Frequently Asked Questions
Health and Safety in the UK Oil and Gas Industry
Q1. What was Piper Alpha?
A. Piper Alpha was a large North Sea oil platform that started production in 1976.
It produced oil from 24 wells. In its early life it had also produced gas from two wells.
It was connected by an oil pipeline to Flotta and by gas pipelines to two other installations.
Q2. Who operated Piper Alpha?
A. At the time of the disaster, the Operating company was Occidental Petroleum (Caledonia) Ltd ("OpCal"), a wholly owned subsidiary of Occidental Petroleum Corporation. In July 1991 Elf / Enterprise bought Occidental's UK assets and acquired control of OpCal. In 1996 Elf / Enterprise demerged and OpCal became a wholly owned Elf Group subsidiary and is now dormant. The Elf Group subsequently merged with TotalFina to form TotalFinaElf (now re-branded Total). These companies were not involved with Piper Alpha at the time of the disaster.
Q3. What happened at Piper Alpha?
A. On 6 July 1988 there was a massive leakage of gas condensate which was ignited causing an explosion which led to large oil fires. The heat ruptured the riser of a gas pipeline from another installation. This produced a further massive explosion and fireball that engulfed the Piper Alpha platform. All this took just 22 minutes. The scale of the disaster was enormous. 167 people died, 62 people survived.
Q4. What caused the leak?
A. It is believed that the leak came from pipe work connected to a condensate pump. A safety valve had been removed from this pipe work for overhaul and maintenance. The pump itself was undergoing maintenance work. When the pipe work from which the safety valve had been removed was pressurised at start-up, it is believed the leak occurred.
Q5. What was industry's initial response?
A. As details of the causes of the disaster emerged every offshore Operator undertook immediate wide-ranging assessments of their installations and management systems. These included:
The Industry invested in the order of £1 billion on these and other safety measures before Lord Cullen's Public Inquiry into the disaster reported.
- Improvements to the "Permit to work" management systems
- Relocation of some pipeline emergency shutdown valves
- Installation of sub sea pipeline isolation systems
- Mitigation of smoke hazards
- Improvements to evacuation and escape systems
- Initiation of Formal Safety Assessments
Follow this link for details of what these improvements entailed.
Q6. What was the Cullen Inquiry?
A. Lord Cullen chaired the official Public Inquiry into the disaster in two parts. The first was to establish the causes of the disaster. The second made recommendations for changes to the safety regime.
Q7. What part did Industry play?
A. UKOOA, the Industry's Trade Association, was represented throughout but did not participate in Part I, which was to establish the cause of the disaster. It did, however, play a full role in Part II, which considered measures to prevent future major accidents, and provided 34 expert witnesses.
Q8. When was the Cullen Report published?
A. Lord Cullen commenced the Public Inquiry in November 1988 and his Report was published in November 1990.
Q9. What did the Cullen Report conclude?
A. Lord Cullen made 106 recommendations. Responsibilities for implementing them were spread across the regulator and the Industry. The Health and Safety Executive (HSE) was to oversee 57. The Operators were responsible for 40. Eight were for the whole industry to progress and the last was for the Standby Ship Owners Association.
Q10. What was the industry's response?
A. The Industry accepted all 106 recommendations. Many of them came as a direct result of industry evidence.
Q11. How quickly did the Industry act upon the recommendations?
A. Industry acted urgently to carry out the 48 recommendations that Operators were directly responsible for. By 1993 all had been acted upon and substantially implemented.
At the same time the Health and Safety Executive (HSE) developed and implemented Lord Cullen's key recommendation: the introduction of safety regulations requiring the Operator/Owner of every fixed and mobile installation operating in UK waters to submit to the HSE, for their acceptance, a safety case.
The Safety Case Regulations came into force in 1992. By November 1993 a safety case for every installation had been submitted to the HSE and by November 1995 all had had their safety case accepted by the HSE.
Q12. What is a safety case?
A. The Offshore Installations (Safety Case) Regulations, which came into force in 1992, require the Operator/Owner (known as the 'duty holder') of every fixed and mobile installation operating in UK waters to submit to the HSE, for their acceptance, a safety case.
Safety cases are also required by the HSE at the design stage for fixed installations and when installations are involved in combined operations (for example, in temporary drilling or well activities) or are decommissioned.
The safety case must give full details of the arrangements for managing health and safety and controlling major accident hazards on the installation.
It must demonstrate, for example, that the Company has safety management systems in place, has identified risks and reduced them to as low as reasonably practicable, has introduced management controls, provided a temporary safe refuge on the installation and has made provisions for safe evacuation and rescue.
The safety case is a very comprehensive piece of work. Preparing, revising and updating the Safety Case whenever needed throughout the full life cycle of an installation make considerable demands on the duty holder.
The HSE is currently reviewing the Safety Case regime, in consultation with the Industry. Several workshops have already been held on the subject which will also be the focus of a major conference this autumn. Formal consultation will be issued next year.
Q13. What is a temporary refuge?
A. The temporary refuge is a specially designated area on board every offshore oil and gas production platform which is designed to ensure that personnel can muster in safety for a period of protection while an incident is being assessed and a decision taken on whether or not to abandon the installation. The temporary refuge is equipped, amongst other things, with command, communication, monitoring, mustering and medical facilities.
Q14. What health and safety legislation applies offshore?
A. Offshore safety regulation recognises that there may be particular hazards in the offshore environment that need special consideration. There are therefore four major sets of UK regulation applicable to the industry's operations.
There are earlier offshore -specific regulations dealing with first-aid, safety representatives and safety committees, and safety zones. The offshore industry is also covered by general UK legislation addressing health and safety concerns common to all industries, and which are applicable both on and offshore. Such legislation includes the Management of Health and Safety at Work Regulations 1992, the Control of Substances Hazardous to Health Regulations updated in1999 and the Noise at Work Regulations 1989.
- The Offshore Installation (Safety Case) Regulations 1992 - these require all fixed and mobile offshore installations, operating in UK waters to have a safety case which must be accepted by the Health and Safety Executive. The safety critical elements on installations must be verified as suitable by independent and competent people.
- The Offshore Installation and Pipeline Works (Management and Administration) Regulations 1995 - these set out requirements for the safe management of offshore installations such as the appointment of offshore installation managers (OIMs) and the use of permit-to-work systems;
- The Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995 (PFEER) - these provide for the protection of offshore workers from fire and explosion, and for securing effective emergency response;
- The Offshore Installations and Wells (Design and Construction, etc) Regulations 1996 - These are aimed at ensuring the integrity of installations, the safety of offshore and onshore wells, and the safety of the workplace environment offshore.
In the UK, safety legislation is "goal-setting" rather than prescriptive. The legislation sets out the objectives that must be achieved, but allows flexibility in the choice of methods or equipment that may be used by companies to meet their statutory obligations.
Q15. How are the regulations enforced?
A. The Health and Safety Executive's (HSE) Offshore Safety Division employs a team of inspectors who are responsible for enforcing both the offshore specific regulations and the general safety legislation common to all industries. Their work includes regular inspection visits to offshore installations. They will investigate safety incidents, and prosecute if necessary.
Q16. How is the workforce involved in safety?
A. The Offshore Installations (Safety Representatives and Safety Committees) Regulations, which came into force in 1989, provided a voice to the offshore workforce in the health and safety of their installation. Members of the offshore workforce have the right to elect, by secret ballot every two years, a safety representative to represent them in dealings with the installation management on health and safety and to establish safety committees on each platform.
There are approximately 1,200 elected Safety Representatives that cover some 250 installations and 25,000 staff. The Operator has a duty to ensure and pay for the training of the Safety Representatives.
Secondly, the workforce is involved in developing the Safety Case for an installation. The Safety Case Regulations introduced in 1992 require the Operator both to consult with the workforce when preparing the Safety Case and to make copies of the accepted Safety Case available to them.
Safety Representatives have made and continue to make a valuable contribution to safety offshore. For example, Safety Representatives from installations across the UKCS are actively engaged with the Industry's Step Change in Safety campaign, via the Elected Safety Representative network set up to improve exchange of information and share best practice.
Q17. How are Safety Guidelines established?
A. Lord Cullen recommended that Industry specify the standards used to comply with goal-setting regulations. UKOOA publishes guidelines in accordance with this recommendation which are usually developed with other stakeholders, such as the Health and Safety Executive (HSE) and other Trade Associations. The guidelines are designed to identify and assess key areas of risk and provide guidance on the measures and procedures most suitable for controlling those risks.
The "goal-setting" approach to safety legislation differs from the prescriptive style in that rather than being given a fixed check list of things that must be done to meet a statutory requirement, companies can choose the best methods or equipment available at the time. UKOOA guidelines aid this process by promoting best practice across the industry.
Q18. What impact are the Industry's efforts having on safety performance?
A. The chart below shows the safety performance of the UK oil and gas industry since 1989/90 in terms of the frequency of all reported injuries (including fatalities).
Source: Step Change in Safety
The chart indicates that following a significant fall in the frequency of injuries between 1989 and 1995, the Industry's safety performance appeared to deteriorate in the latter half of the decade.
The Industry was concerned that its earlier successes were not being sustained and launched the Step Change in Safety (www.stepchangeinsafety.net) initiative in September 1997. The campaign was to refocus the safety effort and set an ambitious target of delivering a 50 per cent improvement in the whole industry's safety performance over the following three years.
Since 1997, the industry's safety record has shown some improvement. The all-injury frequency rate across the industry has been reduced by nearly 40 per cent. Some companies have reported an 80 per cent improvement during this time.
The Health and Safety Executive (HSE) publishes all health and safety statistics relating to the UK oil and gas industry on its website at www.hse.gov.uk/hid/osd/hsr1002/index.htm
Q.19 What is the Industry currently doing to improve its safety performance?
A. It is a tragic fact that people are still getting hurt or losing their lives in our industry. Reflecting the priority that safety must take in the sector's operations, Industry leaders gave an undertaking in 2002 to ensure that by 2010, "the UK is the safest place to work in the worldwide oil and gas industry". This undertaking was incorporated into the list of industry objectives for PILOT, the joint Government Industry initiative to prolong UK oil and gas production through improved competitiveness.
The Step Change Leadership Team was set up under PILOT, bringing together senior managers from operators and contractors, as well as senior representation from the HSE and the trade unions. Its role is to steer Step Change towards the PILOT vision and to drive the Step Change agenda with individual leaders personally taking responsibility and accountability for the delivery of each safety related initiative.
A survey of UKOOA member companies on accident statistics for 2002 shows a 20 per cent improvement in major and over-3-day injuries per million man-hours.
The Health and Safety Executive (HSE) publishes all health and safety information relating to the UK oil and gas industry on its website at www.hse.gov.uk
Q20. What is Step Change in Safety?
A. Since its launch in 1997, Step Change in Safety has become the UK oil and gas industry's foremost safety forum, drawing together key representatives from across the Industry, from all management levels, in debate and action on safety issues.
Its activities include:
Further information is available on www.stepchangeinsafety.net.
- The harmonisation of man riding hand signals across the industry;
- The introduction of Safety Leadership training;
- An on-line safety site www.stepchangeinsafety.net which, amongst other things, hosts a discussion forum, a calendar of events and downloadable publications;
- The creation of SADIE - the Safety Alert Database and Information Exchange, which allows companies to share safety alerts and learn lessons from incidents;
- The launch of a CD-Rom with a common induction course for new offshore workers, covering 80 per cent of the generic employer induction requirements for the industry;
- A review of the 11 fatalities across the North Sea during the period 2000-2002, to identify common threads and learnings;
- The strengthening of ties and the sharing of good practice between Step Change in Safety in the UK and its Norwegian equivalent Working Together for Safety.
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