BSEE is partnering with the Bureau of Transportation Statistics to set up a voluntary near-miss reporting system. The agency has held two public forums and is engaging industry in a number of less formal briefings on their concept. The idea is to ” give the offshore oil and gas industry, other stakeholders and the public an opportunity to discuss the Voluntary Confidential Near-Miss Reporting System and contribute to the development of the system.”
So far, BSEE hasn’t posted a lot on the process online, but it probably will soon. There is a prototype webpage set up for the process, but it appears to be just a placeholder. By every indication, officials want to work closely with industry and the public to make the system work. The public presentations have stressed that the system will help industry and government spot emerging trends and reduce risk.
The definition they use for a near-miss is “A sequence of events and/or conditions that could have resulted in loss. This loss was prevented only by a fortuitous break in the chain of events and/or conditions. The potential loss could be human injury, environmental damage, or negative business impact.”
That covers a lot of territory. Conceivably, it could include:
- Vessels nearly striking platforms
- Dropped objects
- Well kicks
- Lubricating oil that is stopped before reaching the water
- Circumstances causing someone to call a Stop Work
- Poorly slung loads
In other words, the million and one things that could go wrong on a thousand offshore structures.
So what’s not to like? Based on the comments at the meetings, there are pluses and minuses.
Harnessing the incident statistics for a whole industry is a very powerful tool. Big data is a big deal. We are seeing over and over in industry that large volumes of data can produce startling truths and paths to improvement.
It puts the stress on industry trends. Right now, each company is on its own when it comes to near-miss analysis. In other words, I can tell what my company is doing, but I don’t have effective ways to benchmark against the industry or to take advantage of lessons learned on common problems. I may not even know that something is a common problem.
It takes the focus off individual companies. This is a little counter intuitive, but right now, because the window on what the entire industry is doing is limited, the focus is on what each company does. Industry-wide approaches tend to shift the focus onto industry-wide solutions. For example, when we look at the airline industry, which does a lot of benchmarking, we tend to focus on how the industry is addressing safety as a whole. The public’s perception is that the industry is safe. Looking at oil and gas, it is nice that select companies have fantastic safety records, but what the public wants to know is whether the industry is safe and is preventing environmental accidents. This could help, eventually.
GI/GO. Garbage in/Garbage out. What information are we actually collecting? If it turns out to be a free-for all of anonymous complaints without enough details to do root cause analysis, it will be a colossal waste of time.
Will it really spot trends – If a million and one things offshore could be considered a near-miss, we could wind up with a million and one unrelated data points. It doesn’t tell you anything meaningful.
Massive potential for confusion – We already have the following:
- Stop Work policies calling on workers to speak out on scene if an unsafe situation exists.
- Individual company near-miss reporting programs
- Near Miss statistical programs from IADC and the COS.
- Coast Guard whistle blower program
- BSEE whistle blower program
- BSEE minor incident reporting (spills that don’t reach the water, for example).
Now we are adding yet another program calling on workers and companies to report incidents. The procedures for reporting a safety concern could become more confusing than an IKEA instruction manual.
It will look really ugly for a while. Those of us involved in the post-OPA 90 years know that one of the first results was that industry became very scrupulous about reporting every spill and preventing every skills. Unfortunately, because reporting had been lax, the first few years after OPA 90 showed a huge increase in spills (because they were how being reported) even as the industry was showing respectable progress in reducing spills. Because this program will focus on data that has not been publicly reported in the past, industry could look dangerous and reckless until the data normalizes.
Finally, there is one issue that bothers me in particular. After the Macondo incident, I thought we were searching for leading indicators that could prevent another catastrophic failure. We don’t know what those indicators are, but experts are fairly sure that Macondo was not caused by poorly executed slip, trip and fall programs or any of the other occupational safety programs that industry has in place. This program could very easily generate mountains of data and cost countless man-hours over common HSE near-miss incidents. But will it do anything to prevent the next catastrophic failure? Statisticians would say “we won’t know until we have the data,” But it looks a little like we are just kicking the can down the road five or six more years.