By Ian Hamilton

Within safety critical industries there is a consensus of opinion that human factors have caused, or significantly contributed to, up to 90% of incidents and accidents. This is widely reported in the marine, transportation and aviation sectors but is equally true in the oil and gas sector.^1,2 Human factors causes have featured in a number of high profile incidents in recent years, including the explosion and fire at Texas City in 2005, the leak of radioactive materials at the Thermal Oxide Reprocessing Plant at Sellafield (UK 2005), the Buncefield fuel depot explosion also in 2005, and most recently, the explosion and fire on the Deepwater Horizon drilling rig in 2010.

The Introduction of SEMS

Increasingly, regulators are demanding that operators and license holders take steps to address weaknesses in their safety behavior and management systems that can lead to human and organizational failures. In the UK, the Health and Safety Executive’s Publication HSG48³ identifies the mechanisms by which failure on the part of people can be influenced by the management and decision-making  functions of the organization. In Australia, the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA), was passed by Parliament in September this year and the Government is committed to the commencement of NOPSEMA on 1 January 2012. The control of human factors risks is a central element of the NOPSA Safety Case Guidance.⁴

Following the investigation into the causes of the Deepwater Horizon incident, the US Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) has implemented regulatory reforms aimed at improving safety in the Gulf of Mexico.⁵ Central to these is the Safety and Environmental Management System (SEMS) or workplace safety rule. This will require operators to identify and manage human and organizational risk factors and demonstrate their control measures through a safety case. Particularly, and for the first time, there is a specific focus on the control of human error, the assurance of competence, and the management of the risks of organizational failure.

Achieving this as part of a safety case style regime will demand that many operators adopt new risk management practices to match this new emphasis. Those operators that are familiar with the UK and Australian style of safety regulation, will be able to achieve this by adapting some of their established processes. But operators who operate exclusively in the Gulf of Mexico will need to rely on some form of independent industry guidance. IADC guidance on safety case preparation⁶ does include advice on human factors but this is focused primarily on the ergonomics of equipment and workspaces and provides little assistance to address the broader human and organizational risk factors as they relate to safety management.

Human and Organizational Factor Elements

Several human and organizational factor elements are essential for full safety assurance which must be demonstrated in the safety case. Firstly there should be evidence of a thorough review of safety critical tasks to identify and control the risk of human error. This can be achieved through a HAZOP-style review meeting that is supported by a human factors analysis of frontline activities involving exposure to hazards. Suitable risk control measures should be identified and implemented comprehensively. This may include the re-design of plants and equipment to improve usability.

Secondly, there must be genuine safety leadership from senior management onshore, through offshore installation management, supervision and team leaders. Good safety leadership requires a combination of technical and interpersonal skills. Leaders should demonstrate competence and a thorough understanding of their safety responsibility; they should communicate clearly and lead by example. Trust is essential. Supervision should be seen as consistent and fair, and leaders should be open and consultative with their colleagues.

Hazard analysis and safety leadership are essential to promoting the third factor in the safety assurance process, good hazard awareness amongst crew members. The most effective risk management will also include a process to plan for peaks and troughs in workload and to ensure that sufficient and competent manpower is always available.

Fourth, competence assurance must be demonstrated, not just by the provision of training, but by the assessment of all relevant technical knowledge and skill. Assessment results should be transparent and used to set development goals and as a framework for appraisals and promotions. Good competence management should also include the specification of knowledge, skill, and aptitude criteria for selection and recruitment, and these should be reviewed and modified to remain aligned with changes in the business’ objectives and practices. The competence management system should also include evidence of the explicit specification of safety responsibilities and accountabilities for each job role.

Processes and procedures should be targeted towards the control of risk and be useable and practicable. Many organizations fail to ensure that their processes are relevant and up to date. This can lead to the perception by the workforce that safety processes and procedures are not essential, encouraging a climate of routine violation of safety rules.

The sixth element is an effective system of safety communications to ensure that weaknesses in practices and procedures are identified and addressed. All safety incidents and near misses should be reported. This requires an atmosphere of trust in which people are confident that they can report occurrences free from any risk of blame and punishment.

Where there is good communication, there will be opportunities for the continuous review and improvement of working methods, equipment, supervision and safety rules.

Finally, a system of governance should exist to provide a mechanism to review feedback and findings from incidents and reviews, plan for improvements, and to manage change so that improvements are correctly established and durable.

Conclusions

These eight concepts are the essential elements of effective human factors risk management that should be incorporated within a safety management system and demonstrated through the safety case:

•Safety critical task analysis

•Safety responsibility and leadership

•Good hazard awareness

•Competence assurance

•Usable processes and procedures 

•Good safety communications

•Continuous review and improvement

•Effective change management 

They operate as mutually dependent elements of a mature, involving, and progressively improving safety culture. SEMS should demonstrate that safety is achieved and maintained through the management of the hazards associated with all the elements of people, plant design and process that make up the offshore asset. The demonstration is evidence-based rather than rule-based, and should be complementary to the elements of assessment of the technical safety systems. This is essential because the proper function of the safety mechanisms depends on the reliable performance of the maintenance and operational personnel. In short, organizational integrity should complement technical integrity for optimum performance.

References

1.       Alison Collins and Deborah Keeley. 2003. Loss of Containment Analysis. HSL 2003/07, UK Health & Safety Laboratory. http://www.hse.gov.uk/research/hsl_pdf/2003/hsl03-07.pdf

2.       Alison McGillivray and John Hare. 2008. Offshore Hydrocarbon releases 2001-2008. Research Report RR672, UK Health & Safety Laboratory. http://www.hse.gov.uk/research/rrpdf/rr672.pdf

3.       Reducing Error and Influencing Behaviour. 2009. HSG48, UK Health and Safety Executive (1999). http://www.hse.gov.uk/pubns/books/hsg48.htm

4.       NOPSA Guidance http://www.nopsa.gov.au/projects.asp

5.       Report Regarding the Causes of the April 20 2010 Macondo Well Blowout. 2011. Bureau of Ocean Energy Management Regulation and Enforcement, US Department of the Interior (September 2011). http://www.boemre.gov/pdfs/maps/dwhfinal.pdf

6.       Health, Safety and Environment Case Guidelines for Offshore Drilling Contractors, Appendix 1 (2007). International Association of Drilling Contractors. http://www.iadc.org/hsecase/MODU%20Offshore%20Appendix%20Issue%203.3.1%20Final.pdf

Photo credits

“Texas City Disaster.” 2005. Popular Mechanics. http://www.popularmechanics.com/technology/gadgets/news/1758242

“Buncefield Explosion.” 2005. Buncefield Investigation. http://www.buncefieldinvestigation.gov.uk/images/gallery/casu02big.jpg

“Gulf of Mexico Oil Rig.” Shutterstock.com

“Woman in Hard Hat.” Shutterstock.com

Contact the ERM North America Risk Practice Group, a global leader in assessments of engineering design and operations safety for hazardous facilities. The Risk Practice conducts facility siting, consequence analysis, process hazard assessments, hazard identification, and a host of other safety and hazard analysis.

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