The Health and Safety Executive (HSE) Offshore Divison (OSD) aims to ensure that risks to workers in the UK’s oil and gas extraction industries are properly controlled. With around 25,000 people employed directly in these sectors, this is a challenging task. Since the early 1980s the UK has been one of the world’s largest producers of offshore oil and gas. Undertaking this task on the UK Continental Shelf are some 250 offshore installations, of which 52 are fixed normally unmanned structures and 31 are mobile drilling units.

Britain’s safety laws differ from those of most other producing nations in that they consider an installation owner or operator to be the primary party on whom legal duties are imposed – or ‘dutyholder’ – rather than the licensee, as in Norway and the USA. Thus, in Britain, drilling contractors have equivalent responsibilities to oil and gas producing companies.

A key feature of our regulatory regime is the safety case. This concept requires every dutyholder first to demonstrate, in document form, that proper safety arrangements, including an effective management system, are in place on their installation and second to have that ‘case for safety’ accepted by HSE to permit operations to start or continue.

Offshore Division
This year, OSD is focusing on behavioural issues, looking specifically at management risks; in particular how jobs are organised; the quality of supervision and monitoring of work activities and how risks are assessed before the job. This project aims to eliminate fatalities in deck and drillingrelated operations.

Currently, we are preparing to look at integrity verification for safety critical plant and equipment – maintenance, inspection, etc. HSE is concerned there may in some cases be inadequate maintenance of ageing platforms and insufficient management of third-party equipment and is challenging the industry to ‘raise its game’ in these respects.

This is a major hazards prevention programme, whilst the behavioural project mentioned above is mostly focussed on ‘nonescalatable’ health and safety. Every offshore regulator needs to strike the balance between major hazard prevention and occupational safety improvements.

The industry must face up to the need to improve health and safety standards whilst it maintains revenue. HSE is a member of PILOT, a Department of Trade and Industry (DTI)-led forum that addresses the sustainability of UKCS production. PILOT aims to secure steady and high direct investment (£3 billion/year) and to maintain hydrocarbon production (1 million barrels of oil equivalent/day) to 2010. OSD is paying particular attention to the effectiveness of safety management systems during major restructuring exercises when labour costs are lowered. Some of the issues that characterise the future challenges for the UK offshore sector are:

• Challenges to ‘known’ standards and applying the ‘as low as reasonably practicable’ principle to risk during the reduction of development costs through technical innovation;
• Maintaining the integrity of
  main structures and safety critical plant whilst extending the use of ageing infrastructure beyond design life; and
• Providing a sense of ‘future’, by competing against other, cheaper provinces for investment and encouraging new people into the industry.

Furthermore, the cyclical nature of the drilling business produces further future challenges. Contractors typically discharge staff and re-hire in the upturn, with foreseeable consequences on competence and working practices. OSD pays particular attention to start-up programmes for long-term stacked rigs and has taken enforcement action to ensure appropriate standards are maintained.

Safety performance
The performance of the sector is mixed, comparing favourably with agriculture and construction, but less favourably with the onshore chemicals and manufacturing sectors.

The steady decline in ‘over-threeday’ injuries is also matched by a decline in dangerous occurrences (events with no injuries, though potential existed). The latter includes hydrocarbon releases, with major releases now in single figures per year for the first time since records began in 1993. However, the high level of, and possibly slightly upward trend in, major injuries is both worrying and unacceptable.

I see preventing major incidents as the greatest corporate challenge for the industry. Most of OSD’s resources, both in its science and innovation work, as well as on the front line, goes into the major hazards prevention programmes. Since 2000 our strategy has been to focus effort against high-risk activities in health, occupational safety and major hazards through six project-based key programmes aimed at reductions of:

• 50% in major and significant hydrocarbon releases;
• 25% in shuttle tanker ‘loss of station keeping’ events;
• 10% in injuries and ill-health arising from manual handling operations;
• 15% in reported slips, trips and falls from height; and
• 15% in reported incidents/dangerous occurrences involving lifting and mechanical handling.

Indications are that these targets will be achieved and OSD’s efforts here have been acknowledged by industry to be the catalyst for the improved performance.

Despite improvements, major gas releases still occur on a fairly regular basis (though currently down to less than one a month) and a number of prosecutions continue to be taken. Overall though, the hydrocarbon leaks programme has been a very effective initiative. However there are other indications that major hazard risks – such as high maintenance backlogs, sometimes on safety-critical plant; inadequate staff levels in high-risk activities; infringements of permit to work systems – are not reducing.

Partnership
OSD has revised its strategy to simplify and streamline the suite of key programmes, and to encourage a greater partnership with dutyholders, including the supply chain, in acknowledgement of increasing contractorisation, and the workforce in addition to HSE’s regulatory role.

In meetings with stakeholders we have agreed to converge on a vision that aims to make the UK the safest offshore province in the global oil and gas production industry by 2010. This from a starting point, as measured in occupational safety performance (not a complete measure, by any means), of the UK being some way behind the global best performers. This vision has been adopted by DTI under the PILOT programme (see above). I see this as an important acknowledgement that safety has a place in the industrial value chain. Indeed, we calculate significant cash benefits accruing to industry should these shared targets for improved safety performance be realised.

Although the means to achieving this vision are yet to be agreed, the core concept is that real and dramatic improvement can only be secured through partnership between employers, trade unions and the regulator. It is too early to say whether this approach is succeeding, though there are early indications that active co-operation is working in areas where there is agreement of the importance of reducing risks, as in the hydrocarbon leaks reduction programme.

However, the key factors to the success of the programme include:

• The commitment of industry key players who have the drive, authority and reputation to carry others with them;
• Close involvement of HSE staff to recognise opportunities and work actively with the grain of external developments;
• Securing acceptance that HSE’s role can be compatible with working in partnership. In this regard, our published Enforcement Policy and Enforcement Management Model (an inspectors’ toolkit, or guide to appropriate action in particular circumstances) are extremely helpful in establishing both consistency and transparency: bridging the ‘trust gap’ between regulator and industry;
• Not undermining HSE’s freedom to take independent action to target risks, follow through and meet raised expectations;
• Balancing effort between major hazard prevention, occupational safety and health; and
• Establishing meaningful benchmarks and performance measures.

We have found that a partnership approach is more likely to seed itself in a coherent industry such as the offshore sector. The approach can be used to challenge other sectors to take similar, proportionate action. Conversely, failure to see the strategy through will undermine the potential for wider impact.