SPE 86599

Results From a Four Year Regulatory Campaign To Reduce Offshore Hydrocarbon

Releases
Neville Edmondson, UK Health and Safety Executive

Copyright 2004, Society of Petroleum Engineers Inc.

Background
This paper was prepared for presentation at The Seventh SPE International Conference on
Health, Safety, and Environment in Oil and Gas Exploration and Production held in Calgary,
Alberta, Canada, 29–31 March 2004. The campaign started in April 2000 and was targeted at
This paper was selected for presentation by an SPE Program Committee following review of
trying to secure a 50% reduction in the annual number of
information contained in a proposal submitted by the author(s). Contents of the paper, as offshore major and significant hydrocarbon releases
presented, have not been reviewed by the Society of Petroleum Engineers and are subject to
correction by the author(s). The material, as presented, does not necessarily reflect any (see Table 1 for definition of release categories) by the
position of the Society of Petroleum Engineers, its officers, or members. Papers presented at
SPE meetings are subject to publication review by Editorial Committees of the Society of
end of Year 2003/2004 compared to a baseline of Year
Petroleum Engineers. Electronic reproduction, distribution, or storage of any part of this paper 1999/2000 when there were 139 such releases, 12
for commercial purposes without the written consent of the Society of Petroleum Engineers is
prohibited. Permission to reproduce in print is restricted to a proposal of not more than 300 major and 127 significants. So a reduction to 70
words; illustrations may not be copied. The proposal must contain conspicuous
acknowledgment of where and by whom the paper was presented. Write Librarian, SPE, P.O.
releases or lower was needed, if the target was to be
Box 833836, Richardson, TX 75083-3836, U.S.A., fax 01-972-952-9435. met.

Proposal TABLE 1

In April 2000, The Offshore Safety Division of the United NUMERICAL SEVERITY CLASSIFICATION
Kingdom Health and Safety Executive launched a 4 year MAJOR RELEASES
campaign to try to reduce the number of hydrocarbon
releases occurring on offshore installations in the UK Gas
Continental Shelf (UKCS). The target was to reduce the Either Quantity release > 300kg
annual number of major and significant releases by 50% Or Mass release rate > 1kg/s and duration > 5 min
by the end of March 2004. The campaign resulted from Liquid
Either Quantity released > 9000kg
concerns that no improvement had been seen in the Or Mass release rate > 10kg/s and duration > 15 min
hydrocarbon release record over the previous several Two-phase
years. The paper will Either Quantity released > 300kg
Or Liquid release rate > 1kg/s and duration > 5 min
• Outline the main elements of the campaign Significant Releases
Those lying between the limits for major and minor releases
MINOR RELEASES
• Report on ‘bottom line’ progress in reducing
Gas
release numbers Either Quantity released < 1kg
Or Release rate < 0.1kg/s and duration < 2 min
• Indicate the main problem areas (in terms of Liquid
both equipment and systems procedures) that Either Quantity released < 60kg
have been identified as involved in the releases, Or Release rate < 0.2kg/s and duration < 5 min
report on the remedial measures formulated to Two-phase
Either Quantity of liquids release < 1kg
counter these problems areas and indicate the
Or Liquid release rate < 0.1kg/s and duration < 2 min
effectiveness of the measures
The campaign was initiated as a result of concerns
• Report on the excellent co-operation achieved regarding the continuing levels of hydrocarbon release
between regulators and industry in pursuance of that were being seen. Whilst the post – Piper A years
the campaign and indicate some of the forms had seen substantial improvements across many areas
that the co-operation has taken offshore (fire and blast protection, temporary refuge
facilities, escape, evacuation and rescue arrangements
• Conclude that carefully formulated joint action etc) examination of the hydrocarbon release record
plans between regulators and industry can lead indicated that there had not been matching improvement
to significant reductions in annual hydrocarbon with this particular facet and that overall release
release numbers
2 SPE 86599

numbers had largely remained the same for the past 4 in 2001/2002 before increasing slightly to 6 in
several years. 2002/2003.

Given that the initial release is the catalyst for all The last three years in fact represent the first time that
subsequent fire and explosions, this was particularly major release numbers have been in single figures and
worrying. It was also clear that many of the major overall gives a 50% reduction against the baseline
releases had the potential, given the right target. Given that it is the major releases that have the
circumstances, in terms of factors such as finding a greatest potential for rapid escalation, the reduction is
source of ignition, the location and timing of the ignition viewed as particularly encouraging.
etc, to give rise to very serious events indeed, possibly
involving significant loss of life or significant damage to Significant Releases- The number of significant
the installations concerned. For example, there was an releases fell from 127 in 1999/2000 to 117 in the first
incident on the UKCS where, for a short period of time, year of the campaign to 105 in 2001/2002 and then to 79
virtually the whole of an installation was enveloped in 2002/2003. This gave an overall 38% reduction
within a flammable gas cloud. Fortunately the cloud did against the baseline target.
not ignite but if it had there is no doubt as to the potential
seriousness of the situation. Minor Releases – Minor releases were specifically
excluded from the release target because prior to the
The financial implications of the releases in terms of start of the campaign there were doubts as to the
outage time / lost production / remedial work were also reliability and completeness of release reporting for this
not insignificant with typical average cost estimates lying category. For example, the recorded annual number of
in the range of £35K and £50K per release, though minor releases appeared much lower than the number
clearly much higher figures applied to the larger that would be expected based on a typical Heinrich
releases. triangle approach and the corresponding number of
significant releases. In the first year of the campaign, a
So, all in all, it was decided that a more proactive significant increase was seen in the number of minor
approach to the problem was needed with the objective releases reported, from 95 to 145, though the figure has
of making real inroads into reducing release numbers since stabilized around this higher number. However in
and hence the campaign was initiated. practice is believed that the initial rise mainly
represented an increase in reporting activity as result of
The campaign was largely based around 2 parallel both greater awareness and greater scrutiny of the
initiatives reporting process rather than an increase in the number
of such incidents actually taking place. It should also be
• One based on the mandatory investigation noted that the figures for recent years appear to present
for a 12 month period of all RIDDOR(1) more credible Heinrich triangle formats.
reportable incidents involving hydrocarbon
release, targeted at trying to obtain a better
understanding of the causes (immediate and Table 2
underlying) of the releases that were 10 Year Hydrocarbon Release Record
occurring. 93/ 94/ 95/ 96/ 97/
Severity
94 95 96 97 98
Major 24 20 20 19 13
• The other involving a four year rolling Significant 151 194 134 129 139
programme of detailed process integrity Minor 96 111 58 78 66
inspections for all normally manned offshore
production platforms. Severity
98/ 99/ 00/ 01/ 02/
99 00 01 02 03
Major 15 12 8 4 6
‘Bottom line’ Progress
Significant 134 127 117 105 79
Minor 85 95 145 134 144
The annual number of hydrocarbon releases reported to
HSE for each of the past ten years, classified in terms of Current Year Figures
the major, significant and minor categories that are
employed are shown in Table 2. At the time of writing, provisional release figures are only
available for the first 4 months of 2003/2004. These
Major Releases - From Table 2 it can be seen that for a indicate major and significant release numbers slightly
large period of the last decade, major releases were ahead of the equivalent period in 2004/2003, indicating
typically running between 15 and 20 each year. that a sustained effort will be required for the remainder
Following a small scale pilot release reduction project of the year if the full 50% reduction is to be achieved.
this was reduced to 12 in 1999/2000. The first year of
the campaign proper, 2000/2001, saw a reduction in the
number of major releases from 12 to 8. This then fell to
SPE 86599
Bench Marking
The annual hydrocarbon release figures were used as a
basis for a coarse bench marking of the leak
performance of different companies. The bench marking
was done on the number of major and significant
releases per normally manned installation for each
dutyholder. The picture that emerged using the 2000 /
2001 data was one of fairly wide differences in
performance, with the worst performing company having
a release rate around 6 times that of the best. In
subsequent years, overall performance levels have
generally both improved and also tended to bunch closer
together (with the exception each year of a different
outlier) indicating that standards across the industry are
gradually rising and becoming more uniform.
Companies have been kept appraised of their own
performance relative to their peers in order that they can
gaugue their potential for further improvement.
Problem Areas and Remedial Measures
One of the prime objectives of both the investigation and
inspection elements of the campaign was to identify the
main problem areas leading to the release of
hydrocarbon and then in conjunction with industry
determine whether there were remedial measures (‘good
practice’ guidance, training etc) that could be put in
place to improve the position. The conceptual
improvement model employed is shown in Figure 1.
F ig u re 1 Im p ro v e m e n t M o d e l
H S E u s e re g u la to ry p o w ers to c o lle c t
elev ant data
D ata
D ata a n aalyse
n a lys
d toe d
id eto id ethnetify
n tify m ath
in ep ro
mbain
lem s
problem a rea s sareas
A ppropriate rem edial m ea sures
form ulated an d a gre ed w ith industry
H S E m o n itor for a w a re n e s s / a d o p tio n
o f rem e d ia l m e a su re s d u rin g p ro c e s s
ins p e c tio n s
The cycle is then repeated every 3 to 4 years to
determine whether there are any new problem areas
3
emerging and also to assess the extent of any
improvement in the previously identified problem areas
resulting from the remedial measures put in place. In
this context, a new mandatory release investigation
project was initiated in 2003/2004.
Main Problem Areas
Investigation Project
A detailed analysis was carried out of the release
investigation reports. The analysis covered a variety of
factors including operating mode, immediate causes,
underlying causes etc. A full account of the analysis is
given in Reference 2.
One of the most significant findings from the analysis
was the fact that the vast majority of releases occurred
not for reasons of great technical complexity but rather
as a result of breakdown in basic procedures and
controls such as, for example, failure to make flanged
joints or small bore tubing connections. In some
respects this finding was encouraging in that it indicated
that significant improvement was possible provided basic
standards in these areas could be improved. From a
review of the analysis the following problem areas were
prioritized for follow-up work to identify possible remedial
measures.
(a) Corrosion management
(b) Fatigue and vibration monitoring
(c) Small bore tubing and instrument fittings
(d) Bolted pipe joints
(e) Flexible hoses
The mechanism for formulating possible remedial
actions for each of these areas and the actual measures
agreed are described under ‘Remedial Measures’.
Inspection Project
The inspection project was formulated in terms of 10
process elements which were selected to represent
some of the main topic areas which influence the safe
operation of process plant offshore. They were as
follows:
1. Management of process integrity
2. Small bore tubing systems and
flexible hoses
3. Documentation and communication
4. Isolation and permit to work controls
5. Process plant protection systems
4 SPE 86599
6. Change control
7. Maintenance and verification of safety
critical elements
8. Control of specific process hazards
9. FPSO – specific systems
10. Construction and commissioning of
process plant
As part of the project, all relevant elements were to be
inspected across all manned production installations.
There are currently some 105 such installations on the
UKCS. With 6 months of the project still to go, between
65% - 70% of the planned number of inspection have
been completed.
A final report covering all ten elements will be produced
when the project has been completed. However an
interim summary of some of the main points emerging at
the midway mark for the first 5 elements is given in
Reference 3.
Perhaps the most significant general finding and one
that applied to many companies was the mismatch
between onshore perceptions and offshore reality. From
onshore enquiries, it often appeared that companies had
in place procedures and systems that covered the
relevant areas and were well conceived. However when
the same procedure and systems were inspected in
detail offshore, the position revealed was frequently very
different in that compliance with some of the designated
procedures was pretty poor and in extreme cases
personnel even appeared unaware of their existence.
Onshore management often seemed unaware that their
procedures / systems were not being followed, indicating
some significant weaknesses in the ‘measuring
performance’ / ‘reviewing performance’ / ‘auditing’
elements of the associated Safety Management
Systems. Unfortunately the breakdown in compliance
with designated procedures has also been a strong
contributor to a number of recent offshore relases.
Findings from some of the other elements of the project
were
(a) Small bore tubing. Several companies had
procedure in place which deviated
significantly from recognized good practice in
areas such as
• Uncontrolled usage of different types of
fitting
• The absence of clear competency
standards
• Lack of adequate storage segregation
between different fitting types
(b) Flexible hoses. Very few companies had
any procedures covering the usage, design,
selection or testing of hoses including those
on hydrocarbon duty.
(c) Documentation and Communication. There
were many examples of failure to maintain
up-to-date versions of critical documents
such as Piping and Instrumentation
Diagrams (P&ID’s) and operating manuals.
In some cases this has had a ‘knock on’
effect in that a number of hydrocarbon
releases had occurred as a result of
incorrectly placed isolations due to staff
working with out-of-date P&ID’s.
(d) Isolations A variety of problems were
encountered including
• No clear system for logging Long Term
Isolations
• No system for reviewing the need for
long term isolations
• Breakdown of locked valve systems
where critical values were either not
locked or locked in the wrong position
• Use of more than one procedure on the
same installation to determine isolation
standards leading to potential confusion
and a lack of consistency
• Company isolation procedures which
were significantly less rigorous than
recognized good practice
(e) Process Plant Protection Systems.
Instances where
• Override had been applied or left on
without obvious valid reason and without
any form of risk assessment having
been carried out
• No assessment of trip function criticality
(for example by Safety Integrity Level
[SIL] assessment or similar). Examples
of where an assessment had been
carried out, the methodology employed
had differed significantly from
recognized good practice
• No up to date record for trip settings nor
formal authorisation controls as to when
SPE 86599
changes could be made and on whose
authorisation.
Remedial Measures
It was recognized at the outset of the campaign that for
maximum impact and take-up any proposed remedial
measures should have been formulated and agree as a
collaborative venture with the industry. The conduit for
discussions with the industry has been the Release
Reduction Workgroup set up by the United Kingdom
Offshore Operators Association (UKOOA).
In practice, the normal form of remedial measure has
been the production of industry ’good practice’ guides
addressing each of the individual problem areas,
supplemented where relevant by appropriate training.
The format adopted to produce the good practice guides
has been for either
(a) The task to be undertaken by a dedicated
group of industry nominees, trade
representatives and HSE
(b) The work to be carried out by specialist
consultancies jointly funded by both industry
and HSE
References 4 to 8 are examples of good practice guides
produced via this route. The guides were produced to
specifically address the prioritised list of problem areas
identified by the investigation project. As mentioned
previously, an important mechanism for promoting
awareness and usage of the documents has been for
them to be incorporated into HSE’s offshore inspection
programmes.
Most of the guides have only been in place for a
relatively short period of time and hence it is difficult to
reach definitive conclusions (particularly quantitative
conclusions) as to whether the desired beneficial effects
are being achieved and release numbers in these areas
being reduced. Qualitatively it is clear from inspection
reports that much much higher general standards are
starting to be seen with respect to small bore tubing,
fatigue / vibration (the number of offshore vibration
surveys carried out is particularly encouraging) and
flexible hoses. However the effect on release numbers
is at best tentative and a few more years data is required
before the impact of the guides can be accurately
measured.
Industry Support
An important feature of the campaign has been the
degree of support that it has received from the industry
itself. From the outset of the campaign, every effort was
made to communicate to industry what was planned and
why in order to proceed as far as possible on a
collaborative basis. This is a stance that has been
maintained throughout, with numerous talks being given
5
to individual companies and trade associations, annual
feedback seminars being organized with the United
Kingdom Offshore Operators Association (UKOOA), all
documentation relating to the campaign (such as the
HSE Inspection Guidance Notes) being made freely
available etc. Some of the corresponding industry
inputs include.
• The setting up by UKOOA of a Release
Reduction Work Group to support the campaign
with representation from all operating
companies.
• The production by the Release Reduction Work
Group of a ‘Reducing Leaks – Raising
Awareness’ video which was shown to the
workforce on all installations
• Provision of staff to support the various work
groups set up to formulate good practice in
different problem areas.
Several individual companies also set up their own
internal release reduction campaigns to operate in
parallel with the HSE campaign. By way of example of
the level of effort that went into some of these individual
campaigns one company
• Produced a quarterly Leak Reduction Bulletin
which was sent to all staff.
• Provided monthly status reports on release
numbers for all installations which were issued
across the company
• Purchased portable ultrasonic leak detectors for
all installations, employed in the context of
regular co-ordinated leak surveys on each
installation
• Sent 700 offshore personnel on a bolted joint
assembly course designed to supplement the
UKOOA ‘good practice’ guide
• Sent 900 offshore personnel on a compression
fitting course and made successful completion of
the course a mandatory condition for future
working on such fittings
• Sent 400 selected offshore personnel on a
corrosion awareness refresher course and also
produced a compact disk on the subject to
promote further platform discussion
Conclusions
The current position from an HSE perspective as the
current campaign comes to a close are
6 SPE 86599

• Good progress toward the 50% reduction target 7. Guideline for the Avoidance of Vibration Induced
has been made, with the largest reduction Fatigue in Process Pipework, Marine
occurring in the major release category Technology Directorate ISBN 1870553373

• The benefits to the workforce in terms of
reduced risk levels and to the industry in terms
of reduced outage have been significant
• The campaign has benefited greatly from
excellent industry co-operation
8. Review of Corrosion Management for Offshore
Oil and Gas Processing, UK Health and Safety
Executive, Report OTO 2001/044, August 2001,
ISBN 0717620964

• Analysis of incident causation indicates that the

vast majority occur not for reasons of great
technical complexity but from failure in basic
controls and procedures and hence are
eminently preventable

• The model going forward is to continue to use

available data sources to identify key problem
areas, set up with industry appropriate work
groups. To formulate good practice in these
areas, vigorously promote the good practice
across the industry and use it as a basis for
regulatory inspections

• In this and other areas, the value of good

company procedures is greatly diminished if
there is no appropriate management driven
monitoring and audit system in place to ensure
that the procedures are actually being followed

References

1. The Reporting of Injuries, Diseases and

Dangerous Occurrences Regulations (RIDDOR)
1995

2. Report on the Hydrocarbon Release Incident

Investigation Project 1/4/2000 to 31/3/2001 – UK
Health and Safety Executive, Report OTO
2001/055

3. Feedback / Learning from Process Integrity

Inspection, J N Edmondson and A Thompson,
3rd Joint UKOOA / HSE Seminar on Offshore
Hydrocarbon Releases, Aberdeen 2002

4. Guidelines for the Management of Integrity of

Bolted Pipe Joints, UKOOA / Institute of
Petroleum, June 2002, ISBN 1903003148

5. Flexible Hose Management Guidelines, UKOOA

/ Institute of Petroleum, January 2003, ISBN
1903003210

6. Guidelines for the Management, Design, Installation

and Maintenance of Small Bore Tubing Systems,
UKOOA / Institute of Petroleum, June 2000, ISBN
0852932758