US National Academy of Sciences Performance and Management Based Safety Regulatory Regimes in the North Sea Offshore Oil&Gas Sector

Transcription

1 Meeting with US National Academy of Sciences Performance and Management Based Safety Regulatory Regimes in the North Sea Offshore Oil&Gas Sector The Hague, 5 January 2017

2 79 Members around the world representing 1/3 of world oil and gas production North America Anadarko API Baker Hughes CAPP Chevron CNR International ConocoPhillips Devon Energy ExxonMobil Hess Corporation Husky Energy IADC IAGC Kosmos Energy Marathon Oil Noble Energy Pemex Schluberger Suncor Talisman Energy Europe Afren plc ASSOMMINERARIA BG Group BP Cairn Energy DONG Energy E.ON Ruhrgas AS Energy Institute 44 members active in region Eni Fairfield Energy GALP Energia Genie IECO IOOA IPIECA Maersk Oil MOL plc Repsol NOGEPA RWE Dea AG Norwegian Oil & Gas Shell Oil Gas Denmark Statoil Oil & Gas UK Total OMV Tullow Oil Perenco Holdings WEG Premier Oil Wintershall 35 members active in region Russia & Caspian region Africa JSOC Bashneft NCOC 21 members active in region South America ARPEL IBP Pan American Petrobras PLUSPETROL 31 members active in region Sasol Sonangol 41 members active in region Middle East ADNOC CC Energy Development Dolphin Energy Dragon Oil 34 members active in region Kuwait Oil Qatar Petroleum RasGas Yemen LNG Asia & Australia APPEA BHPBilliton Cairn India CNOOC INPEX Origin Energy Papuan Oil Search Petronas PTTEP Woodside 32 members active in region 2

3 Who we are IOGP s Members produce over a third of world oil and gas. IOGP works on behalf of the world s oil and gas companies and organizations to promote safety, efficiency and reliability of oil and gas exploration and production operations The Association defends industry Licence to Operate

4 Members are the heart and soul of IOGP s work Management Committee Member-based committees strategise, decide, contribute The secretariat proposes, coordinates, executes 4

5 Guidelines for implementing Well Operations Crew Resource Management training Prepares training providers to deliver programmes that introduce and sustain well operations crew resource management (WOCRM). Sets learning objectives Includes guidance on training delivery, assessment and qualifications and knowledge of instructors and facilitators

6 Collection of Data series 4 major annual reports Process safety events: Tiers 1 & 2 Provides narratives of the process safety events and of process safety-related events where there are significant learnings Environment: 1.Gaseous emissions 2.Energy consumption 3.Flaring 4.Aqueous discharges 5.Non-aqueous drilling fluids retained on cuttings discharged to sea 6.Spills of oil and chemicals Health management: Self-assessment rated on a scale of 0-4 Occupational safety: Fatalities and fatal accident rate

7 International Regulators Forum (IRF) conference To collectively identify and oversee well control improvement initiatives (with IADC) To increase information sharing between the industry and regulators Focus on joint industry project (JIP) addressing blowout preventer (BOP) reliability and technology

8 Europe oil and gas industry The key challenge for operators, suppliers and regulators. Safety and Environment protection, but activity must be profitable. Today, the industry delivers around 55% of the EU energy mix. Will remain around 40% in 2040 Challenge: Maintaining competitiveness in Europe when production comes increasingly from other producing regions of the world Domestic production is key for security of supply and competitive energy markets 8

9 Europe oil and gas industry Basic : One-size-fits-all approach not adapted to our industry Introduction of OSPAR Background document on BAT for produced water: it cannot be concluded that a method, which has been operated successfully at one installation, may achieve the same results at another location (North Sea / Mediterranean / Onshore = different worlds) Industry clearly likes the Goal setting regime. It allows the flexibility to select the most appropriate solution Regulators (and industry) operate according to the key principle of ALARP Post Macondo discussions between EU Commission and Industry -- Offshore Safety Directive 9

10 Offshore Safety directive (1) When granting licenses, EU countries must ensure that companies are well financed and have the necessary technical expertise Before exploration or production begins, companies must prepare a Major Hazard Report for their offshore installation. This report must contain a risk assessment and an emergency response plan Companies must keep resources at hand in order to put them into operation when necessary Technical solutions which are critical for the safety of operators installations must be independently verified. This must be done prior to the installation going into operation 10

11 Offshore Safety directive (2) Competent National authorities must verify safety provisions, environmental protection measures, and the emergency preparedness of rigs and platforms. All incidents significant incidents must be reported If companies do not respect the minimum standards, EU countries can impose sanctions, including halting production Information on how companies and EU countries keep installations safe must be made available for citizens Companies will be fully liable for environmental damages caused to protected marine species and natural habitats. For damage to marine habitats, the geographical zone will cover all EU marine waters including exclusive economic zones and continental shelves. 11

12 OSD is not prescriptive, however industry has developed Standards and Guidance National legislative regime; EU level regulation; international treaties Standards developing organisations Laws regulation guidelines, notices international standards regional standards national standards Regulatory authorities, enforcing authorities i.e. ISO, IEC i.e. CEN (Europe) i.e. ANSI/API (US), DIN (Germany), NEN (NL) Trade associations industry standards best or recommended practices guidelines IOGP, IADC, IMCA, NOGEPA, NOROG, Oil & Gas UK, etc Companies group specifications company specifications (project specifications) multinationals independents/business units manufacturers/epc contractors Best or recommended practices: last survey referenced standards coming from 180 different organizations 12

13 Upstream oil & gas activities are already comprehensively regulated at EU level Safety 1. Offshore Safety Directive 2. Major-accident Hazards Directive (Seveso II) Workforce 3. Council Directive 89/391/EEC on the introduction of measures to encourage improvements in the safety and health of workers at work 4. Outdoor equipment Directive 5. Working Time Directive Security of Supply and energy market 6. Directive on the conditions for granting and using authorizations for the prospection, exploration and production of hydrocarbons 7. European Energy Security Strategy 8. Security of Gas Supply Regulation 9. Common rules for the internal market in natural gas 10. Wholesale energy market integrity and transparency (REMIT) Regulation 11. Markets in Financial Instruments Directive (MIFID) Environment 12. Environmental Impact Assessment (EIA) 13. Access to environmental information 14. Strategical Impact Assessment (SEA) 15. Environmental Liability Directive (ELD) 16. Habitats Directive 17. Bird Directive 18. Marine Planning Framework Directive 19. Maritime Spatial Planning 20. Biocidal products regulations Air Quality 21. Directive on the limitation of emissions of certain pollutants into the air from Large Combustion Plants (LCP) 22. Medium Combustion Plant Directive (MCP) 23. National Emissions Ceilings Directive (NEC) 24. Industrial Emissions Directive (IED) 25. Integrated Pollution Preventive and Control (IPCC) Climate 26. Directive 2009/30/EC on the specification of petrol, diesel and gas-oil and introducing a mechanism to monitor and reduce greenhouse gas emissions GHG emissions (FQD) 27. Directive 2015/652 on calculation methods (including UERs) 28. Regulation on a mechanism for monitoring and reporting greenhouse gas emissions and for reporting other information at national and Union level relevant to climate change 29. Directive on Geological storage of carbon dioxide (CCS) 30. Energy Efficiency Directive Ground, Chemicals and Products 31. Shale gas Recommendations 32. Substance Mixture and Packaging Directive 33. Mining Waste Directive 34. Waste Framework Directive 35. Water Framework Directive 36. Groundwater Directive 37. REACH 38. Biocidal Products 13

14 What is industry aiming for today? 1) We want to continue to develop globally accepted technical standards preferably no BATs - for the oil and gas industry that: are mutually applicable worldwide and developed through collaborative and transparent processes; enhances technical integrity, improves safety, reduces environment risk; creates a worldwide level playing field (enables supply or movement of equipment and materials across borders) 2) We want to develop competencies able to understand and manage risks with efficient processes 14

15 So what does it all mean in practice? Of course we have a procedure! Safety Case describes how we identify and manage risks Most companies do this via their SMS 15

16 Safety case in practice Safety case describes the hazard ID process and the risk management tools (HAZOP, HAZID, MAR, QRA, etc.) used to ID and rank risk For each installation, they then identify the SCE, processes and procedures that eliminate or manage these risks (the barriers in the bow ties) The barriers all have performance standards they have to conform to The SC then describes which activities maintain these barriers These activities are mapped to the various regulations so that we can demonstrate which activity manages which barrier or piece of prescriptive regulation and how the performance standards are maintained These activities therefore become the prescriptive regulation that the operator follows 16

17 Maintaining Safety Case Changes are managed through an MoC process that includes a system to check if the change will affect Safety Case All Safety Cases are reviewed at a high level every 2.5 years (or rather MoC s are reviewed as a further check) and in depth every 5 years 17

18 Safety Case in practice cont. The SC actually describes the company s SMS BP Asset UK Operational Safety Cases typically comprise three volumes as follows: Volume 1 Section 1 Executive Summary Volume 1 Section 2 Description of Health, Safety and Environmental Management System Volume 2 Installation Description Volume 3 Installation Hazard Management (including Justification for (Continuing) Operation) Description of Health, Safety and Environment Management System The North Sea Region (UK) Health, Safety and Environment Management System is the same for all Installations. Standardised text has been prepared for this section; refer to Addendum 3. 18

19 Safety Case in practice The HSE MS is, in BP speak, our OMS OMS Framework and the Integral Arrangements for Health and Safety Management The framework for OMS and the integral arrangements for health and safety management are built around the International Standards Organisation (ISO) principles. The framework comprises three key components which together provide a roadmap to safe and reliable operations: The elements of operating, which inform The Performance Improvement Cycle (PIC), which applies to The local business processes, which deliver the elements of operating 19

20 Safety Case in practice The Elements of Operating The elements of operating comprise eight areas, which are the basic elements that BP has identified need to be focused on at any point in time, to achieve safe and reliable operations. The eight elements are: Leadership Organisation Risk Procedures Assets Optimisation Privilege to Operate Results 20

21 Safety Case in practice The OMS is Global based on Exxon s OIMS management system - and applicable across the entire BP Group Going back to the third part of the OMS The local business processes, which deliver the elements of operating These may vary depending on the country of operation but always deliver the requirements of the 8 OMS elements of operating as well as whatever local regulation there may be These are described in the How we operate in.. In over 90% of cases the OMS exceeds the local regulations, the remaining 10% is generally documentation, reporting processes, frequencies etc. 21

22 Safety Case in practice Specifically in Angola any spill over 1bbl has to be reported to Sonangol (PSA partner) and MinPet within 7 days regardless of where it is spilled from and to (primary, secondary containment etc.) and any spill to sea reported within 6 hours regardless of size. In all Regions there is a process to manage and track these differences (CTM) There is no effective national emergency response (coastguard, medical etc.) so industry has its own mutual aid process (ACEPA) 22

23 Audit, Assurance and Self Verification BP operates a three lines of defence model Audit is Group Audit an independent audit body that reports directly to the BP Board (not the CEO!) Assurance is Safety and Operational Risk both deployed to the Regions and Central and report into the S&OR EVP both these bodies are 2 nd Parties Self Verification is the line checking itself that it is following its own procedures Third party auditors are also used (where required) but they never find as much as the 2 nd party! 23

24 Why we like Goal Based Example noise shall be below 83dB(A) or restrictions shall apply A member used smart ear defenders to determine that many areas which had previously been measured at more than 83 db(a) had many areas that were in fact below 83 db(a) and successfully changed their safety case to allow workers in these areas 24/7 if needed. BUT when risk changes, industry or technology changes, so does the barrier/performance standard/risk management process, so does the Safety Case MUCH quicker than regulations! 24

25 For more information please contact: Chris Hawkes Registered Office Level Blackfriars Rd London SE1 8NL United Kingdom T +44 (0) F +44 (0) reception@iogp.org Brussels Office Bd du Souverain,165 4th Floor B-1160 Brussels Belgium T +32 (0) F +32 (0)