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International Regulators’ Forum Country Performance data for 2021 and 2022 have now been posted. Unfortunately, the US fatalities data for 2022 are incorrect. Four workers died as a result of a helicopter crash at the West Delta 106 A platform on 12/29/2022. However, the IRF summary table indicates only one fatality for the year.

Per the IRF guidelines, “Helicopter operations at or near an Offshore Installation” are supposed to be counted. The fatal 12/29/2022 incident clearly happened at the platform’s helideck (photos below).

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Per the BSEE presentation attached below:

Slide 13: “In 2022, the rate of occupational fatalities, reported for activities on facilities where BSEE has primary investigation authority, decreased to being near the historical national average of approximately 0.9 fatalities per 25,000 full time equivalent workers per year. However, considering all offshore risk factors, including helicopter transportation, diving, marine transfer, and COVID-19 exposures, the occupational fatality rate for all OCS activities has remained high since 2019.

Slide 15: “In 2022, the TRIR for both production and construction operations increased to the highest levels recorded since 2010 and remained high even after discounting the impact of COVID-19 illnesses. The TRIR for drilling and well operations, however, remained near their historical lows.

Comments:

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  • Date: 3-4 Oct 2023
  • Location: Perth, Australia
  • Announcement

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:

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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:

  • Exclude Geophysical and Geotechnical surveying and support vessel operations not directly associated with activities at an Offshore Installation
  • Exclude horizontal components associated with incoming and outgoing pipelines and flowlines beyond either the first flange at the seabed near an Offshore Installation or a 500 meter radius, whichever is less.
  • Exclude helicopter operations at or near an Offshore Installation
  • Exclude mobile or floating Offshore Installations being transported to or from the offshore location.
  • Exclude subsea wells and structures.
  • Do not include Fatalities and Injuries that are self-inflicted.
  • Do not include Occupational Illnesses in Fatality or Injury counts.
  • Do not include fatalities that are due to natural causes.

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.)

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An international regulatory colleague brought this puzzling RigZone article to my attention. Quotes:

“From one perspective, one can look at the overall absence of risk – from this perspective, we can easily say that either the United Kingdom’s North Sea or Canada’s Nova Scotian continental shelf is the safest region for offshore oil and gas operations right now,” Robak told Rigzone.

“Canada’s offshore industry accounts for approximately one million barrels per day, and its geographic location along the Nova Scotian continental shelf has been a benefit in that there is little to no risk to its continued operation on a day-to-day basis,” Robak said.

Comments:

Scotian shelf

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Raphael is a highly regarded offshore safety leader and a positive force for continuous safety achievement in Brazil and internationally.

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Upstream image

After 8 outstanding years with Australia’s offshore safety and environmental regulator, Stuart Smith has announced that he will be departing NOPSEMA in September. Stuart was a highly effective CEO and an important contributor to international offshore safety initiatives. Best wishes to Stuart!

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Trinity Spirit FPSO

Six weeks after the Trinity Spirit fire, there is still no public accounting of the number of fatalities and injuries. The initial reports were incomplete and inconsistent, even with regard to the number of people on the vessel at the time of the incident.

SEPCOL, the FPSO operator, no longer has a website and has issued no public statements on the incident since the day afer its occurrence. The company’s status is thus uncertain. The Nigerian Upstream Petroleum Regulatory Commission website only advises that the fire was extinguished as of 4 February.

The absence of timely information on major incidents reflects poorly on the offshore industry and those who regulate it. This is not just a Nigerian issue. It’s past time for an international standard that identifies incident information to be publicly disclosed and specifies the timeframes and methods for releasing this information.

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The above slide is from the excellent presentation that Jan de Jong (Inspector General, State Supervision of Mines, the Netherlands) never got to deliver in Vancouver. As session chair, Jan graciously yielded his time to his panelists.

Jan’s presentation notes the growing importance of international cooperation. This trend has the potential to improve regulatory capabilities, expand data availability and access, reduce regulatory costs through the sharing of resources, reduce costs for industry through greater international consistency and regulatory certainty, and improve international relations.  The Netherlands, Russia, Norway, Cuba, the US, and everyone else should be on the same team when it comes to offshore safety and pollution prevention.  Some near-term suggestions follow:

  • Except where regional conditions dictate otherwise, the same standards should be applied worldwide.  Government and industry should be collectively questioning, testing, and improving these standards. Remember that the goal is continuous improvement, not mere compliance.
  • An international information system should provide for the collection and verification of incident and performance data.
  • Using international data and expertise, a cooperative risk assessment program should be initiated.
  • An organized international audit capability should be established to evaluate operators and regulators.
  • To improve access to expertise and reduce costs, a network of specialists should assist regulators worldwide.
  • Industry training requirements should be uniform and consistently applied, and regulator training programs should be consolidated regionally or internationally.
  • The international research network should be expanded.
  • To ensure that accidents are investigated independently and to minimize the potential for political influences on the investigation process, an international accident investigation capability should be established.
  • The safety culture message should be promoted worldwide.  Successes and failures should be cooperatively examined.

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