A team of process safety engineers have written and published a potentially life-saving guidance document based on extensive research into non-compliance letters sent to duty-holders in the UKCS by the UK Health and Safety Executive (HSE).
David Jamieson, Founder and MD of Aberdeen-based process firm, Salus Technical, led his team on the project which saw them analysing 147 non-compliance letters which the HSE sent to duty-holders in 2019. The end-result is a guidance document which is available to download, free of charge, from the Salus Technical website: https://salus-technical.com/hse-research-2019/.
Explaining the rationale, Jamieson says, “Each year, the Energy Division of the UK HSE visits over 100 offshore oil and gas installations to carry out inspections on a wide range of topics. If a topic inspection finds poor performance, the HSE writes to the duty holder outlining the action they need to take to improve. The total number of non-compliances each year is public record, but not the detail that lies within. We believe that the detail is where the true value lies – greater understanding and awareness can inform changes to prevent incidents taking place.”
Following the submission of a Freedom of Information (FOI) request to the HSE, the team set about analysing the detail of 147 letters. Crucially, they converted these into a truly anonymous database, removing all reference to duty holders and installations. “This is about learning, not pointing the finger,” adds Jamieson. “It’s also important to note that each one of these non-compliances was resolved by the duty holder prior to the HSE releasing the information, a powerful signal that the industry takes its safety obligations very seriously.”
They went on to produce a guidance document grouped by inspection topic, breaking down the detail of each topic, highlighting common areas of concern, and offering real, actionable advice to prevent major accidents happening in the future.
Entitled, How offshore inspection scores reveal major accident prevention measures, the publication contains a wealth of valuable information which would normally be out of reach to anyone other than the recipient of the individual inspection letters.
Having dedicated significant resources to this project over the course of 2022, the Salus Technical team are determined to ensure that as many industry professionals as possible can access the document.
Jamieson continues, “Many of our findings were recurring, with multiple duty holders in the same year experiencing the same issue. This means it’s more than likely that many others will also be grappling with these, and indeed may potentially be unaware that these are non-compliance issues. If that knowledge is in the public domain, then duty holders have an opportunity to resolve these issues. Learning from others in the industry aligns with Offshore Energies UK (OEUK) Process Safety Leadership principles, and as members of OEUK we are fully committed to these.”
“We have worked hard to produce an engaging, interesting document that shares valuable information and encourages taking action – it’s not a dull safety tome that will gather dust on a shelf! Ultimately, we want to make process safety as straightforward as possible. With that in mind we have tried to make it easy for people to implement changes: we have created a one-page summary for leaders within the industry, and also written assurance checklists, so that any duty holder can easily perform an audit against our findings,” he adds.
The guidance document has been peer-reviewed by a number of senior figures within the industry, including Mark Wilson, Offshore Energies UK’s HSE and Operations Director, who comments, “The insights gained from Salus’s analysis of the Health and Safety Executive’s inspection findings can help to shape and enable new risk-based approaches. This development has the potential to benefit safety performance across the industry.”
“This latest report links to the ongoing work that OEUK and our members have been undertaking – particularly in the areas of hydrocarbon release prevention, maintenance backlog reduction, operational risk assessment and workforce engagement. As an industry, there is no room for complacency. So this kind of analysis ensures that we remain constantly vigilant, maintaining focus on the key areas of health and safety development,” Wilson says.
The findings from the Salus team’s research have been woven into the fabric of their online process safety awareness training course, (https://www.processsafetytraining.com/courses/Process-Safety-Awareness) which launched last year. The on-demand training course covers the fundamentals of managing process safety in high-hazard industries and is designed to upskill personnel with vital knowledge and understanding in a convenient and time-efficient format. Geared towards all personnel working in major hazard industries, and not just those tasked specifically with responsibility for process safety, the content has been written in line with key process safety frameworks from organisations around the world.
Several duty-holders have already signed up, with one of these rolling the course out to their entire workforce.