Spotlight on Steve Walker, Head of HSE's Offshore Safety Division (OSD)
December 2010
1. What is KP4 seeking to achieve and what will the inspections look at specifically?
After 40 years of oil and gas production in the UK sector of the North Sea, more than half of fixed platforms have exceeded their original design life, or soon will. Many are expected to remain operational for the foreseeable future. KP4 has been developed to meet these challenges, and it comprises a new inspection programme for offshore oil and gas installations on the UK continental shelf (UKCS) to ensure the risk to asset integrity arising from ageing and life extension is being adequately controlled. Whereas our previous priority programme, KP3, looked at the ‘here and now’ condition of offshore installations, KP4 takes this one stage further by looking at the ability of the offshore industry to take action now to make sure conditions are safe in the future.
The objectives of KP4 are:
- to raise awareness of the need for specific consideration of ageing issues as a distinct activity within the asset integrity management process;
- to inspect duty holders’ approaches to the management of the risks to asset integrity associated with ageing and life extension;
- to identify shortcomings and enforce an appropriate programme of remedial action where necessary;
- to work with the offshore industry to establish a common approach to the management of ageing installations.
KP4 will run until September 2013. It will also include the development of technical information for operators on ageing installations, promotion of good practice, liaison with industry bodies, and sharing of experience through seminars and workshops.
2. Is this a test of individual installations or companies as a whole?
KP4 will be assessing companies as a whole, but the work will be delivered by a mixture of onshore and offshore inspections. When we go offshore we will focus particularly on offshore installations which are approaching, or have exceeded, their original anticipated design lives, but you need to remember the theme of KP4 is relevant to all installations. The programme will determine the extent to which asset integrity risks associated with ageing and life extension are being managed effectively by duty holders and will place emphasis on the development and promotion of the use of good practice within the industry as a whole.
3. How likely is a re-run of KP3?
When we undertook the 2009 review of industry’s progress following KP3, 18 months on from the landmark KP3 report, we concluded that though the safety of the UK’s offshore installations was improving, the work was by no means complete and will require sustained effort and investment. The chair of HSE, Judith Hackitt, described it as very much a work in progress and that the momentum for improvement must continue. So, offshore asset integrity remains a key priority for OSD.
The format of KP3, with clear inspection templates and consistent ‘traffic lighting’ of integrity topics, lends itself to repeat application to continue assessing industry and duty holder progress. I think, though, that industry needs to do some of this KP3 review work itself. I was very pleased that as part of the KP3 Review in 2009, Oil & Gas UK commissioned independent consultants to undertake inspections using the KP3 templates on some offshore installations, and there is no reason why that approach couldn’t be widely adopted by the industry as part of self-assessment.
4. What can companies do to work more efficiently with HSE?
Along with asset integrity and worker involvement, HSE is looking specifically at the issue of leadership. This is a key issue for all of the UK’s major hazard industries and continues to be given particular emphasis by OSD. Our objective is to see industry leaders demonstrate their commitment to health and safety and ensure the effective management and understanding of major accident risks and their control.
During 2010/11 OSD is developing and trialling an approach of focused interviews with the most senior managers in the industry to assess the range of health and safety information (including process key performance indicators) which the most senior leadership get, how they use it and how they know it is valid and reliable.
5. How has HSE reacted to Deepwater Horizon and Montara and what are the key health and safety issues affecting the UK as a result?
The responsibility for managing risk sits firmly with the operator that creates the risk, but two such major incidents have caused OSD and DECC, as the offshore safety and environmental regulators, to review our regulatory systems. We concluded that we have a robust and sophisticated regulatory system for the offshore industry in the UK, but there are no grounds for complacency. So, we have reinforced our approaches, particularly increasing the peer review of our well design assessments and safety case work, as well as increasing our inspections of well control issues offshore. I see the Oil Spill Prevention and Response Advisory Group (OSPRAG) as being the key group in the UK for learning any lessons from the Gulf of Mexico - OSD is playing a full part in this joint industry/employee/regulators group to see how any lessons can be applied in the UK offshore industry.
HSE has also formed its internal Deepwater Horizon Review Group which aims to review the findings from the investigations into the Deepwater Horizon incident and the Montara blowout, share information which is relevant to the work of HSE and make recommendations as necessary with regard to the control of wells and the safety of the exploitation of offshore oil and gas in the UK.
There has been a lot of interest from other countries about how we regulate offshore safety in the UK. Since Deepwater Horizon, I’ve had significant contact with my counterparts in the United States – the Bureau of Ocean Energy Management, Regulation and Enforcement – as well as other offshore regulators around the world, to share our experiences, to understand the cause of the incident and to see whether there are implications for safety at offshore operations on the UKCS.
6. What role has HSE played in OSPRAG to date?
HSE has been a member of OSPRAG since its inception, and has inspectors on two of its specialist review groups: technical (covering well engineering, operations and control) and European issues.
7. What demands have been placed on HSE from Europe?
Since Deepwater Horizon happened in the Gulf of Mexico, the European Commission has been taking an increasing interest in European offshore safety issues. Over the last six months or so, myself and my colleagues in DECC have spent a considerable amount of time helping Commission officials understand the offshore safety and environmental protection regimes in the UK. I know that individual offshore companies and trades associations like Oil & Gas UK have been doing likewise, and I’m pleased that the Commission now appreciates the maturity and extent of the UK regime. The Commission have recently published their views on what additional matters need to be addressed Europe-wide, and we will working closely with Brussels as their views develop into 2011.
8. What role has HSE played in the IRF (International Regulators Forum) in the light of these incidents?
IRF is a Forum to share knowledge and information of safety regulation issues and global company performance. I represent the UK on IRF, and one of the priority tasks which the UK is taking forward is developing proposals for greater consistency of regulator scrutiny of well control issues. Following the Third International Regulators Offshore Safety Conference, IRF members met and approved a strategic agenda focusing on safety culture and leadership, blow-out preventer integrity and operational issues, performance indicators, operator competency/capacity criteria and use of standards and industry best practice.