Hazard analysis could be problematic in company offshore audits

Charlie Williams is the director of the Center for Offshore Safety, an industry sponsored organization that is dedicated to improving offshore safety in the deepwater Gulf of Mexico. The Center has focused on helping offshore operators create federally mandated Safety and Environmental Management Systems (SEMS) for identifying and mitigating process safety risks. It also has established a program to certify third-party auditors who can evaluate companies’ SEMS programs.

All companies are required to submit their first audit of their safety programs to the Bureau of Environmental Enforcement by November 15, 2013. FuelFix spoke to Williams about challenges companies are having in implementing the new regulations.

FuelFix: What areas do you anticipate will be problematic for companies when the audits are completed?

Williams: We have not seen the audits yet, but I expect that hazard analysis will be one of the areas. Hazard analysis is one of the key processes. You have to identify your hazards and then make sure that you have established barriers against those hazards escalating. It is a really key part of the safety plans and I think it is a place that people are going to want to do more work and have more focus. I wouldn’t be surprised to see improvement plans in those areas. They have hazard analysis now – it is really just raising the level.

FuelFix: What are the challenges in finding suitable auditors capable of evaluating the effectiveness of these safety programs that offshore operators are implementing?

Williams: Almost all of these people have been auditors and may have done onshore audits, because a lot of the process safety began with refineries and chemical processing plants, but they have not worked offshore. The difficulty we have had is two-fold: one is their lack of familiarity with offshore work. For an audit to be effective, you have to understand offshore operations and offshore work, so it’s important to get the auditors familiar with the nature of the work and how it is done.

The second issue is how to audit these systems. Traditional safety audits have focused on process safety, which really is, how to manage running the equipment. We are talking about a higher level of audit, in reviewing how these Safety and Environmental Management Systems (SEMS) plans are working. In SEMS you are looking at the following kinds of issues: how do you manage training people, how do you manage developing your standards, how do you manage your management of change. It is a different level of management system you are auditing, and we have to teach auditors how to think about this management differently than they would for process safety.

FuelFix: What are some issues in the industry post-Macondo that you hope the safety plans will address?

Williams: The expectations of stakeholders have changed – the expectations of the government, and of the public, of the NGOs, because of the realization of how many contractors we use and how much contractors are involved in working offshore. I think even people who were familiar with that became a lot more interested in that relationship and how it works post-Macondo. My message is that one of the key things that safety management does is talk about, how do you manage those contractors and how do you manage that relationship? There is this discussion about a bridging document between your contractor and your operator about how safety is going to be done on this project, on this facility and whose system is going to dominate under certain circumstances and that is all done in advance. SEMS is a really effective tool to manage the contractor-operator relationship and to improve it. That goes to really improve the confidence of the stakeholders in what we are doing.

FuelFix: What future would you ideally like to see for SEMS?

Williams: I am planning to speak at OTC at what I call the journey of SEMS. We have done the auditing SEMS step. Now we want to gain the information and learn from the audits. Then we want to develop good practices from what we have learned from the audits. We want to collect even more information from safety performance indicators and incidents, so we can learn even more. Then we ultimately want to move up to a point where the audits are in the background and we are really working more on the culture, so we are working more on leadership and skills and capabilities of staff and organizations and building and maintaining barriers and processes for those. A lot of people thought about SEMS as an auditing thing – its beginnings are as an audit tool, but it is a progression from auditing to culture.

FuelFix: Are audits a learning tool or an enforcement tool?

Williams: James Watson (the director of the Bureau of Safety and Environmental Enforcement) has said that he wants audits to be a learning tool, and the Center for Offshore Safety wants them to be a learning tool and find areas of improvement. But because we come from a culture of inspections and prescriptiveness, people still have the concern that it is going to be an exercise around finding faults and issuing incidents of non-compliance and not really improving things. We haven’t quite made this psychological change that wants to use this to learn and get better.

But if you have an egregious violation or if you violate the things that are still ‘inc-able’ (issues of non-compliance), you are still going to get written up. Most people understand the psychology that the best thing is to understand those things and to learn from them. What should be enforced is if you don’t improve. What BSEE says they will enforce is if you don’t improve. If you have an improvement plan and then don’t show progress and you don’t follow your plan, then you will have enforcement.

FuelFix: What do you predict will be the offshore safety issues will be five years down the road?

Williams: The issue always is about sustainability, because there is this normal human tendency that we think of things as being programs or initiatives. You start it today and finish it in five years and then you are done. But this is one of those things that will never be done. That is why I have started talking about the journey. We are never going to be done – we are going to continually improve and the proof will be in the results. The proof can only be in the results. Ten years from now we have to be better than five years from now – some people talk about it as a journey of constant unease. When it comes to managing safety, you have to manage it for the long term and you can’t think about it as an initiative where you can stop with what you have already accomplished. It is about capabilities of organizations to manage change and things that need this constant attention and constant improvement. It is not something we are ever going to be done with. That does not mean we are not improving – it just means we have to continually improve.

FuelFix: What do you think is the biggest thing that has been accomplished since the Macondo accident in terms of safety?

Williams: This new focus on safety management has been really powerful. People have understood this from process safety, but there has been a huge focus and a re-awareness on that. These groups that we set up where the industry can work and learn together, like the Marine Well Containment Company or the Center for Offshore Safety – that is a significant and sustainable improvement as well. Some of the regulations and some of the things people have voluntarily put in place, where there is more requirements for professional engineers to review things, third parties to review things, for outside parties to review things – I think we have a substantially better level of assurance and review on things than we have ever had before.

FuelFix: What do you think is the biggest misconception about the state of safety in the Gulf of Mexico?

Williams: I think the biggest misconception is that not much has been done, when there has been a tremendous amount of effort by the industry and by regulators in moving this forward. But evidently, we haven’t done a good job of making people aware of how much has gone into this. There has been more collaboration, cooperation and improvement in working together to make things better than I think we have ever done before.