Posted in accidents, Mexico, Offshore Energy - General, tagged 2 fatalities, Bay of Campeche, Cantarell Field, Mexico, Platform fire on July 11, 2023| Leave a Comment »
The fire was triggered by an explosion on the Nohoch-A link platform of the company’s Cantarell Field, in the the Bay of Campeche. It then spread to a compression complex, where the two workers lost their lives. More than 300 people were evacuated. The fire is reported to be controlled.
Posted in accidents, Gulf of Mexico, Offshore Energy - General, Regulation, UK, tagged fire, Lord Cullen, North Sea, Piper Alpha, safety case, South Pass 60 B on July 6, 2023| Leave a Comment »
The Piper Alpha fire was the worst disaster in the history of offshore oil and gas operations and sent shock waves around the world. Eight months later another interactive pipeline-platform fire killed 7 workers at the South Pass 60 “B” facility in the Gulf of Mexico. A US Minerals Management Service task group reviewed the investigation reports for both fires and recommended regulatory changes with regard to:
Paul Schneider and I wrote a paper on the task group’s findings and that paper was published in Offshore Operations Post Piper Alpha (Institute of Marine Engineers,1991). The proposed regulations that followed summarized these findings and can be be found at this Federal Register link.
Lord Cullen’s comprehensive inquiry into the Piper Alpha tragedy challenged traditional thinking about regulation and how safety objectives could best be achieved, and was perhaps the most important report in the history of offshore oil and gas operations. Per Cullen:
“Many current safety regulations are unduly restrictive because they impose solutions rather than objectives. They also are out of date in relation to technological advances. Guidance notes lend themselves to interpretations that discourage alternatives. There is a danger that compliance takes precedence over wider safety considerations and that sound innovations are discouraged.“
Cullen advocated management systems that describe the safety objectives, the system by which those objectives were to be achieved, the performance standards to be met, and the means by which adherence to those standards was to be monitored. He called for safety cases that describe major hazards on an installation and provide appropriate safety measures. Per Cullen, each operator should be required in the safety case to demonstrate that the safety management systems of the company and the installation are adequate to assure that design and operation of the platform and its equipment are safe.
Links for the full Piper Alpha Inquiry: volume 1 and volume 2
Posted in accidents, Gulf of Mexico, Offshore Energy - General, tagged 4 fatalities, Bell 407, BSEE, helicopter crash, Island Operating Co., NTSB, USCG, Walter Oil and Gas on June 22, 2023| Leave a Comment »
The preliminary NTSB report was posted on 1/18/2023, but the final report has still not been published. Status update:
Will the investigators consider longstanding regulatory fragmentation issues? The most recent Coast Guard – BSEE MOA for fixed platforms added to helideck regulatory uncertainty by assigning decks and fuel handling to BSEE and railings and perimeter netting to the Coast Guard. This is the antithesis of holistic, systems-based regulation.
Posted in accidents, climate, Offshore Energy - General, pipelines, tagged Nord Stream, play by play, Russia, Seymour Hersh, Ukraine, US, whodunnit? on June 21, 2023| Leave a Comment »
Trying to keep track:
So at this time, some theories on the culprits appear to have dropped out. Those that are still in play include various versions of the Ukrainian rental yacht narrative and the Hersh account. Hopefully, the responsible parties will be identified, but given the political stakes, this is becoming increasingly unlikely.
Posted in accidents, Australia, NOPSEMA, Norway, Offshore Energy - General, tagged Austraiia, BSEE, lifting incident, NOPSEMA, North Rankin, PSA Norway on June 13, 2023| Leave a Comment »
NOPSEMA’s June 8 safety alert implies that the June 2nd fatality at the North Rankin complex, offshore Western Australia, was the result of a crane/lifting incident. Per NOPSEMA:
A recent fatal incident involving a person working on an offshore oil and gas facility has provided a tragic reminder of the risks of work involving the rigging, manipulation and movement of loads, including people and equipment.
Despite the international focus on lifting operations over the past 30 years, Norwegian and US data do not suggest improved performance. PSA Norway’s “Trends in risk level on the Norwegian Continental Shelf” report shows an increase in lifting incident rates for both fixed and mobile facilities over the past 10 years (first chart below).
Similarly, recent lifting data from BSEE’s incident tables (summary below) and Jason Mathew’s June 2022 presentation (pages 48-63) suggest that lifting risks are not being effectively mitigated. Why are industy/regulator messages regarding hazard identification and controls not achieving the desired results? Perhaps a fresh look and renewed dialogue are needed.
Crane or personnel/material handling incident (as used in 30 CFR 250.188(a)(8)) refers to an incident involving damage to, or a failure of, the crane itself (e.g., the boom, cables, winches, ballring), other lifting apparatuses (e.g., air tuggers, chain pulls), the rigging hardware (e.g., slings, shackles, turnbuckles), or the load (e.g., striking personnel, dropping the load, damaging the load, damaging the facility) at any time during exploration, development, or production operations on the OCS. This includes all incidents of shock loading that, upon inspection, reveals damage to any part of the crane, lifting apparatus, rigging hardware, or load. Personnel handling incidents include events involving swing ropes, personnel baskets, and any other means to move personnel. Material handling incidents include any activities involving the loading and unloading of material and moving it on, off, or around an OCS facility.
Posted in accidents, Australia, Offshore Energy - General, tagged fatality, North Rankin, Western Australia, Woodside on June 2, 2023| Leave a Comment »
All we know at this point is that a Woodside contractor died during work activities at noon today (AWST).
The North Rankin complex is in 135 km offshore from Dampier on the northwest coast of Australia and is in 125 m of water.
More to follow.
Posted in accidents, Australia, conferences, IRF, NOPSEMA, tagged IRF conference, NOPSEMA, offshore safety, performance measures, regulatory fragmentation, safety leadership on May 25, 2023| Leave a Comment »
IRF conferences present an excellent opportunity for dialogue among regulators, operators, trade organizations, contractors, academics, and other interested parties.
Some suggested agenda topics for the Perth conference:
Posted in accidents, pipelines, Russia, tagged Nord Stream, Ukraine on May 22, 2023| Leave a Comment »
German investigators are sceptical of claims that Russian naval ships sabotaged the Nord Stream gas pipelines and are instead pursuing leads that point to the Ukrainian authorities, according to a report.
The vacuum of official information has been filled by speculation variously pinning the blame on the United States, Russia, the Ukrainian secret services and an unnamed businessman in Ukraine. All three states have denied responsibility.
Times of London
Posted in accidents, Gulf of Mexico, Offshore Energy - General, pipelines, Regulation, tagged BOEM, BSEE, Coast Guard, fires and explosions, Huntington Beach pipeline spill, macondo, OCS fatalities, regulatory fragmentation, safety, South Pass 60 B on May 18, 2023| Leave a Comment »
Linking an interesting academic paper on regulatory fragmentation:
Regulatory fragmentation occurs when multiple federal agencies oversee a single issue. Using the full text of the Federal Register, the government’s official daily publication, we provide the first systematic evidence on the extent and costs of regulatory fragmentation. We find that fragmentation increases the firm’s costs while lowering its productivity, profitability, and growth. Moreover, it deters entry into an industry. These effects arise from regulatory redundancy and, more prominently, regulatory inconsistency between agencies. Our results uncover a new source of regulatory burden: companies pay a substantial economic price when regulatory oversight is fragmented across multiple government agencies.
Regulatory Fragmentation
The US has a highly fragmented offshore regulatory regime that has become even more fragmented with the complex division of responsibilities between BOEM and BSEE. The slide below is from a presentation on this topic.
While the linked paper focuses on costs and productivity, fragmentation may also be a significant safety risk factor. A UK colleague once asseted that “overlap is underlap,” and I believe there is something to that. If multiple agencies have jurisdiction over a facility, system, or procedure, the resulting redundancy, inconsistency, and ambiguity may create significant gaps in industry and governmental oversight.
For example, regulatory fragmentation was arguably a significant factor in the most fatal US offshore fire/explosion incidents in the past 35 years – the South Pass B fire in 1989 and the Macondo blowout in 2010. More specifically:
South Pass 60 B: The investigation of the 1989 South Pass 60 B platform explosion that killed 7 workers noted the inconsistency in regulatory practices for the platform, regulated by DOI, and the pipeline regulated by DOT. Cutting into the 18-inch pipeline riser did not require an approved procedure, and the risks associated with hydrocarbon pockets in the undulating pipeline were not carefully assessed. Oversight by the pipeline operator was minimal, and the contractor began cutting into the riser without first determining its contents. A massive explosion occurred and 7 lives were lost.
Decades later, DOT and DOI pipeline regulations and oversight practices are still inconsistent. Note the confusion regarding the applicable regulations following the Huntington Beach pipeline spill in 2021. As posted following that spill:
One would hope that this major spill will lead to an independent review of the regulatory regime for offshore pipelines. Consideration should be given to designating a single regulator that is responsible and accountable for offshore pipeline safety (a joint authority approach might also merit consideration) and developing a single set of clear and consistent regulations.
Macondo: While the root causes of the Macondo blowout involved well planning and construction decisions regarding the casing point, cementing of the production casing, and well suspension procedure, the blowout would likely have been at least partially mitigated (and lives saved) if the gas detection system was fully operable, the emergency disconnect sequence was activated in a timely manner, flow was automatically diverted overboard, or engine overspeed devices functioned properly. Indeed, regulatory overlap led to underlap as summarized below:
| Macondo contributing factor | jurisdiction |
| flow not automatically diverted overboard | DOI/USCG (also concerns about EPA discharge violations) |
| some gas detectors were inoperable | DOI/USCG |
| generators did not automatically shutdown when gas was detected | USCG/DOI |
| failure to activate emergency disconnect sequence in a timely manner (training deficiencies and chain-of-command complications) | USCG/DOI |
| engine overspeed devices did not function | USCG/DOI |
| hazardous area classification shortcomings | USCG/DOI |
MOUs and MOAs are seldom effective regulatory solutions as they are often unclear or inconclusive, and tend to be more about the interests of the regulator and protecting turf. They also do nothing to ensure a consistent commitment among the regulators. In the case of the US OCS program, BOEM-BSEE have a greater stake in the safety and environmental outcomes given that offshore energy is the reason for their existence. That is not the case for any of the other regulators identified in the graphic above.
The contributing factors listed in the Macondo table are not clearly or effectively addressed in the current MOAs for MODUs and floating production facilities.
Helicopter safety is another example of MOA inadequacy. Three offshore workers and a pilot died in December when a helicopter crashed onto the helideck of a GoM platform during takeoff. The most recent Coast Guard – BSEE MOA for fixed platforms added to helideck regulatory uncertainty by assigning decks and fuel handling to BSEE and railings and perimeter netting to the Coast Guard. This is the antithesis of holistic, systems-based regulation.
Posted in accidents, conferences, IRF, Offshore Energy - General, tagged BSEE, fatalities, incident data, IRF, performance measures, WWNO on May 16, 2023| Leave a Comment »
Among the more important workstreams of the International Regulators’ Forum, a group of offshore safety regulators, are country performance data which provide a means of measuring and comparing offshore safety performance internationally. As we near the midpoint of 2023, the last data posted are for 2020. This lag makes it difficult to assess current trends and risks.
In addition to more timely updates, there are significant holes in the IRF data sets. For example, per IRF guidelines fatalities associated with illnesses or “natural causes” are not counted; nor are helicopter incidents that are not in the immediate vicinity of an offshore facility. Also, incidents associated with geophysical surveys, many pipeline segments, and (inexplicably) subsea wells and structures are excluded (see excerpts below).
Excerpts from IRF Performance Measurement Guidelines:
Perhaps the IRF can consider these and other data collection and publication issues at their next conference. Because voluntary incident reporting schemes have always suffered from incomplete or selective reporting, the regulators have to drive incident data collection and transparency.
Parallel US concerns about offshore incident data: After a review of BSEE fatality data provided in response to a Freedom of Information Act request, WWNO reported that “nearly half of known offshore worker fatalities in the Gulf of Mexico from 2005 to 2019 didn’t fit BSEE’s reporting criteria.” They noted that 24 of the 83 known offshore worker fatalities during that period were classified as “non-occupational.” (As previously posted, the rash of “natural cause” deaths (12) at Gulf of Mexico facilities in 2021 and 2022 is particularly troubling and warrants further investigation.)
Bud's Offshore Energy (BOE) 