By Chris Hamlet, Operations and Improvement Manager, ADIL Thirty years ago, Chris Hamlet learned that self-regulation was an important part of working in the oil and gas industry. Today, the operations and improvement manager with independent energy consultancy ADIL (Asset Development and Improvement Ltd.), questions whether we have retained all the lessons we should have learned from past incidents. For the first time in its history, the U.K. oil and gas industry has voluntarily released information to the public about hydrocarbon leaks on North Sea facilities. This is a major change for an industry that, until now, has not detailed the performance of individual operators. Furthermore, through the cross-industry Step Change in Safety Initiative, the U.K. has set a self-imposed goal of cutting the 2010 level of hydrocarbon releases by 50% by 2013. This demonstrates the commitment of operators and suppliers to share best practices, ideas and techniques, and ultimately to learn from one another. The “best” operators in terms of minimizing hydrocarbon releases are currently experiencing an average of less than one significant release a year. The industry average, however, is about five or six per year. As each significant or major release has the potential to lead to a catastrophic event, even one a year is one too many. Public inquiries from past major incidents such as the Piper Alpha disaster have led to a number of changes in both regulation and operating practices. As a result, the North Sea offshore environment has undoubtedly become a safer place to work. However, many of the practices that contributed to these incidents still appear in the offshore workplace today. Why does our industry find it hard permanently to learn the lessons of the past? A cursory glance at the rate of major industrial incidents would indicate that every three or four years, there is one that causes multiple loss of life and other harm. Since Piper Alpha (1988), oil and gas incidents have included Longford Gas Plant (1998), Petrobras P36 (2001), Mumbai High (2005), Texas City (2005), Montara (2009) and Deepwater Horizon (2010), among others. This would suggest that more needs to be done to keep the lessons of the past alive. The fact that these more recent incidents did not take place in the North Sea provides no guarantee they could not happen in the future. A common factor identified as a cause of these incidents was a steady reduction in safety levels, coupled with normalized deviation from good practice and procedures. Just because a hydrocarbon release does not ignite, it does not mean that it is safe. All it means is that its disaster potential has not been fully realized. Many of the changes resulting from the public enquiries following major incidents have addressed both the consequence and likelihood of hydrocarbon leaks. While these factors have been addressed through increased governance and regulator scrutiny, the full benefits in terms of improved safety are not commensurate. Why? There is an increasing awareness that, across the oil and gas industry, many procedures that have been put in place to prevent hydrocarbon leaks are not being followed consistently. Examples of these procedures include: the checking of isolations; the recognition of high and low pressure (HP/LP) interfaces; and the adherence to basic processes used to ensure pressure containment. At times, isolation schemes are designed by supervisors with no one able to check them. This reduces the time supervisors have to monitor and maintain standards with the result being that basic steps are missed and vital checks bypassed. The potential consequences to both people and the industry as a whole are huge. When I first went offshore 30 years ago, the role of the supervisor was to train, check and, where necessary, hold people to account. It took many weeks of supervision before I was allowed to work alone. I was expected to learn from any mistakes I made. Supervisors were appointed on their ability to coach and supervise, not just on length of service and technical skills. Anyone who was not prepared to, or could not maintain an appropriate standard of working practice, was re-assigned to a role with less consequence. Many studies have been carried out on the impact of regulation. The Peltzman effect, for example, suggests that people tend to react to a safety regulation by increasing other risky aspects of their behavior. This has the result of offsetting some or all of the benefits of the regulation. Increased regulation alone cannot realistically create a safe place to work if we then let slip the good practices that kept us safe before these new parameters came along. We cannot substitute good practice with processes and rules. Good practice must be maintained with regulation and procedures reinforcing it. We also have to ask ourselves why good practice diminishes. There is a range of possible answers. Many of the younger crews on facilities were not born or were infants when Piper Alpha happened. That tragedy is resigned to a part of history, rather than something that could happen today. Today's Hollywood and the current rash of computer games would have us believe that humans have the ability to get up, brush themselves off and still function after a large explosion, car crash or fall from a 500-ft building. Have we become desensitized to the potential consequences of an incident? Few of us intuitively understand risk. When we take an action and nothing bad happens, we tend to think of it as “safe.” For low frequency events, this can lead to a consistent decline in operating standards. Whatever the causes of this decline, we have to be sure that those in charge are asking the right questions today. Risk mitigation cannot be achieved through onshore training alone. It requires leaders that have confidence in the skills and standards of their workforce and the quality of their procedures. Furthermore, they have to be sure that people are following the processes put in place to mitigate risk. If they are confident that things are being done right, they should also make sure that this confidence is justified. Do they seek an external perspective, or are they satisfied instead with a “Don’t Ask, Don’t Tell” policy? The whole industry needs to take responsibility for its actions. Legislation and regulation is one part of the solution but they need to be supported by the appropriate skills, understanding and quality of work from those involved in operations to ensure people are as safe as possible. Only then, can we be certain that we have truly minimized risk. Chris Hamlet discussed the “Role of Supervision” at the Oil & Gas U.K. Hydrocarbon Release Seminar on March 15 at the Aberdeen Exhibition and Conference Centre, Aberdeen, Scotland, U.K.