HSE OFFSHORE HEALTH AND SAFETY STRATEGY TO 2010
Contents OUR VISION ................................................................................................................... 3 OUR MISSION ................................................................................................................ 3 OUR STRATEGIC GOALS ............................................................................................. 3 BACKGROUND TO THE OFFSHORE SECTOR............................................................ 3 KEY FUNCTIONS ........................................................................................................... 4 Annex A - HSE’s UK Stakeholders ............................................................................. 11 Annex B - International bodies ................................................................................... 12
OUR VISION To gain recognition of health and safety as a cornerstone of a civilised society and, with that, to achieve a record of workplace health and safety that leads the world. OUR MISSION To protect people’s health and safety by ensuring that risks in the changing workplace are properly controlled. OUR STRATEGIC GOALS HSE’s continuing goals for the upstream petroleum industry are: • • • • • to prevent major accidents with catastrophic consequences offshore; to secure a step change improvement in injury rates and work related ill health, and consequent days lost from work; to work with industry and support its ambition to make the United Kingdom Continental Shelf (UKCS) the safest offshore sector in the world by 2010; to improve workforce involvement in securing better health and safety performance; to maintain an effective regulatory framework.
In addition, we aim to have the necessary systems, processes and resources in place to deliver our operational goals efficiently and effectively. BACKGROUND TO THE OFFSHORE SECTOR The UK sector is one of the largest producers of offshore oil and gas in the world, and remaining reserves are likely to be equivalent to those produced already. There are about 19,000 people directly employed offshore and about 260,000 other jobs either dependent on or supported by the offshore sector; direct investment offshore by industry was about £8.6bn in 2004. The contribution of oil and gas production to the UK economy is enormous. Interruption of supply, for example through adverse unplanned events such as serious injury, accident or a hydrocarbon escape has a huge financial impact and potential social consequences. Therefore as well as being a high hazard industry, the offshore industry is still an important part of the UK’s social and economic system. Following the Piper Alpha tragedy in July 1988 in which 167 people perished, Lord Cullen made 106 recommendations for improving control of major hazards offshore, all of which were accepted by government. Responsibility for the regulation of the offshore industry transferred to HSE and the pre-existing suite of regulations (so-called prescriptive regulations because they set specific requirements on duty holders) were replaced by goal setting regulations. The corner stone of the current regime is the creation of a safety case for each installation that demonstrates how major accident hazards are adequately controlled and that the management system is suitable. HSE must accept the safety case before the duty holder can bring their installation into use on the UKCS.
In the period after Piper Alpha the offshore industry traditionally comprised large international companies with considerable health and safety expertise, but the industry is now changing. Trade associations are restructuring, companies are amalgamating and assets are being sold to newcomers, many of whom are small and without experience of operating on the UKCS. New technology is being introduced for which there is little or no operational experience. Questions are being asked as to whether ageing equipment should be kept going, reused elsewhere or decommissioned. Environmental concerns, such as demands for complete removal of redundant installations, may also have safety implications. Strategies are being developed to tackle these new risks. HSE’s Offshore Division (OSD) and a supporting policy unit are together working to raise standards of health and safety in the offshore industry. However the Regulator cannot act alone. Responsibility for health and safety lies mainly with those who own, manage, and work in industrial and commercial undertakings. HSE has a role in helping to secure for Britain a safe, clean offshore industry with a long future. The Health and Safety Commission’s (HSC) “Four Point Strategy” includes our commitments to develop closer partnerships with stakeholders and others, to stimulate, orchestrate, audit, assure and promote high standards of health and safety and take appropriate action when things go wrong. HSE will help ensure that risks in a changing workplace are properly controlled and endeavour to communicate the benefits of health and safety to business and society. KEY FUNCTIONS HSE’s offshore plan of work is based on 3 key functions. These contribute to both national (‘Revitalising Health and Safety’, ‘Securing Health Together’) and sector based programmes that deliver HSE’s public sector agreement targets as required by HM Government. Click on the links to view targets for the national health and safety system. For offshore there are additional targets: to reduce by 2010 fatal and major injuries by 50%; and significant hydrocarbon releases by 10% year on year from the 2001/02 baseline. Offshore, our 3 key functions are: 1. 2. 3. 1. securing compliance with the law; maintaining the confidence of our stakeholders; and managing HSE’s resources and systems.
Securing compliance with the law
To secure compliance we will conduct planned inspection programmes and fit for purpose investigations to target high risk and comply with the HSC’s enforcement policy. Our programmes include particular focus on the prevention of major hazard events, and of fatal and major injury accidents. Being clear about our priorities We will explain to our staff and duty holders and other stakeholders what it is we aim to achieve with our resources, and the basis of the work programme. We will maintain the currency of our offshore strategy, and issue plans of work that make plain what it is we shall
be doing in any period of time. We shall make our plans available on the internet, in a biennial poster and through presentations to stakeholders. We will also be clear about what we won’t do, or where functions are better done by others. Intervention Strategy OSD’s regulatory functions include: • • • • visits to offshore installations to inspect activities on and in connection with the installation; investigation of incidents and complaints; assessment of safety cases; and provision of advice, guidance and technical information.
OSD’s approach to inspection combines local knowledge of the duty holder, gained through safety case assessment, inspection and investigation, with overall general knowledge of the offshore sector. We will also look specifically at management systems, in particular how jobs are organised, how training needs are identified and met, the quality of supervision and monitoring of work activities and how risks are assessed before the job. We target, through a key programme, fatal and major injuries associated with heavy lifting on decks and on the drill floor because the risks from such activities are currently very high. We will continually review our impact, when necessary adopting new approaches, to ensure we achieve the outcome of a safer industry. Enforcement Where necessary, formal enforcement action will be taken. OSD’s Inspectors apply the HSE Enforcement Management Model, a framework that helps inspectors make fairer and more consistent enforcement decisions in line with HSC’s Enforcement Policy Statement. This sets out principles that Inspectors should apply when determining what enforcement action to take in response to breaches of health and safety legislation. Enforcement action should be proportional to the health and safety risks and the seriousness of the breach. Strategic partnerships HSE works closely with other UK Regulators responsible for legislation that applies offshore. The work of these Regulators may overlap with those of HSE and the boundaries need to be clear. HSE has Memoranda of Understanding or other arrangements, which define the interfaces with the Maritime and Coastguard Agency and the Marine Accident Investigation Branch on marine activities; with the Civil Aviation Authority and the Air Accident Investigation Branch concerning helicopter safety; and with the Department of Trade and Industry on pollution and licensing issues. HSE is working to establish effective links with the Scottish Office and the Scottish Executive. Prevention of major accident hazards One of OSD’s continuing goals is to ensure that duty holders have appropriate measures and arrangements in place to prevent major accidents with catastrophic consequences offshore. Most of OSD’s resources, including all of its science and innovation effort go into the major hazards preventive programmes.
The cornerstone of our offshore regulatory regime is the safety case. All duty holders must demonstrate, in document form, that proper safety arrangements, including an effective management system, are in place on their installation. The safety case has to be accepted by HSE before operations can start or continue. We will carry out prompt and effective assessment of safety cases; improve consistency of and transparency in assessment; produce revised guidance for the assessment of safety cases and make this available to stakeholders. In operating the safety case regime we will give emphasis to site verification of safety cases and duty holder improvement programmes in line with HSC’s Policy Statement: our approach to permissioning regimes. . A current national key programme for offshore targets major accident hazard risks associated with installation integrity. Occupational health We aim to improve the management of health offshore and ensure compliance with relevant legislation. We will do this best by working with employers to share information and knowledge of the health of the offshore population and giving appropriate guidance to the offshore workforce and their managers. The programme also extends to commercial diving where significant hazards include noise, manual handling and polluted water. We will target musculoskeletal disorders and the incidence of stress offshore. Maintaining an effective regulatory framework Health and safety law is not static. HSE’s legislation and guidance needs to keep pace with modern developments and to react to external influence. It is our practice to evaluate the impact of legislation on health and safety standards and to ensure the lessons of evaluation are used to improve the legislation. Since being introduced all offshore specific legislation with the exception of requirements for verification schemes has been subject to external evaluation. The verification scheme requirements are now also being evaluated. The safety case regime has been in place for over 10 years. We consider that the safety case approach is still fundamentally sound, but in need of updating to meet the circumstances of a mature regime. HSC has consulted stakeholders on proposals to revise the Offshore Installations (Safety Case) Regulations 1992, consulting widely with our stakeholders. The new regulations are expected to take effect in 2005. 2. Maintaining the confidence of HSE’s Stakeholders
We strive to recognise the needs of all of our stakeholders and work in partnership with them, without prejudicing our enforcement role. We will maintain the confidence of external stakeholders, the Department of Work and Pensions and other government departments, including DTI, by implementing suitable plans for national initiatives such as ‘Revitalising Health and Safety’ while at the same time implementing specific programmes for the offshore sector. We will issue regular and useful reports of progress. We will comply with appropriate standards of performance, accountability and propriety for the public sector. We will audit our activities and benchmark against suitable comparators, and inform and work with others in Government to secure our aims.
We will maintain the respect of duty holders and employers by striving to improve our performance in line with HSC’s Enforcement Policy Statement: that our actions are targeted; proportionate; transparent; accountable and consistent. We will operate the charging regime in a fair and consistent manner through front line programmes based on risk. We will operate the safety case regime on a fit for purpose basis. Promoting the benefits of health and safety We will continue to work with industry stakeholders to promote health and safety, but with increasing emphasis on improving the perception of risk; and encouraging communication between regulators, trade unions, trade associations, employers and employees. We will work with stakeholders and other to identify, define, document and promote good practice. We will make it clear that effective health and safety management is essential to sustaining the industry, that an efficient and productive worksite has intrinsically low incident potential and minimal unplanned events. We will emphasise that safety and health are collective responsibilities in which individuals too must play their part. Promoting improvement We will encourage industry to sponsor research to: • • • • • • provide information on risks and how they can be managed; inform our contribution to the development of standards and guidance; develop guidance for inspectors; identify new and developing risks; understand the underlying causes of accidents and incidents; identify and define good practice.
Where necessary, we will conduct this research through collaborative sponsorship arrangements with industry. We will continue to contribute to initiatives that take forward relevant health and safety interests and concerns of the offshore industry. Involving the workforce In accordance with HSC’s statement on worker involvement and consultation we will strive to maintain the confidence of the people we are protecting by meeting with offshore staff and their safety representatives at each installation visit. We will explain the purpose and the findings of the visit and we will listen to the concerns and views of the workforce. We will convene regular meetings with TU representatives, MPs and MSPs to explain our plans and performance. We will respond promptly and diligently to all complaints. We will provide health and safety advice to workers and their families and will use all means to promote safe and healthy working in our sector. We will deal openly and fairly with all those who can assist our aims.
Communicating effectively We will maintain high levels of communication. HSE aims to be an open organisation, sharing information with others where reasonably possible. We will work in accordance with the Data Protection Act and Freedom of Information Act. We will adopt the language, style and type of communication that best fits the need. Internally we will share information with other parts of HSE. Externally we will make the best use of external communications and monitor their effectiveness. We will seek out opportunities to engage stakeholders, establishing and maintaining contacts with organisations involved in the offshore industry (see Annex A). Providing accessible advice and support We will produce guidance in clear and concise English, jointly with stakeholders. When producing publications, where appropriate, we will consult with stakeholders to obtain their views. We will improve the pages dealing with offshore matters on the HSE website to make it easier to use, with clear signposting and hyperlinks. We will disseminate information more widely on the website. We will continue to offer advice and support when we inspect, visit duty holder premises, and otherwise in the conduct of our normal activities. 3. Managing our resources and systems
Our internal organisation and processes will support the preceding objectives by: • Providing the necessary human resources to deliver our objectives by organising our staff to suit our priorities and by anticipating and filling agreed vacancies in a timely manner. We will be clear about the skills and levels of staffing we require. We will provide the necessary business cases, to maintain adequate payroll funding. Being fit for purpose and based on HSE or Directorate processes and guidance wherever appropriate. We will continue to emphasise the role of the authoritative good practice and good engineering judgement in decision-making in preference to quantitative risk assessment. We will use audit and benchmarking to measure our impact. We will collect and monitor sufficient data to manage our staff well and to be effective in regulating our sectors. Providing adequate physical and financial resources to enable staff to work effectively by compiling prompt and well-defended bids for resources and demonstrating value for money in annual outturns. Maintaining effective leadership by demonstrating core values of HSE, and by being clear about our priorities. We will communicate HSE’s objectives and our part in them, to our staff. We will give recognition of good performance and create an enabled, supportive working environment. Maintaining effective staff, now and for the future by providing suitable training and guidance, and monitoring performance and encouraging good performance, professionalism and developing individual potential. We will be fair and open and promote values of diversity and we will correct unacceptable
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behaviour. We will adapt to changing priorities in HSE and in our sector and recruit staff with the skills we need for the future. We will make information available to staff to help them be effective in their jobs. Maintaining close links with the regulatory bodies of other nations operating in the North Sea and worldwide (see Annex B), to reflect the global nature of the industry and the benefits of collaboration.
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Challenges for the future The industry, work force and Regulators have addressed many of the industry’s problems highlighted by Piper Alpha. However new challenges are constantly emerging against a background of pressure to reduce production costs. Many of the large platform-produced oil and gas fields, which were brought into production in the early phases of North Sea development, are now producing at low rates. As the supporting infrastructure ages, often beyond the original intended design life, the industry faces increased costs of maintenance. Although only approximately half of the North Sea reserves have been produced, the remainder are more difficult and more costly to extract. On current trends the industry will be spending more to deliver less oil and gas. As the major oil companies review their portfolios and basis for their continued involvement on the UKCS, smaller companies, who believe they can make a satisfactory profit from remaining reserves, are acquiring some of the older installations. These facilities require high levels of technical knowledge and expertise and are challenging to those who do not have the resources of the major international companies. These smaller companies can also be more responsive to change requiring the regulator to be correspondingly flexible and able to match this responsiveness. Up to 40 fields could cease production and be decommissioned in the next 10 years. Decommissioning is likely to raise both safety and environmental issues with the removal of redundant platforms to shore for dismantling. There is also an ageing workforce. Skills are being lost as those who have been in the industry most of their working lives are now reaching retirement age and staffing levels are reduced to meet cost pressures. Between now and 2008, 50% of workers who are over the age of 45 are likely to leave the industry. Fewer new people consider entering the industry on the UKCS than before. This will also impact on HSE’s ability to maintain existing levels of suitably qualified staff. Specific challenges Since Piper Alpha, real progress has been made to improve safety performance. There has been an encouraging downward trend in over 3 day injury rates, but fatal and serious injury rates remain unacceptably high. Recent initiatives to reduce the number of hydrocarbon releases have produced encouraging results but release rates need to be reduced further. Although the UK oil and gas industry is safer than many other UK industries, the OGP’s (Association of Oil and Gas Producers) report shows that statistically it compares less favourably with some other parts of the world. A number of barriers appear to inhibit improvements in the safety performance on the UKCS. The UKCS has developed relatively sophisticated safety policies and procedures, which have served to improve the technical integrity of installations, yet have failed to instil, at all levels, personal accountability and responsibility for safety. More importantly visible safety
leadership from senior players in the oil and gas industry is not consistent. As a result many workers do not believe it to be the high priority that duty holders claim it to be. There has been some movement towards industry shared systems and standards. It is generally agreed that initiatives, though they would result in industry wide improvements at no commercial disadvantage, have not been well implemented. HSE recognises that it must respond to the challenges of the changing workplace. Efforts to promote and encourage workforce involvement will continue. The workforce should be encouraged to give and accept safety advice and be willing and able to raise safety issues with management and accept responsibility for their own and others safety. By encouraging a more effective partnership with duty holders and the workforce we aim to raise awareness of the importance of health and safety in the workplace, to improve the perception of risk and encourage better communication between regulators, trade unions, trade associations, employers and employees. We will continue to build on this partnership approach by direct involvement in PILOT and Step Change in Safety initiatives and continuing to work with key stakeholder bodies including Trade Associations and Trade Unions. By embracing a co-operative approach, greater improvement can be achieved than by the Regulator acting alone.
Annex A - HSE’s UK Stakeholders • PILOT
A Government/Industry high-level forum chaired by DTI’s Energy Minister. PILOT is made up of senior government officials, including the Scottish Office and Scottish Executive Ministers, with HSE and recognised leaders from the offshore oil and gas industry. PILOT aims to preserve the competitiveness of the UKCS and maximise jobs, investment and commercial opportunities. In 2002 health and safety became one of PILOT’S three priorities for the year and an additional target was added to it’s 2010 vision - to make the UKCS, the safest place to work in the worldwide oil and gas industry. PILOT is “parent” to “Step Change in Safety”. HSE is developing an effective partnership with PILOT and will play an active part in delivering PILOT’s vision without compromising its unique role as regulator and adviser. • Step Change in Safety
Step Change in Safety is the most important safety initiative of the UK offshore industry. Launched in 1997 it aims to deliver a major improvement in the whole industry’s safety performance. Through cross-industry partnerships it is endeavouring to improve health and safety performance in the industry with the target of a 50% reduction in the fatal and major injury rate by 2010. The major trade associations, industry and the trade unions have all signed up to working together and collaborating with HSE to achieve the Step Change targets. Since the start of Step Change there has been an 8% improvement in the fatal and major injury rate and a 38% improvement in the all injury rate. In 2002, Step Change responded to a challenge by HSE to significantly increase its impact. This led to levering into the Pilot programme (see above) a core principle that health and safety are integral to the industrial value chain and good performance is critical to the sustainability of the UKCS. Following the adoption of safety goals into PILOT’s top priorities, HSE was invited to join the Step Change leadership team. • Offshore Industry Advisory Committee (OIAC)
OIAC, an HSC Industry Advisory Committee, brings together management and the unions in the industry and provides a forum in which topical issues can be discussed and taken forward. OIAC aims to encourage participation of the representative organisations in protecting people offshore.
Annex B - International bodies • North Sea Offshore Authorities Forum (NSOAF)
NSOAF is comprised of representatives from Denmark, the Faroe Islands, France, Germany, Ireland, the Netherlands, Norway, Sweden and the UK. It meets annually to exchange information and develop common positions and where appropriate joint initiatives. NSOAF is working to reduce the difficulties due to differences in regulatory regimes and requirements and in particular to make it easier to move rigs between North Sea countries and to harmonise safety training standards. • International Regulators Forum (IRF)
IRF currently comprises eight coastal states that produce offshore oil and gas; USA, Canada, Brazil, Netherlands, Norway, Australia, New Zealand and UK. IRF Strives to share knowledge and information of safety issues and global company performance. The group meets annually and corresponds by e-mail at other times. Current projects are: • • • • • international performance indicators; recognition of outstanding performance; improving safety in lifting operations; international regulators conference.
European Union
In recent years most health and safety legislation has been introduced to implement European directives, mainly to promote minimum standards for health and safety of workers, but also to maintain the single market or protect the environment. There is now a developed body of EU health and safety law, the basis of which is the Framework Directive that established broadly based obligations for employers to avoid and reduce risks in the workplace. We will work with other member states to ensure standards are appropriate for the UK and offshore. • Bilaterals
In addition to collaboration in multinational fora, we have regular bilaterals with major producing neighbours. We have close and effective working links with our Norwegian counterparts, the Norwegian Petroleum Safety Authority through the UK/Norwegian Special Working Group. The meetings allow an exchange of information and the development of common positions and cross border issues. A new UK/Norway Treaty is planned to encourage even closer links. Annual meetings are also held with the Danish Energy Authority and the Dutch State Supervision of Mines. These meetings aim to facilitate agreement on cross border issues.