STRENGTHENING OFFSHORE SAFETY CULTURE- A SUMMARY OF THE TRANSPORTATION RESEARCH BOARD SPECIAL REPORT 321

MARTIN ROBB

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• The US National Academies completed a Framing Study of the Offshore Oil and Gas Industry’s Safety Culture;

• Work was related to the Macondo well blowout; commenced in March 2014, published 2016;

• Safety Culture “Factors” identified echo those of BSEE (one of the US Offshore Regulators) and may be incorporated into API RP 75;

• Includes several detailed recommendations for the Oil and Gas Industry.

SUMMARY

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• Bureau of Safety and Environmental Enforcement (BSEE) released Safety Culture Policy Statement, May 2013; defines safety culture as,

“The core values and behaviors of all members of an organization that reflect a commitment to conduct business in a manner that protects people and the environment”• Adopts nine (9) characteristics of a robust safety culture (details next slide):

– Leadership commitment to safety values & actions, – Respectful work environment, – Environment for raising concerns, – Effective safety and environmental communication, – Personal accountability,

• Report recommends this definition be adopted by regulators and industry.

DEFINITIONS

– Inquiring attitude, – Hazard identification and risk

management, – Work processes, and – Continuous improvement.

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• Leadership commitment to safety values and actions —Leaders demonstrate a commitment to safety and environmental stewardship in their decisions and behaviors. Leaders visibly demonstrate this commitment through how they allocate resources within the organization and prioritize safety relative to production.

• Respectful work environment—Trust and respect permeate the organization, with a focus on teamwork and collaboration.

• Environment for raising concerns—A work environment is maintained in which personnel feel free to raise safety and environmental concerns without fear of retaliation, intimidation, harassment, or discrimination.

• Effective safety and environmental communication—Communications maintain a focus on safety and environmental stewardship. Knowledge and experience are shared throughout the organization.

• Personal accountability —All individuals take personal responsibility for process and personal safety, as well as environmental stewardship.

DEFINITION OF SAFETY CULTURE: CHARACTERISTICS 1

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• Inquiring attitude —Individuals avoid complacency and continuously consider and review existing conditions and activities in order to identify discrepancies that might result in error or inappropriate action. Workers are expected to question work practices as part of everyday conversations without hesitation.

• Hazard identification and risk management—Issues potentially impacting safety and environmental stewardship are promptly identified, fully evaluated, and promptly addressed or corrected commensurate with their significance.

• Work processes —The process of planning and controlling work activities is implemented in a manner that maintains so that safety and environmental stewardship are maintained while ensuring use of the correct equipment, used in the correct way, for the correct work.

• Continuous improvement —Opportunities to learn about ways to ensure safety and environmental stewardship are sought out and implemented.

• The report contains sections that explain the research behind each of the selected factors and some of the actions that may be adopted to build these, such as After-Event Reviews (for “Continuous Improvement”).

DEFINITION OF SAFETY CULTURE: CHARACTERISTICS 2

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• 3 incidents that included human performance failings highlighted in report:– Piper Alpha (1987): Two factors (human error and design) contributed to the severity of the

incident;– Montara (2009): Company’s systems and processes deficient; staff of poor competence;

regulatory regime inadequate;– Deepwater Horizon (2010): Systematic failure in risk management.

• Safety culture improvements:– Not simply responses to major incidents – noted as a popular idea – these changes are usually

short-lived;– Improvements are based on sustained practical measures.

MAJOR INCIDENTS AND SAFETY CULTURE

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• Risk-taking remains prevalent;• “Blame culture” focuses on the proximal causes of safety failures e.g. human error;• Fragmented nature of the industry in GoM region, e.g:

– Diverse levels of leadership commitment to safety;– Differing safety attitudes due to company sizes, history, cultural backgrounds & education,

language – safety subcultures;– Multiple relationships between companies make consistent practice difficult;– Cyclic nature of industry; high staff turnover; – No single industry body represents all companies.

• Competitive industry;• Safety culture not a part of the regulations.

IDENTIFIED “INDUSTRY” BARRIERS TO IMPROVED SAFETY CULTURE

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• Industry should develop:– An industry vision statement;– A decision-making process that weighs risks and shares information across industry;– A specific body dedicated to safety leadership;– Center for Offshore Safety (COS, formed after Deepwater Horizon) nominated for this role –in

which it would be made independent of API;– Working in conjunction with regulators, map out the mix of regulations & voluntary actions

needed to foster safety culture.

RECOMMENDATIONS FOR INDUSTRY – 1

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• Safety Culture to be added to API RP 75;• Operators and contractors should regularly assess their safety culture as part of SEMS:

– Measures tailored to the industry, including;• Use of leading and lagging indicators, and• Quantitative and qualitative measures;

– Include some standardized elements, to facilitate benchmarking;– Develop internal expertise in these areas (over time).

• “To strengthen and sustain safety culture, company senior leadership must commit to and be personally engaged in a long and uncertain safety culture journey”.

RECOMMENDATIONS FOR INDUSTRY – 2

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• Regulating bodies (BSEE, Coast Guard and Pipeline and Hazardous Materials Safety Administration) should develop Memorandum of Understanding;

• Define the data needed to identify accident precursors;• Champion the 9 elements of safety culture and develop guidance to promote;• BSEE to facilitate and quality-control industry exchanges and benchmarking;• *SEMS Requirements (made mandatory by BSEE in “SEMS II Rule”, 2013) have already

indicated a shift from minimum standard compliance towards continuous improvement.

RECOMMENDATIONS FOR REGULATORS

*Safety and Environmental Management System

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• Do aspects of an effective safety culture matter differentially for different types of organizations (e.g. operators, contractors, and large and small companies)?

• Do aspects of an effective safety culture matter differentially for different outcomes, including personal safety, design safety, and process safety and leading and lagging indicators (e.g. gas releases)?

• In terms of low-frequency, high-consequence events, how is it possible to identify whether an organization is close to the safety envelope (i.e. the point at which a disaster becomes more likely)?

• What are the best practices (e.g., recruiting, hiring, training) for ensuring that an organization has sufficient competence in its leadership and workforce to create and sustain an effective safety culture?

• Do operations comprising multiple organizations have a safety record that is consistent with the weakest safety culture? the strongest?

AREA FOR FURTHER RESEARCH

OSLO Morten Nilstad Pettersen+47 97 73 17 80mnp@orsconsulting.no

MALMO/COPENHAGENBaris Arslan+46 735 391827 baa@orsconsulting.no

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STAVANGERSverre Nodland +47 922 20 818sno@orsconsulting.no

HOUSTONMartin Robb +1 713 402 8895mro@orsconsulting.no