The offshore oil and gas industry is, perhaps unsurprisingly, one of the most dangerous sectors in which to work, with all sorts of risks facing employees on a daily basis.
This is why it’s so essential that companies in this particular industry know exactly what their responsibilities are where health and safety is concerned, so all the risks have been mitigated against and they have done all they possibly can to ensure that their workers have a safe environment in which to operate.
But even with all the appropriate preparation, risk assessments and measures of control in place, accidents can still take place, as evidenced recently (May 20th) by the handing down of a £1.16 million fine to a company following a Health and Safety Executive (HSE) investigation into a high pressure gas release that took place on Boxing Day 2015.
Aberdeen Sheriff Court heard that on December 26th, a platform suffered a rupture in an eight-inch diameter high-pressure pipework in Module 14, as a result of corrosion under insulation issue, which saw more than two tonnes of high-pressure methane gas to be released instantaneously.
Widespread and significant damage was caused as a result, taking place while the majority of the 100 people on the platform were in the accommodation block, ready for a festive meal - which luckily meant they were away from the source of the blast.
The company pleaded guilty to breaching regulations set out in the Health and Safety at Work Act 1974, which resulted in the huge fine.
The HSE investigation found that the company hadn’t undertaken any suitable and sufficient inspections of the pipework that would have allowed it to identify risks and prevent the incident from taking place.
Such failures led to those on board possibly being exposed to risk of serious personal injury or death from explosion and fire, also resulting in the HSE serving it with an improvement notice in January 2016. This required the company to bring in an effective hydrocarbon pipework inspection and maintenance procedure.
Ahmedur Rezwan, Inspector with the HSE, commented: “This incident is a further reminder of the ever-present hazards in oil and gas production, that if not rigorously managed can easily result in a potentially life-threatening event.”
“Corrosion under insulation is a well-known risk and this incident should not have occurred. During any normal period of operations, personnel could easily have been working in or transiting through Module 14, and they would almost certainly have been killed or suffered serious injury. The timing of the incident and the fact that the gas did not ignite was fortuitous.”
What is corrosion under insulation?
Corrosion under insulation (CUI) is a big problem for the petrochemical industry, a form of corrosion that happens because of a build-up of moisture on the outside of insulated equipment. It has numerous causes and if it goes undetected it can lead to the shutdown of process units, facilities or even result in a safety incident, as evidenced above.
In order to help prevent CUI from happening, it’s essential that companies monitor the condition of equipment and piping so they know when it should no longer be in use. This will most likely work out more cost-effective than repairing or replacing any damaged equipment.
There are several ways in which CUI can be inspected, whether it’s by stripping the insulation off the equipment to see what’s going on (which will take some time and prove quite costly) or by non-destructive testing through the use of radiography or pulsed eddy currents, which highlights there’s no need to strip the insulation.
How the HSE regulates the offshore oil and gas sector
As the HSE explains, major hazard risks that unfortunately could result in serious injuries and fatalities to offshore workers are well known - fire and explosion linked to hydrocarbon releases and loss of structural integrity and stability. The precautions against these are also well known and both the HSE and the industry as a whole have made attempts in the consistent management of these risks across the entire sector.
However, this work has only been partially successful and a consistent focus is lacking to make sure that the required improvements are applied sector-wide, improvements that are then sustained.
In the past, the HSE has focused on operators as those responsible for the installation, but the organisation’s latest strategy recognises that this isn’t correct since contractors employ 85 per cent of the workforce. The most up-to-date strategy looks to make sure that anyone with influence over conditions that workers are exposed to contribute to making sure that the risks are properly managed and controlled.
The proper maintenance of production facilities and the subsea pipeline network is required in order to prevent major accidents from taking place. Achieving strong health and safety standards will reduce the risk of pollution incidents and contribute to the UK’s energy resilience while protecting workers at the same time.
While significant investment has been made in new infrastructure, a lot of the system structures is ageing and, of course, is continuously exposed to harsh environments and heavy usage. Around 50 per cent of offshore platforms have gone past their original design life and in order to ensure asset integrity, work must be carried out to make sure that corrosion and so on haven’t affected the pipelines’ structural strength, as well as that of equipment and installations.
Planned interventions by the HSE
The HSE targets inspections based on the inherent hazards of different installations, as well as the ability on the part of the owner to manage risk and the impact that combined operations might have. This means that in some years, operators may have no interventions but each one will be subject to planned visits at least once every three years.
The focus will be on major hazard risks, rather than personal safety issues (aside from those relating to crane operations, since failure could be a hazard precursor and mechanical handling on drill floors). The aim of such interventions is to make sure that major risks are being properly managed and where issues are identified, action will be taken to remedy the problems.
Management systems will be looked at to make sure they’re appropriate, applied and properly understood by those responsible, with regular reviews to be scheduled. If any technical failures are discovered, the causes will be identified and inspectors will work to make sure that the failure is remedied and that its causes are identified and rectified as well.
Enforcement action by the HSE
This is taken in order to protect workers against injury and steps may be carried out to prohibit activities when circumstances arise that are judged to put people at risk of serious personal injury.
Improvement notices may be handed down if there’s a contravention of a legal requirement or if circumstances have been contravened that make it likely that this will continue or be repeated.
This service is not meant to be viewed as a punishment, but rather an opportunity for operators to ensure they’re complying with legal requirements. Failure to comply will result in a referral to the courts.
For advice relating to GWO basic safety training, get in touch with the HFR Solutions CIC team today.