included, having been extensively reviewed as separate items i n the past. U t i l i t y systems were also not included i n the study.
Specif ic areas are a1 located t o appropriate d i sc ip l i ne engineers. Where necessary additional spec i f ic expertise i S brought i n from Contract Engineers. A Senior Engineer runs the audit co-ordinating the a c t i v i t i e s and ensuring that adequate resources are avai l able. Periodic reviews are carr ied out wi th Production & Safety t o report on progress and the resu l ts t o date. At the end o f the audit an overal l report i s prepared describing the areas looked at, the problems iden t i f i ed and the projects raised t o correct the def ic iencies. O f course t h i s report i s backed up by detai led reports covering each spec i f ic topic.
3.1. API RP 14C Com~l iance
The object here was t o determine whether the individual items o f equipment complied with the recommendations o f API Recommended Practice No 14C. This out1 ines the minimum leve ls o f protect ion f o r process equipment and i t s basic tenet i s that there should be two independent leve ls o f protect ion against any par t i cu l ar unwanted event.
3.2. Loaic. Cause and Effect + ESD Review
The u n i t control l og ic (UCL) which operates the platform safety shutdown systems i s defined, as f a r as the i n i t i a t i n g deviations and control actions, through the Cause and Ef fect Charts.
These charts are presented as a matr ix and describe the outcome o f a deviation i n terms o f the i so la t ion valve actions. It i s imperative t o have an up t o date record o f the status o f the log ic and, t o t h i s end, a survey o f the UCL was carr ied out, changes t o the or ig ina l design were highl ighted and subjected t o review. Following the update o f the Cause and Ef fect charts the actual Emergency Shutdown System (ESD) was reviewed and confirmed as sat isfactory.
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3.3. Area C lass i f i ca t i on
An examination was ca r r i ed out t o determine what changes had taken p1 ace on each p1 at form which might in f luence the zoning o f areas w i th respect t o hazard c l ass i f i ca t i on . The basis f o r the c l a s s i f i c a t i o n was the B r i t i s h code o f p rac t i ce BS5345 and the I n s t i t u t e o f Petroleum code.
3.4. PSV/Fl are Header Checks
Of prime importance i n safe handling o f hydrocarbons i s the a b i l i t y o f the pressure sa fe ty valves (PSV) on a l l items o f equipment t o handle the worst case f lowrate under r e l i e v i n g condi t ions. It was there fore important t o check where r e l i e f valves were required and also t o determine by de ta i l ed s i z i ng whether the valves were s u f f i c i e n t l y l a rge t o accommodate both present and fu tu re f lowrates. Accurate ca l cu la t i on o f the e f f e c t o f back pressure from the f l a r e system on the r e l i e f valve performance was ca r r i ed out where appropri ate.
3.5. O ~ e r a t i nq Procedures and O ~ e r a t i nq L im i t s
It i s recognised t h a t each system should have an adequate se t o f operat ing i ns t ruc t i ons f o r start-up, shutdown and normal operat ion and t o t h i s end i t was ant ic ipa ted tha t the Process Aud i t should address t h i s area. The Operating L im i t s were reviewed i n the l i g h t o f the rese rvo i r condit ions, PSV, Vessel and Piping capac i t ies t o ensure t h a t the l i m i t s were su i t ab le f o r the cur rent condi t ions.
3.6. Vessel C a ~ a c i t i e s
This i s s i m i l a r t o the pressure sa fe ty valve analysis and was an examination o f the adequacy o f the vessel S f o r cur rent and fu tu re requirements.
Erosional considerations o f p i p ing v e l o c i t i e s warrant considerat ion and t o t h i s end a check was made on product ion headers and c r i t i c a l p i pework.
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3.8. Electrical Ca~aci ties
The adequacy of the electrical, normal and emergency and uninterruptabl e power supply systems was examined to confirm that they were adequate and meet current standards.
This relates primarily to instrumentation and the ease of operation and control by Operators. Shortcomings in men-machine interfaces were investigated for future improvement.
4.0. SAFETY PROGRAMME AUDITS
Most companies develop and introduce programmes and activities to identify and correct safety deficiencies and weaknesses and raise the level of safety. It is important if these programme are to be effective that they are audited on a regular basis to monitor compl i ance and identify weaknesses in the programmes and standards.
Typical of these are the following;
4. l. Environmental Oual itv Assurance Audit
This involves a thorough annual audit of all discharges from the offshore platforms and is carried out by the Company Environmental Scientist.
The Audit consists of examining re1 evant documentation on the platforms eg:
i. Oil spill contingency plans ii . Continental She1 f notices.
ii i . Oil in water reporting procedures iv. Oil in cuttings reporting procedure v. Chemical usage recording and reporting vi. Oil spills monitoring and reporting
vi i . Remote sensi ng/aeri a1 survei l l ance reporting
This is followed by a general facility inspection and the witnessing of the calibration of offshore I/R oil in water analyser.
Samples are taken for onshore oil in water cross checks with offshore laboratory results.
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4.2. Radiation Protection Audit
This involves a thorough annual audit with respect to ionising radiations at all locations and is carried out by the Contract RPA along with the onshore and offshore Radiation Protection Supervisors. Included are checks in documentation covering :
i . Registrations ii. Authorisations
i i i . Disposal records vi. Source records v. Controlled and supervised area records
vi . Source leakage test records vii. Instrument calibration records
vi i i . Dose records ix. Transportation records
A full examination of all "Local Rules" is carried out along with a general facil i ty inspection.
4.3. Chemical S Hazardous Materi a1 S Audit
The platform audit is to make an inventory of all hazardous substances. It is carried out periodically by the onshore safety advisor special ising in chemical safety and the industrial hygienist. They list all substances on the platform and confirm that an up to date material safety data sheet is available for each of them.
Most companies are expanding this audit to cover COSHH requ i remen t S.
4.4. Traininq Audits
This is a rolling audit of all personnel, company and contractor, safety training aiming to cover everyone approximately annually. It is carried out by the training section of the Employee Re1 ations department. The audit compares actual training received by personnel against the standards laid out in the Division Training Policy. The p01 icy defines survival and safety training required for all personnel. The relevant parts are included in contracts.
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4.5. ISRS and Five Star Proaramme
These aud i t programmes are very de ta i l ed and requ i re f u l l y t r a i ned safe ty auditors. Although I have taken the ISRS t r a i n i n g I have never used the programme but i t has inf luenced me and the programmes t h a t I have developed.
Having discussed t h e i r experiences w i t h a number o f users o f the ISRS system i t c e r t a i n l y benef i ts the company i n many ways i n add i t ion t o safety, however, i t i s a very major long term commitment and f requent ly i t i s necessary t o adapt the programme t o the company.
MANAGEMENT SAFETY AUDIT
I n l a t e 1986 the company t h a t I worked f o r decided t o i n s t i t u t e an annual management safety aud i t o f the Aberdeen f a c i l i t i e s as p a r t o f the programme o f a c t i v i t i e s designed t o r a i s e the l eve l o f awareness o f and commitment t o sa fe ty i n a l l employees. The ob jec t ive was t o i n s ~ e c t a l l f a c i l i t i e s , assess the standard o f sa fe ty performances, communicate management's commitment t o achieving the highest sa fe ty standards and t h e i r reac t ion t o the standards ac tua l l y being achieved, fo l low-UD on the r e s u l t s o f the inspect ion and the conclusions drawn and, f i n a l l y , t o ass i s t i n r a i s i n g the safety standards i n l i n e w i t h the p o l i c y o f "Achieving Excellence" .
The 1986 aud i t o f the o f fshore f a c i l i t i e s took place i n December 1986 and consisted o f a group o f managers car ry ing out a de ta i l ed inspect ion o f the f a c i l i t i e s i n the company o f the Offshore I n s t a l l a t i o n s Manager and the Senior Maintenance Supervisor. Probably inev i tab ly , the inspect ion degenerated i n t o a housekeeping inspect ion and the r e s u l t s were very negative. With the s ize o f the group and the l ack o f time, very few top ics could be discussed i n depth and on ly a very supe r f i c i a l impression o f most aspects o f the p la t fo rm operations could be gleaned. Management ended up w i th knowledge o f some o f the f a i l u r e s o f the f a c i l i t y personnel and v i r t u a l l y no knowledge o f t h e i r successes and the good th ings t h a t were being achieved. The f a c i l i t y supervisors equal ly f e l t t h a t the aud i t was u n f a i r as they received no recogni t ion, merely blame.
The Safety Department there fore recommended t h a t the sty1 e o f aud i t be changed. It was recommended t h a t the primary ob jec t ive o f the aud i t should be t o develop a va l i d assessment o f the safety condi t ions t h a t e x i s t a t the t ime o f the aud i t fo r the
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benefit of both onshore and offshore management. The audit should identify the strengths of the current safety programme just as clearly as the deficiencies. It should not only determine what is not being done, but should recognise and give credit to the programmes which are good and effective.
5.2. l987 Audit
The recommended method of achieving an effective audit was by looking at the safety programmes in depth. Is there a formal or informal policy and programme? What does it cover and specify? Does it meet Company standards? Is being applied in practice? Is it effective? Are the standards satisfactory for our specific operations? Are they too high or too low? Are the results recorded? Are the deficiencies found corrected in an acceptable time scale? Finally, what recommendations, if any, should be considered to improve the current situation?
Thus, the investigator needs an in depth review of written p01 icies and procedures, discussion on their appl ication and effectiveness with supervisors and the personnel applying them and, finally, monitoring of the actual appl ication and standard being achieved.
Obviously in the time available it would not be possible to cover every safety policy and programme. It was therefore recommended that a number be selected and allocated to specific team members. In addition, all team members were asked to record any unsafe acts or conditions observed during their inspections, note and comment on the housekeeping standards, training programmes, standards and records and, finally, the overall safety management of the p1 atform.
Prior to the audit taking place, an audit procedure was devel oped and approved by the Operations Manager, Production Manager and Drill ing Manager. In addition, specific safety programmes were a1 located to specific team members (See Tab1 e 1).
An opening conference was held on each platform at which the Safety Manager described the technique and a discussion was held on the detailed organisation with all the platform personnel involved. Each group then set to work and audited the programmes a1 located in conjunction with the relevant p1 atform personnel. The groups toured selected parts of the platforms appropriate to the programmes being audited. At the end of the audit one member of each group reported on a programme at a closing conference. They described the appropriate programme, its effectiveness and any recommendations for improvement. Each group then produced a written report which was forwarded to the Safety Department who produced an overall summary for each platform.
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The new audit procedure was felt by both offshore and onshore to be a major improvement on the previous technique. Onshore management were able to carry out an in depth examination of a number of safety systems and programmes and to gain an impression of the overall status of the safety climate. Offshore management were satisfied that their attributes were recognised as well as any deficiencies and be1 ieve that the audit was useful and equitable. It was judged by a1 l concerned to be a success.
5.3. 1988 Audit
The technique developed for the 1987 Safety Audit was utilised and as before the audit team was divided into groups of two and allocated specific topics as shown in Table 2. Guide1 ines were generated for each topic and distributed along with a general introduction to the audit technique.
During the opening conference on each platform the OIM reviewed the 1987 audit recommendations and discussed the implementation of the major items. In addition he introduced the platform staff who would be assisting the audit team and arrangements were made for the various teams to discuss the appropriate programmes and tour re1 evant parts of the p1 atform.
In 1988 in addition to the Division Senior Management, representatives from Headquarters, Exploration and Production and Corporate Occupational Safety and Health took part in the audit. Just prior to the audit the idea of inter-company audits was discussed at a very senior level in a number of companies. This was agreed and representation from two majors joined the team as observers.
Another innovation this year was the use of a physical conditions inspection record sheet. This was based on the International Loss Control Institute check1 ist. The concept i S to mark each specific observation of a wide range of physical conditions, each time the standard is shown as satisfactory or substandard. A comparison of the number of substandard to total observations gives a quantitative assessment of the standard of compl i ance.
As in 1987 the audit was felt -by everyone concerned to be of great value. The platform personnel received credit for the positive efforts that they are making to achieve a safe operation along with guidance from Senior Management on possible improvements. Onshore Management were able to make an in depth assessment of the effectiveness of the programmes in place in a positive way rather than using the accident figures which are negative and merely measure the failures. The addition of the representatives proved very benef i ci a1 . The operations were
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looked a t by t o t a l l y f resh minds and assessed based on corporate standards and programmes. I n the opposite d i r e c t i o n the corporate representat ives were able t o gain experience o f a d i f f e r e n t technique o f aud i t ing and know1 edge about l arge North Sea i ns ta l l a t i ons .
The physical condi t ions inspect ion work sheet proved t o have f a r too many items t o be able t o be used e f f e c t i v e l y by the team members. The concept o f inter-company aud i ts was shown t o have potent i a1 .
5.4. 1990 Audi t
I n 1989 a major re-organisat ion o f the company production operations was implemented and i t was not possible t o organise an aud i t i n 1989 due t o other p r i o r i t i e s , however, an aud i t was organised i n March 1990. This fol lowed the format used i n 1988 except t h a t each group was a l located two aspects o f housekeeping t o look a t dur ing t h e i r physical inspect ions ra the r than the whole range o f condi t ions. I n add i t ion the concept o f i n t e r company aud i t was continued and a Dept o f Energy inspector a lso jo ined the team. The top i c a l locat ions are l i s t e d i n Table 3.
POSSIBLE DEVELOPMENTS
I f u l l y expect t o see the Technical Audi t introduced i n some form as p a r t o f the Formal Safety Assessment l e g i s l a t i o n l i k e l y t o be recommended by Lord Cul len i n h i s repo r t on the Piper d isas ter . This w i l l lead t o development o f the top ics covered and formal i sat ion o f the procedure.
I bel ieve the i nd i v i dua l programme aud i t i s a very useful technique t o ensure t h a t standards are being maintained. It helps t o i d e n t i f y problem areas w h i l s t spreading the workload and i nvo l v i ng personnel i n the safety e f f o r t and enhancing t h e i r commitment. I personal ly would l i k e t o see a s i g n i f i c a n t expansion o f t h i s programme, however, i t does take a l o t o f e f f o r t t o develop the necessary check l i s t s and t r a i n personnel.
The Management Safety Audi t technique should be f u r t h e r ref ined. I would l i k e t o see a wider team membership probably t o include Safety Representatives. I n t e r company aud i ts w i l l almost c e r t a i n l y increase and I see s i g n i f i c a n t benef i ts i n j o i n t audi ts w i t h the Dept o f Energy.
' F i na l l y , I suggest t h a t companies consider the advantages o f c reat ing a new job, the "Compliance Coordinatorn. Par t o f t h i s persons j ob w i l l be t o monitor compliance w i th l e g i s l a t i v e , Indust ry and Company requirements and standards. Obviously t h i s w i l l invo lve ensuring t h a t aud i ts are e f f ec t i ve , i d e n t i f y i n g areas where new audi ts would be useful , car ry ing out audi ts himsel f where appropr iate and repo r t i ng h i S f ind ings t o senior management.
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Table 1
1987 Manaaement Safetv Audi t
TEAM MEMBERSHIP TABLE
CATEGORIES
General
Management
Tra in ing
Housekeepi ng
Svstems Safetv Proarammes
Chemical Management Programme
Contractor Safety Programme
Emergency Shutdown System
F i r e Protect ion Programme
Hand Tool Inspect i on Programme
L i ft i ng Equipment Safety Programme
Personnel I n j u r y Prevention Programme
Pol l u t i on Control Programme
Se l f Audi t Programme
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Table 2
1988 Manaaement Safety A u m
Observers : BP She1 l
Cranes j Gas Cyl i nders I ,
1 Work Permits I
l Modif icat ion Safety Reviews i Emergency Procedures I
L
A1 arm Systems 4
I
1
Y I
1
/ l
TABLE 3
1990 MANAGEMENT SAFETY W I T
OBSERVER - DEPARTMENT OF ENERGY INSPECTOR - CHEVRON
