Safety Case and Beyond
Published: 01st Jan 2012
Providing appropriate, effective safety systems is clearly important in maintaining and improving the safety performance of a large scale industrial asset or organisation, but perhaps equally important is creating and encouraging a positive safety culture throughout the organisation.
Research has shown that the key influence on an organisation’s safety culture is management attitudes and behaviours towards safety, and their willingness to lead by example, communicate clearly on risk and safety issues and involve personnel in the process of improving safety performance. Here, we use the offshore oil and gas industry as an example to demonstrate both how regulatory developments can drive improvements and how operators can build on those developments to encourage workforce involvement and thus further improve safety performance.
There can be few working environments in the world that present hazards on the scale of those encountered on an offshore oil and gas installation. Releases or blowouts of oil, gas or other hazardous substances are serious enough in themselves, but when placed in the context of an isolated installation with limited means of escape and evacuation, their consequences can be catastrophic. Safety awareness has grown over the past few decades in society and industry, in many cases as a reaction to well publicised catastrophes.
This has resulted in a range of more stringent regulatory and statutory requirements, intended to ensure that responsibilities are properly assigned and appropriately discharged. One of the major trends evident in the development of updated regulations is a move towards increased assessment and quantification of risks.
Risk assessment was first used in the offshore industry in the Norwegian sector of the North Sea. In the UK, many developments in quantified risk assessment (QRA) occurred in the onshore industries during the 1980s. Many UK operators used QRA methods as an integral part of the design process but, initially, QRA tended to be applied to specific aspects of the detailed design, when the scope for changes was limited, rather than to overall risks. In 1988, the Piper Alpha disaster provided tragic confirmation that the major accidents that risk analyses consider are indeed realistic. A public inquiry, headed by Lord Cullen, investigated the causes of the accident and made recommendations for change, in an attempt to ensure that such an incident would not occur in future.
The inquiry looked at the existing safety regimes in the UK and Norwegian offshore sectors and in the UK onshore industry, the role of QRA and the use of QRA to satisfy regulatory requirements in the nuclear industry. It considered that QRA could be of use in the offshore industry, in identifying risks so that measures could be put in place to reduce them. One of the key recommendations arising from the inquiry, presented in the Cullen Report, was that an offshore operator should be required to prepare and submit a Safety Case for each of its installations.
A Safety Case is defined in UK regulations as a document that contains specific information relating to the management of health and safety and the control of major accident hazards. The purpose is to demonstrate that an offshore installation is managed safely and that the potential risk to the health and safety of personnel that work on it has been reduced to a level that is tolerable and as low as reasonably practicable.
Safety Cases, which are now also required in many other regulatory regimes worldwide, as well as having an onshore equivalent in the COMAH (Control of Major Accident Hazards) Report, typically comprise:
• A description of the facility and associated operations
• A description of the Safety Management System (SMS) in place
• A description of the hazard management process and assessment of major hazards
The key to ensuring safe operations, however, is not only to undertake appropriate safety reviews and risk assessments but, equally importantly, to ensure that the results of these studies are communicated in a way that can be readily understood by all personnel. Ongoing advances in technology mean that this is now more easily achievable than ever, by producing and linking documents in a dynamic electronic format that will considerably enhance their utility.
Problems with traditional paper Safety Cases
Safety Cases are often produced for the purpose of regulatory approval, rather than for use by the workforce. In general, Safety Cases are prepared onshore by onshore-based personnel, which restricts the level of involvement from offshore personnel and often results in lack of interest in and understanding of the Safety Case, and even mistrust of the hazard assessment process. These problems are compounded by the size and often technical complexity of the document.
Workforce personnel often find it difficult to relate the platform descriptions and outline descriptions of process operations to their operational experiences. Similarly, the description of the SMS is often too high level for workforce personnel to understand how it relates to them. In addition, Safety Cases use QRA techniques to determine the risks to personnel. This can be a difficult process to understand and the results are often expressed in terms that are meaningless to the workforce. This can result in suspicion of the hazard management process, and of the Safety Case in general. This lack of understanding can result in the Safety Case not being used effectively to support decision making.
This is compounded by the fact that a Safety Case is usually a very large document, with numerous supporting studies. Important information (such as the reason and justification for major safety decisions) is embedded in this huge document and, due to its size, it can be difficult to find, extract and communicate this information. Indeed, much information is contained in the supporting safety studies and, even if an effective document management system is in place, it can be a very laborious and time consuming process to trace required information.
This lack of transparency also reduces the efficiency and effectiveness of audits on the Safety Case and SMSs. For this reason, Safety Cases are documents often left ‘on the shelf’ and only taken ‘off the shelf’ for periodic revision. The revision of a Safety Case is a huge task and is generally only undertaken in order to satisfy regulatory requirements. UK regulations require Safety Cases to be reviewed and updated where necessary every five years, or because of any change to platform processes or operations that would render the Safety Case materially different. Minor changes to platform processes or operations that occur between Safety Case reviews are not necessarily accounted for in the Safety Case QRA until the next update is required.
Therefore, often the Safety Case does not accurately reflect the current status of operations and does not always present the ideal basis to support decision making. All these problems result in underuse of information that has required significant effort to prepare. Many of them can be overcome, however, by presenting relevant information in a format that is more easily accessible and transparent in order to maximise the utility of the information.
Communication of QRA data
QRA is an important technique for use in identifying major accident hazards, assessing and understanding the risks associated with those hazards and demonstrating that the risks have been reduced to a level that is as low as can practicably be achieved. It has typically been seen as a ‘black box’ technique, however, little understood by many and in particular those working on the assets in question who are exposed to the risks.
This is clearly not ideal, and is becoming less and less acceptable as regulators increase their drive to ensure not only that operators fully understand and ‘own’ their risks, but also that they communicate clearly with all members of the workforce. Therefore efforts need to be made to improve the communication of QRA data, which will also go a long way to improving understanding. QRA is a structured means of identifying potential hazards to plant and personnel and assessing the likelihood of their occurrence and the subsequent consequences.
The results are typically presented as event trees, which allow a range of accident scenarios to be defined following an initial event, so that subsequent conditions and events can be considered and their impact on the consequences accounted for in the assessment. Historically, event trees have often been stored in spreadsheets, which can make them extremely difficult to read, modify and audit. Tools are available, however, that allow event trees to be constructed and populated more efficiently, and that present the information in an accessible easy-to-view format, so that it can be easily modified and interrogated and therefore used in day to day decision making.
The logical, transparent structure of such tools make them an ideal basis for communicating with people who have not been involved in the risk assessment, but who require detailed knowledge of the process and the implications of the results. For example, management and regulators. The utility can also be improved by storing explanations alongside data values, to summarise the provenance of the data used and provide references to source documents where appropriate. A record of changes made can also be built up, which is of assistance in justifying proposed or actual modifications, whether due to physical alterations or improvements in modelling of events.
Finally, by allowing easy editing and including basic decision making facilities such as sensitivity analysis, the user is provided with the tools to investigate the effect on overall risk levels of possible safety upgrades. This enables safety and loss prevention staff to filter out, at an early stage, modifications that are likely to produce little benefit.
Benefits of improved presentation
As we have discussed, there is a lot of valuable information in a Safety Case, which could and should be used on an ongoing basis to support both day to day operations and projects and to inform operational and safety related decision making, but which is currently often obscured and difficult to access. Presenting this information in a more intuitive format that is easier to access and to understand, interpret and apply has obvious operational and economic benefits, and allows an operator to extract significant additional value from work that has to be undertaken to fulfil regulatory requirements.
Key elements of a Safety Case that would benefit from more graphical interpretation and presentation, improving communication and understanding, include:
• Provision of an asset’s QRA in a user-friendly event tree-based format that allows easy reference to information on the provenance of all key input data, facilitates efficient ongoing use of data and provides improved communication of QRA data to management, workforce and regulatory bodies
• Graphical representation of platform layout schematics showing the key inputs to and outputs from an asset’s QRA, including leak frequencies, manning levels and heat radiation contours
• Graphical ‘bow-tie’ representation to communicate effectively the potential causes and impact of hazards, and potential safeguards and recovery measures in place to mitigate against them
• Provision of an ‘interactive’ emergency response planning tool designed to be used as a ‘prompt’ in an emergency and for training purposes
Presenting information in a less daunting format than that of a traditional paper Safety Case promotes understanding of safety issues amongst the workforce and thus encourages more involvement of offshore personnel in the Safety Case process, ‘bridging’ the gap between the views of onshore and offshore personnel on safety. The benefits of adopting a more graphical approach to the presentation and communication of Safety Case data are many and varied, as it:
• Provides access to information in a logical, efficient and intuitive way
• Presents information in a format and to a level that enables it to be understood by all personnel
• Provides high quality, up-to-date information on facilities for use in discussions with colleagues and external bodies
• Can be easily updated and maintained
• Can be easily translated into two or more languages, since the focus is on graphical representation rather than large quantities of text
• Provides an easily and widely accessible ‘one stop shop’ for HSE data
• Provides detailed QRA data for each area of a facility in a user-friendly format that will facilitate cost effective use of the data in ongoing decision making, as well as resulting in significant efficiencies and cost savings whenever updating of a QRA or Safety Case is required
• Improves communication of QRA data and safety issues to promote understanding and facilitate justification of the assumptions and analyses to management, workforce and subcontractors
• Serves as a through-life record of QRA data, which is useful for auditing purposes
• Provides an easy to use reference tool for reviewing information on major hazards when planning work on plant
• Improves access to and application of information relating to all aspects of safety and safety management for operations staff
• Forms an ideal basis for a user-friendly training tool, for existing staff and new recruits
• Provides a basis for simpler, more efficient compliance and audit assessment
Safety Cases were introduced into offshore regulations in response to high profile incidents such as Piper Alpha, to encourage operators to fully understand and ‘own’ their risks. The impact on the industry was positive, with a noticeable increase in safety awareness and safety performance.
Almost 20 years since Safety Case regulations were introduced in the UK, however, there is still more that can be done to build on progress to date and further improve workforce involvement and safety performance. There is no doubt, for example, that Safety Cases contain valuable information that is currently under utilised due to the format and presentation. The challenge, therefore, is to present that information in an easily accessible format that will engage a wide range of personnel, improving communication and understanding of important risk and safety issues.
Only then will the true benefits of work that is already undertaken be seen, in terms of improvements in safety culture and, subsequently, safety performance.
Published: 01st Jan 2012 in Health and Safety International