OGP publish report on the use of ‘life-saving rules’

March 29, 2012

The International Association of Oil and Gas Producers (OGP) has published a report advocating the use of ‘life-saving rules’ in its member companies.

18 life-saving rules are defined, consisting of 8 ‘core’ rules, and 10 ‘supplemental’ rules.  Some of the rules include:

  • obtain authorisation before entering a confined space;
  • protect yourself against a fall when working from heights;
  • do not walk under a suspended load;
  • wear your seat belt;
  • do not use a phone whilst driving and do not exceed speed limits;
  • work with a valid work permit when required, and
  • verify electrical isolation before beginning work.

The core rules should be applicable to most high hazard industries, with the supplemental rules being suitable for selected industries.

OGP recommends that the life-saving rules be implemented and supported by appropriate disciplinary action for non-compliance.  The report contains a case study on the use of life-saving rules in Shell, where individuals can face disciplinary action up to and including dismissal for non-compliance.  If a rule is broken (even if it didn’t result in incident) Shell first undertakes an investigation to determine why the rule was broken, and then takes appropriate disciplinary action – this may also include investigating supervisors and managers if they were complicit in the rule-break.  Shell is of the view that it is better to take disciplinary action than to risk lives.

The OGP life-saving rules were developed by examining OGP incident data between 1991 and 2010, with the aim that the core rules should cover the direct causes of at least 40% of fatal incidents, and be in line with life-saving rules already developed by OGP member companies.  Together, the core and supplemental rules account for 70% of fatal incidents and 48% of high potential events.

Organisations won’t be expected to implement all 18 rules.  To select the appropriate rules to use, OGP recommends that each organisation undertakes a risk assessment to match the rules up with their own incident data and the type of work they undertake.

Each rule is represented by a symbol based on the ANSI and EU safety icon format. Effort was made to make these as internationally recognisable as possible.

Firm but fair?

Is the use of life-saving rules contentious?  In some cases a single discretion can lead to dismissal, and so opponents have argued that they are too harsh and will lead to a culture of suspicion and blame in the workplace.  Some may also see their use as an alternative to developing safety culture and personal responsibility.

These misgivings may not be justified.

At 2011’s Tripod User Day (September 2011, Amsterdam) Prof. Jop Groeneweg of the University of Leiden gave a talk on the use of life-saving rules in Shell and stressed that they are only worth implementing if they are proven to save lives, otherwise the workforce will not accept them.

The successful use of the life-saving rules relies on non-compliances being reported, which means the rules need to be fully supported and believed in by the workforce.  Consistent enforcement of the life-saving rules may also send the message that the organisation applies consistent standards for safety, and provides the potential to empower front-line workers when taking decisions to stop work on safety grounds.

The OGP life-saving rules themselves focus on preventing only a selection of specific behaviours that are proven to be immediate causes to the majority of fatalities, and should therefore help to standardise the use of life-saving rules across industry.

Implementation

The real issues around the use of life-saving rules are likely to lie in their (mis)application.

In organisations where non-compliances and unsafe working practices are commonplace, or where there is little trust between workers and management, it is questionable whether life-saving rules will be enforceable.  Do organisations therefore require a fairly high safety culture to be already in place before life-saving rules can be implemented?  Implementation of the rules may also depend on the rules themselves being workable – i.e. in there being systems in place to ensure the rules can physically be complied with.

It is important to remember that the life-saving rules mainly relate to fatalities through personal injury (rather than process safety incidents), focus only on strengthening the last line of defence (the worker), and only on a selection of unsafe behaviours.  They are just one part of a larger safety management system, to prevent the failure of a key barrier in what may be a chain of events leading up to an unsafe act, and one means of communicating with the workforce a commitment to safe standards of working.


Changing regulatory oversight of safety management in the US offshore sector

March 22, 2012

The Transportation Research Board (TRB) has released the interim report of the Committee on the Effectiveness of Safety and Environmental Management Systems for Outer Continental Shelf Oil and Gas Operations, which is freely downloadable.

The report explores methods for the US regulators to investigate/audit the implementation and effectiveness of safety and environmental management systems (SEMS) among offshore operators, who should be tasked with investigating/auditing, and the competencies investigators may be expected to have.

The final report is expected to be released after the release of the National Academy of Engineering (NAE) and National Research Council (NRC) report into the likely causes of the Deepwater Horizon incident of 2010.

SEMS

Stemming from the 2010 mandating of API RP 75 by the US Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE), companies operating on the US outer continental shelf are required to have SEMS in place by the end of 2012.  SEMS should work to mitigate human factors root causes in personal safety, major accident hazards (MAHs) and environmental damage.

SEMS will be required to be audited by independent third parties (I3Ps).

In context

The report states that SEMS should operate within four wider organisational processes for managing HSE:

  1. a mechanism for managing HSE (i.e. the SEMS plan);
  2. individual competency;
  3. a strong safety culture, and
  4. personal motivation to behave in the correct way (rewards and consequences).

The implication is that the successful implementation of SEMS cannot simply focus on the SEMS plan itself, but on its use and effectiveness within these wider processes.   This should also be the focus of the auditing and investigation of SEMS.

Investigation methods

The report explores nine possible investigation methods and their advantages and disadvantages, including detailed audits, compliance inspection, peer review-assists, whistle-blower programmes, the use of key performance indicators (KPIs) and mechanical metrics (e.g. from sensors), etc.

Some methods, such as the use of mechanical sensors or KPIs, may be difficult in practice as it is currently unclear which metrics can be used as indicators of an effective SEMS.  Others, such as compliance inspection, may fail to encourage operators to take full ownership and interest in the implementation of SEMS, especially as regulation moves away from prescription-based to risk management-based.

The concern over ownership may also influence who is best to carry out SEMS inspections.  The report states the case for self-inspection, I3P-inspection, regulator inspection, and joint operator/regulator inspection, noting that independent inspections may discourage operators to take full ownership of SEMS, instead delegating the responsibility of performance monitoring on I3Ps.

Competence

The competencies required of SEMS investigators are likely to be broad.  SEMS ruling includes both prescriptive regulations and performance standards, and so SEMS investigation will not only require the reporting of violations of regulations but also identifying weaknesses in the system and opportunities for improvement.

Investigators will also need to be able to focus on both personal safety and process safety, and it is likely that a team of investigators with a number of competencies will be required to complete an audit/investigation.

Lastly investigators will need training and certification.

Commentary

This report represents the initial findings of the committee, but gives an indication of how the US offshore sector may be regulated in the next few years.

Whilst the committee has reviewed various inspection methods in light of how well they encourage operators to take ownership of the process, it is perhaps worth noting that not all inspection methods explored in the report will be suitable for all organisations, as the effectiveness of methods may depend on the safety culture of the organisation.

The 2010 OGP publication A guide to selecting appropriate tools to improve HSE culture provides some guidance on the types of HSE tools that are appropriate for different cultural levels.  It suggests that some methods may not be practical within more reactive cultures, whilst other methods may not allow organisations with more advanced cultures to take full ownership of the investigation process.  For example, peer assists are only really appropriate for ‘proactive’ and ‘generative’ cultures (the two highest cultures on the safety culture ladder).

If the culture of the US offshore sector is to adapt from a prescriptive regulatory framework to a broader approach to risk management using a variety of methods, do operators therefore need to consider their own safety cultures when selecting appropriate investigation methods?  Are a variety of methodologies needed?  Could there be a danger if the methodologies advocated are too narrowly defined?