The Weekly Reflektion Week 15 / 2020
In last week’s reflection we quoted prophetic words from W.G. Carson in 1981, 7 years before the Piper Alpha disaster.
‘The British authorities’ complacent belief in the superiority of their own regulatory approach will retain even the semblance of credibility only as long as a similar tragedy does not overtake an installation operating in the British sector of the North Sea.’ The quote was a reflection over the loss of the Alexander Kielland in 1980.
Quoting one author’s view of the regulations in the UK is however hardly enough to create an impression that more could have been done to prevent the Piper Alpha disaster with foresight. Was there more information available?
John Paterson in his book ‘Behind the Mask, Regulating the Health and Safety in Britain’s Offshore Oil and Gas Industry’ describes some of the discussions on the UK regulations during the hearings for the Burgoyne Committee in 1980. The Burgoyne Committee was set up to learn from the Ekofisk Bravo blowout in Norway in 1977.
The capsize of the Sea Gem drilling rig in the UK sector of the Southern North Sea on the 27th December 1965 led to the Mineral Workings (Offshore Installations) Act 1971. The main provisions of this act were the establishment of detailed prescriptive regulations, the requirement for certification of the installation by Certifying Authorities and the requirement for an Offshore Installation Manager as focal point for responsibility. The recommendations were not consistent with the Robens Report from 1971 that formed the basis for the UK Health and Safety at Work Act in 1974. The 1974 Act put an emphasis on functional type of regulations for workplace safety.
The detailed prescriptive regulations visualized by the investigation team into the Sea Gem disaster were never really fully implemented in the UK. There were two main reasons for this. The first was the complexity and continuing technology development related to the petroleum industry in the North Sea. The second was the resistance from the industry, which considered that detailed prescriptive regulations would restrict their development and lead to unnecessary requirements that would affect the economics of field developments. The close relationship between the industry and the UK Department of Energy, responsible for both resource development and offshore safety was a factor in the in the regulation development.
The Ekofisk Bravo Blowout on the 22nd April 1977 led to the establishment of the Burgoyne Committee in 1980. The committee’s mandate was to review whether the UK regulatory approach was appropriate. The industry presented its view of the existing regulations through UKOOA (the operators association). They maintained that the existing arrangements for assuring technical integrity were satisfactory, as were the arrangements for assuring safe drilling and production. UKOOA also emphasized the emergency response systems in place through the Sector Clubs. UKOOA emphasized that further regulations were not required since the industry had good control of its activities through, for example, a good Permit to Work System. The Petroleum Engineering Division of the Department of Energy were responsible for offshore safety and they presented their view to the Burgoyne Committee. They were of the view that the prescriptive regulations from the 1971 Act were more appropriate for the offshore petroleum industry than the functional requirements in the 1974 Act. The provisions for major accidents were considered adequate and an example given was that none of the 22 fires on offshore installations in 1978 had developed into a Major Accident. Similarly, blast walls between the accommodation and the process areas had not yet proved necessary. The regulators view could be represented by ‘Nothing has gone wrong so far, therefore everything is OK’.
Failure of the permit system, escalation of a fire and lack of blast wall protection were key factors in the Piper Alpha disaster in 1988. The Cullen Inquiry into the Piper Alpha disaster recommended the implementation of goal setting (functional) regulations and that the operators should make a case for safety for all installations. The case for safety was to be described in an installation Safety Case and was required by the 1992 Safety Case Regulations.
Carson was obviously not alone. Why was this information not acted on? Next week we will consider this question and reflect over what this means for today’s offshore petroleum industry.