Test yourself on the COMOPS Quiz!

First let’s start by clarifying our terms. The definition of Combined Operations (COMOPS) is when at least two installations with distinct and approved safety cases enter a joint operation. Before that operation can begin a COMOPS Notification or CON must be submitted to the Offshore Safety Directives Regulator (OSDR) at least 21 days in advance. The CON doesn’t need to be accepted by the OSDR (hope you’re keeping up!), but they can – and they often do – raise concerns.

Figuring out whether any individual operation even qualifies as a COMOPS is not always as straightforward as you might think.

So, when is a COMOP not a COMOPS? Look at the following situations and decide if they qualify as COMOPS. You can find the answers at the end of this post.

  1. Normally unmanned installation and a heavy lift vessel?
  2. Normally unmanned installation and an accommodation vessel?
  3. Manned installation and a jackup drill rig?
  4. Manned installation and a DSV conducting diving operations?

Having prepared many CONs there are some key learnings I’ve discovered (mostly the hard way) that I’d like to share:

  • Collaboration. The regulations require a joint effort between all duty holders. This includes the preparation of the CON itself but they also expect evidence of attendance at and contribution to key risk assessments and table top reviews. It’s often appropriate for one duty holder to take the lead on such matters – but all parties need to demonstrate involvement. To set yourself up for success, construct up a RACI table for the primary activities and identify the right personnel and timings for review of key documentation.
  • Actions. If you intend to submit a CON whilst you have safety actions still outstanding, be very clear about when these will be closed and how they will be verified. The regulator can, and does, request safety action responses if they aren’t satisfied.
  • HSE Website. Regulation guidance, a CON framework, inspection templates and assessment principles can all be downloaded from the HSE’s website. These resources are invaluable and worth using as they outline the criteria upon which you will be assessed.
  • New SECEs. Some of the new equipment on the combined installation that is considered safety critical may be considered as Safety and Environmentally Critical Elements (SECE). These require clear performance standards and for a verification scheme to be developed. The duration of the campaign may be short enough that only initial suitability is required. Specific COMOPS SECEs may include the gangway and its connection, personnel on board (POB) tracking and links between emergency shutdown (ESD) systems.
  • Personnel on Board (POB). The CON should clearly outline the intended POB during normal operations as well as the maximum allowable POB. The POB on each of the installations involved must be clearly defined. This is particularly important where there is a single gangway that connects installations and the basis of this POB limit, for example a PFEER Reg 5 assessment, should be made clear. Be aware these numbers may change throughout the operation as the risk profile changes. The gangway may be a common point of failure across both means of evacuation so make it clear how you intend to protect it.

If you’ve got an experience you’d like to share on CONs – or have more to add to this list of factors to be aware of -I’d like to hear from you. Please add your comment below. You can find more information in Regulation 3 of MAR as well as Reg 22 of SCR2015.

Oh, and the answers to the quiz are here: 1 – No; 2 – Yes; 3 – Yes; 4 – No.

Please visit www.salus-technical.com to find out how we can help you to better understand your risks from dropped objects during COMOPS.

Deconstructing the Dismantling Safety Case

For the vast majority of offshore installations, there have been years of stable operations since the start of production. Today, in the North Sea, an increasing number are beginning to experience significant, sometimes rapid, change as preparatory work for decommissioning begins.

These changes may include the removal of hydrocarbons from topsides, the plugging and abandonment (P&A) of wells, a move to normally unmanned operations, the introduction of walk-to-work, heli-decks taken out of service or even the removal of lifeboats.

From my own experience supporting several decommissioning projects, from direct engagement with the regulator and collaboration with others through a Joint Industry Project, there are some things I’d like to share on developing a safety case strategy that fits with the preparation decommissioning and dismantling.

  • Engagement, Engagement, Engagement. Ensuring everyone is properly communicated with takes work and energy. The workforce and the safety reps need to be involved in the decision-making process around the modification or removal of safety systems. The regulator should be included early in the process with proposed plans shared and discussed. The minutes of these meetings should be kept and sent to the regulator. Not all scenarios are prescribed in the regulations and are open to interpretation. Be prepared for the regulator to revise their opinion as time passes – or for new personnel to be appointed. Building and maintaining good working relationships with the regulator over the duration of decommissioning is well worth the effort.
  • Define your phases. From live operations, right through to dismantling, it pays to define distinct phases of operation. These may be many years or only a matter of days in duration. For each phase, the major accident hazards (MAHs), along with their safeguards, should be identified and appropriately risk assessed. Make it clear in the safety case which phase you are currently in, presenting your risk arguments clearly and succinctly.
  • SECEs, Performance Standards and Verification Scheme. Your list of safety and environmental critical elements (SECEs) for an installation, the performance standards and the verification scheme should be appropriate for the identified MAHs and their risk. These documents, and their associated safety critical maintenance burden, may be simplified along with the changes to the installation, driving significant cost reduction. But it’s important to remember that there may be periods of time when new SECEs could be required or existing SECEs need changes to assurance activities as the decommissioning programme develops.
  • PFEER Philosophy. The prevention of fire and explosion and emergency response (PFEER) philosophy of any installation is its primary and alternative means of evacuation, as well as means of escape. Under the PFEER regulations the distinction between evacuation and escape is an important one. For each phase of operation, the PFEER philosophy must be clearly documented within the safety case. That’s not enough on its own. It must also be clear to the workforce.
  • Group material changes together. Traditionally, material changes consider a single step-change in risk on an installation. Given the sometimes rapid cycle of change in a decommissioning scenario, it may be more appropriate to group several material changes together. This is likely to reduce administrative burden both for the duty holder as well as the regulator, and pave the way for productive early engagement between both parties. However, the arguments supporting the change in each phase should be clearly demonstrated in the safety case.
  • Dismantling Safety Case. Regulation 20 has been interpreted by some as a new document that must be produced early in the decommissioning phases of an installation. In fact, this document is simply a special case material change. It should be submitted when you think it appropriate but this is normally done ahead of physical dismantling operations. The dismantling case itself can be subject to subsequent material changes.

Effective duty holders and project teams recognise that decommissioning is simply another phase of the installation’s lifecycle. It would be great to have your suggested key learnings to add to this list of what matters in late-life operations for the safety case.

I was part of the team who collaborated to produce the “Guidance for UK Safety Case management during End of Life (EoL) decommissioning and dismantling”. This was launched at OE2017 this morning and can be accessed viahttps://goo.gl/EQsM8i

Indiana Jones and the Offshore Safety Case

For those who haven’t seen Raiders of Lost the Lost Ark (1981) (and I can’t think of a good reason why anyone hasn’t) be warned … there are some spoilers below. In this modern classic, Indiana Jones is hired by the U.S Government in a race against time to find the Ark of the Covenant before the bad guys. The Ark is a priceless artefact which, when opened, has disastrous consequences for some individuals. Ultimately in the closing sequence it is placed in storage, gathering dust and never to be opened again.

There are parallels to be drawn between the Ark and Oil and Gas industry Offshore Safety Cases. During major projects and ahead of inspections, Safety Cases can be centre stage, with serious consequences when opened by the regulator if information contained within is found to be inaccurate. They can also, in some cases, sit for prolonged periods on the shelf in the Offshore Installation Manager’s (OIM’s) office offshore, gathering dust.

The Safety Case is regarded by many as the critical document in securing a licence to operate by the offshore regulator. The requirement for a Safety Case was born out of the Piper Alpha Disaster in 1988 when 176 people were killed, over 10% of North Sea production halted and the damage ran into billions of dollars.

The enquiry into the disaster led by Lord Cullen, a former judge, made 106 recommendations, the first of which was that all Offshore Installations in UK waters were required to present their case for safety much like a legal representation to a court. This was the start of the Safety Case as we know it today. In 1992, The Safety Case Regulations were brought into law aimed at reducing the risks from major accidents offshore.

The Safety Case Regulations were refreshed in 2005 and then again in 2015 in the wake of the BP Macondo incident in the Gulf of Mexico. The regulations themselves are goal-setting and their 164-page guidance document describes the information to be contained within the cases, the situations where notifications are required to the regulator as well as information on exemptions, penalties and appeals.

Within a Safety Case you’ll find a detailed description of the installation, details of the duty holder’s Safety and Environmental Management System (SEMS), a list of all the Major Accident Hazards that are present, a risk assessment, the arrangements for emergency response and a summary of how the workforce has been involved in the Safety Case development. Once a duty holder has an accepted Safety Case it must be kept up to date.

Thankfully, the Offshore Safety Case has a far happier ending then Raiders of the Lost Ark. A lot of good work goes into preparing them and, if you haven’t already done so, I would encourage you to read yours. Yes, it may contain some information that is there simply to satisfy the regulator but you will likely learn a lot more about the major accidents present on your installation, how they’re managed, the safeguards in place to prevent them and mitigate their consequences as well as the arrangements in place in an emergency. No one needs to be a hero with a proper Safety Case in place.

A list of UK Offshore health and safety law, with accompanying guidance, can be found here: http://www.hse.gov.uk/offshore/law.htm