Brazil s Regulatory Experience
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1 Brazil s Regulatory Experience Safety as Priority in the Offshore Industry THE NATIONAL AGENCY OF PETROLEUM, NATURAL GAS AND BIOFUELS Madri, June 13 th 2013
2 Superintendence of Operational Safety and Environment Benchmarking Superintendence of Management of Operational Safety Management System of Operational Safety Offshore (RANP 43/2007) Management System for Mechanical Integrity (RTSGI) - Onshore Production SGSO Audits At the adequation period Operational Safety and Environment Technical Regulation on Safety Management of onshore pipelines (RTDT) At the adequation period Assets Integrity Integrity of Marine Structures Integrity of Marine Equipment Brazilian Navy Inspections Agreement ANP / Brazilian Navy Incidents Incident Report and Incident Investigations
3 The ANP Approach Safety Framework - ANP Resolution Nº 43/2007 Focus on Safety Management Systems!!! Regulatory Framework for Offshore Safety Performance-Based/Goal Setting Model Fewer prescriptive requirements (Qualification for the Regulatory Body is essencial) Non-restrictive approach to technological innovations Minimum requirements for: Mechanical Integrity, Risk Assessment, Contractors Selection, Internal Audits, Incident Investigations, Management of Change, Safe Working Practices, Safety Critical Elements Management, Simultaneous Operations etc.
4 The ANP Approach Safety Framework - ANP Resolution Nº 43/2007 Management, Leadership and Personnel MP 1: Safety Culture and Managerial Commitment & Responsibility MP 2: Personnel Involvement MP 3: Personnel Qualification, Training and Performance MP 4: Work Environment and Human Factors MP 5: Contractors Management MP 6: Continuous Improvement and Performance Monitoring MP 7: Audits MP 8: Information and Documentation Management MP9: Incident Investigation Facilities and Technology MP 10: Design, Construction, Installation and Decommissioning MP 11: Critical Operational Safety Elements MP 12: Risk Identification and Analysis MP 13: Mechanical Integrity MP 14: Management of Major Emergencies Operational Practices MP 15: Operational Procedures MP 16: Management of Change (MoC) MP 17: Safe Working Practices and Control Procedures in Special Activities
5 ANP DUTIES Carry out the analysis of the Operational Safety Documentation beginning of operation is allowed if ANP approves it; Carry out audits at the installation to verify the performance of the Operational Safety Management System (Risk Assessment is essencial); Carry out inspection of critical elements for operational safety Practice 11; Put into effect injunction actions when found non-conformities Put into effect injunction actions when found non-conformities regarding the Technical Regulation.
6 Risk Assessment The only way to eliminate the hazard is abandoning the activity. As such a decision is not the appropriate solution for a company, especially in the oil and gas, we need to develop tools to evaluate the classification of risks, defining points until they are acceptable, and evaluate alternatives which can be used to reduce them, control them or mitigate the consequences of a possible accident.
7 EXAMPLE OF RISK ASSESSMENT LITTLE GIRL IN THE ZOO 2 DOORS (BARRIERS) AND SAFETY CORRIDOR COACH TRAINING OPERATIONAL PROCEDURES FENCE PROJECT MAINTENANCE / INSPECTION HOW TO PREDICT? RISK ASSESSMENT WHO IS RESPONSIBLE? THE OWNER RESCUERS AMBULANCE AND HEALTH PROFESSIONALS
8 MANAGEMENT PRACTICES AS BARRIERS OIL PROJETO PROJECT RESPONSIBLE: CONCESSIONAIRE SAFETY CRITICAL ELEMENTS MAINTENANCE TRAINING FAILURE IN THE MANAGEMENT SYSTEM SEA COAST MANAGEMENT OF CHANGE CONTRACTORS MANAGEMENT AUDITS INFORMATION MANAGEMENT INCIDENT INVESTIGATION MANAGEMENT OF MAJOR EMERGENCIES
9 The ANP Approach Safety Framework - ANP Resolution Nº 43/2007 Management, Leadership and Personnel MP 1: Safety Culture and Managerial Commitment & Responsibility MP 2: Personnel Involvement MP 3: Personnel Qualification, Training and Performance MP 4: Work Environment and Human Factors MP 5: Contractors Management MP 6: Continuous Improvement and Performance Monitoring MP 7: Audits MP 8: Information and Documentation Management MP9: Incident Investigation Facilities and Technology MP 10: Design, Construction, Installation and Decommissioning MP 11: Critical Operational Safety Elements MP 12: Risk Identification and Analysis MP 13: Mechanical Integrity MP 14: Management of Major Emergencies Operational Practices MP 15: Operational Procedures MP 16: Management of Change (MoC) MP 17: Safe Working Practices and Control Procedures in Special Activities
10 Cost x Safety Apparent reduction of efficiency and loss of income (costs of corrective maintenance, development of control tools, detection and protection equipment) continuity it of the business! Low frequency of occurrence of catastrophic accidents may complicate decision making resource allocation in operational safety and sub evaluate the impacts of major accident. The companies must include safety in their strategic objectives: policies and standards have to be aligned with the safe practices (operational safety management systems). Recent Accident: Frade Field (Brazil, 2011).
11 Health, Safety and Environment Regulation Brazil Maritime Authority SOLAS Brazilian Institute of Environment (IBAMA) MODU Code Further rules focused on marine systems (Communication, hull, ballast, navigation, general condition, evacuation etc) MARINE SAFETY (Maritime Authority) ENVIRONMENT PROTECTION (IBAMA) Environmental Licensing Spill response plans Rules focused on the interaction of facilities with the environment Labour Ministry Rules focused on the occupational safety and health risks PEOPLE SAFETY (Labor Ministry) PROCESS SAFETY (ANP) Petroleum Agency (ANP) Rules focused on the process plant safety Subsea / Well Control
12 ANP - Process Safety Main issues 1) Very strict onboard auditing process 2) Regulator qualification improvement audits on the last ( ); non-conformity reports; - US$ 122 million in fines - 14 cautionary measures (operation halt) Direct application knowledge; and - Use audits to identify gaps & needs; - Trainings: drilling, workover, well control (IWCF and IADC), Well Design, offshore, inspection, lead auditor, corrosion, HAZID/HAZOP, etc. - Direct application knowledge; and - Benchmarking. 3) Regulatory framework revision - Safety barriers, well control, cementing; - Improve performance indicators; - Operators competency; - Enhanced operations monitoring; and - Encourage research and development. 4) Enhanced communication - With environmental and health regulator; - With industry (workshops); - With society (website, workers unions); - Among regulators (IRF).
13 The ANP Response What is working well - Focus on Process Safety (major hazards) other regulators are responsible for occupational safety, health risks and environmental issues (including oil spill response and containment); - Non-conformity reports system (obligation to do) is a powerful tool to enforce continuous improvement; - Onboard presence is necessary to feel safety climate and culture; and - Precautionary measures (operation halt) when risks are high
14 Final Consideration Perform the audits to guarantee the proper functioning of the plant process operating systems reducing the risks of harm to humans and the environment. Industry development and lessons learned guided the regulation to the operational management systems (Brazilian model). The Superintendence of Operational Safety and Environment, in behalf of ANP, plays a key role in raising, research, orientation and communication of lessons learned in the case of incidents that occur in the oil and gas industry. Incessant search for the best performance of operational safety indicators and challenge for the industry.
15 Regulatory Framework for Operational Safety (SGSO) Concessionaire is responsible for continuously assessing their activities and make decisions to keep the level of risk in its operations as low as possible. Increasing the decision-making freedom of the operator does not mean letting it act without any control. Regulators qualification and career (resources); Improve risk acceptance criteria (more engineering g tools opposed to assumptions and experience ). The oil project is allowed as long as ANP considers its risks acceptable!
16 National Petroleum Agency Gracias! Raphael Henriques Queiroz Technical Advisor Superintendency of Operational Safety and Environment
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