Going to Work Offshore – Helicopter Vs. Basket Transfer

No one ever said the commute to work on an offshore oil and gas facility was easy.  Your choices are to fly out by helicopter or transfer from a workboat to the facility, usually in a basket that dangles more than a hundred feet from a crane or by grabbing a rope and swinging from a boat to a platform, Tarzan-style.    Each one has its own risks.

Now one group is trying to quantify the risks of going offshore by helicopter versus going by boat.  According to a new study performed by DNV GL on behalf of Reflex Marine, Enermech and Seacor Marine, the risks from helicopter are quite a bit higher than vessel transfers.   

According to the announcement by DNV GL (click here to access study), the study authors gathered more worldwide data on vessel transfers than had been available in the past and concluded that the risk of helicopter transfers are 11 times higher than vessel transfers.   They say that they found that the chance of dying in a boat transfer is about one in five million  and the chance of dying in an offshore helicopter transfer are about one in 400,000.   They note that they only looked at fatalities during the transfer and not ones that might have occurred on the transit from shore to the transfer point.     They also didn’t look at non-fatal injuries that may occur during transfers by either boat or helicopter.   

dance party deathA little perspective on this is valuable.    One in 400,000 (the chances of dying in a helicopter crash) is still pretty remote.  For example,  according to one website, your chances of dying in at a dance party are 1 in 100,000, so you are technically safer in a chopper than you are twerking, but you probably already knew that.

You also probably knew that the three companies behind the study, Reflex Marine, Enermech and Seacor Marine, are in the businesses of personnel baskets, cranes and workboats, so they definitely have a point of view on this one.

Still, it is an interesting way to look at the comparative risks of the two options.

The Strange Case of The Missing Safety Case Recommendation

The safety case is one of the keys to North Sea and Australian offshore oil and gas safety.  The approach is very much like a legal argument in which an offshore company must argue before government regulators and present evidence that it has identified hazards and addressed them.  Supporters say it helps ensure that industry has anticipated and controlled hazards.   (I am not so sure that it is an improvement over the U.S. approach and suspect that it is just as prone to becoming a routine check-the-box approach, but that is another story).

Recently  President Obama asked government agencies to come up with new, more effective ways to address safety and environmental concerns over hazardous chemicals (see blog posting here).   Proponents of the approach must have rejoiced when the National Institute for Occupational Safety and Health (NIOSH) recommended that the U.S. adopt a safety case approach in a March 6 record:

safety case letter

 

However, on June 6, after the chemical safety proposals had already been presented to the White House and had been released to the public, NIOSH sent a letter withdrawing the original letter and submitting a new letter that removed any reference to safety case.   They said they based it on a “reevaluation of the scientific evidenciary foundation” for its first letter.    Huh!   Is that bureaucratic speak for ” we just realized we were out of sync with the recommendations of every other agency?”

Thanks to the Charleston, West Virginia Gazette for noticing the reversal.  Here is their article.

 

Is your Safety Manual A Swiss Army Knife?

One of the funniest things I have seen on the internet lately was an Amazon listing for the Wenger 16999 Swiss Army Knife Giant, the mother of all Swiss army knives.    Weighing in at just over seven pounds and costing the low, low price of $1,371.94, the Wegner 16999 has 87 implements, if you count the toothpick.    The comments left on Amazon are the funniest part.

So here is the tie-in to safety.  Has your safety manual turned into a Swiss army knife that tries to do everything for everybody?   In meeting with clients recently, I have seen several manuals that have outgrown their useful size.  In a couple of cases, the manual fills two volumes.

How do they get this way?  Usually it follows a six step process:

Step 1 . Start with a generic manual that may or may not reflect what is actually being done at the company.

Step 2.  Over time, develop individual policies that really reflect their actual operations, but  don’t replace the original policies out of fear that they are needed to meet some regulatory requirement.

Step 3.  Cut and paste stock wording needed to get a passing grade on one of the online contractor pre-qualification surveys. (“Paste your trenching and shoring policy here.” )

Step 4.  Add specific procedures to meet individual customer requirements.

Step 5.  Update any regulatory changes by adding them to the existing policy.

Step 6.  Develop a shorter, more understandable version that is actually given to the crews in the field, but don’t get rid of the first one.

Optional step – For large companies, let the safety manuals for each business unit evolve on their own so that each one is different.

Sound familiar?  It is a common problem.    In my view it is because we haven’t settled on the purpose of a safety manual.  Yes, we want it to set the rules that keep workers safe, but we want it to do a lot more.   We try to write it in complex legalistic language to satisfy a regulation.  We use it to get a green light on safety questionnaires.  We want it to capture the unique requirements of every customer.

That is why I say we try to turn safety manuals into Swiss army knives.   It is not enough to have a cutting blade.   They need a screw driver, a file, a saw blade and an allen wrench.   Before long, we want a compass, magnifying glass and a cigar cutter.  We suddenly realize that our pocket knife won’t fit in our pocket and our safety manual is so heavy it breaks the shelf.

My belief is that the safety manual is a strategic document – It lays out the steps you take to achieve your purpose of controlling hazards.  As with all strategic documents, it needs to be written clearly and understandably or no one will follow it.   You would never want to ignore regulatory or customer requirements or a need to achieve a passing grade that is a precursor to getting work.   However, you need a manual that lays out what workers need to do in order to perform their jobs safely and it needs to be in language that they will understand.   In other words, use a knife as a knife.  Get a saw if you need to saw something.

If your safety manual has gotten too big to be useful, contact me at KenWells@lifelinestrategies.com.

Pay Rates On Rise For Safety Professionals

More evidence that the safety profession is becoming a more lucrative field.      A survey by the American Industrial Hygiene Association® (AIHA) shows salaries are on the increase.   According to AIHA, average salaries for industrial hygienists  increased from $94,947 in 2008 to $105,166 last year.   Consultants averaged $135,023 while IH managers averaged $120,276  (that management figure may be a little skewed when you consider the effect that company size has on management salaries).  Link to the news release here.

The website SafetyNewsAlert.com dug a little deeper into the study.  They point out that gaining a certification like a  Certified Industrial Hygienist (CIH) and/or Certified Safety Professional (CSP) really does have value when it comes to higher salaries.   One of the biggest difference was education.   Doctorates earn an average of 121,605, more than $30,000 higher than someone with a high school diploma or an associate’s degree.   Although another way of looking at it is, someone who only has a diploma but is good at their job can apparently earn $90,000 a year in IH.   A couple of other figures worth noting – The average age of an Industrial Hygienist who responded to the survey is 48 and it is still primarily a boys club.  Only 30% of the respondents were women.

New SEMS II Audit Protocols and Operator Guidance Are Out

Word comes from the Center for Offshore Safety that the audit protocols for SEMS plans have been updated to include the new requirements for SEMS II.   Additionally, new guidance is coming out on how industry may interpret SEMS II and what operators will require from their contractors.

We will cover all of this at the next SEMS Workshop For Contractors.  The session will be held next week:

June 24: Lafayette, LA

For more information or to register, click here.

Note:  This is the only SEMS workshop scheduled at this time.

This workshop can also be delivered at your office for your staff.   For more information, contact me at

KenWells@LifelineStrategies.com or (985) 789-0577

White House Now Reviewing New Chemical Safety Proposals, Including Oil and Gas

psm task forceNearly a year ago, President Obama challenged several agencies to come up with new ways to improve hazardous chemical safety and security.  Now those proposals are at the White House under review.   The task force, formed by Executive Order (EO) 13650 – Improving Chemical Facility Safety and Security, sent its report to the Administration in May, but it was only released to the public this month.

The headline for oil and gas is that it would apply the same requirements to have Process Safety Management Plans (PSM) that chemical plants and refineries now have to comply with.   For oil and gas operators or contractors who work offshore, PSM is very similar to the offshore Safety and Environmental Management System (SEMS) rules.  Operators must perform hazard analyses and control those hazards through a number of  approaches, including safety policies, procedures, training and contractor oversight.

The recommendations also say EPA would develop guidance on unauthorized public access to oil and gas storage facilities, a recurring problem that has resulted in a number of facilities over the years.   It doesn’t say whether EPA’s guidance will be to educate the public to stay away or push operators to make their facilities more secure.

So now what?   The White House will decide what recommendations to approve and then start the necessary rulemaking processes.  Those will take some time, probably longer than the current administration will be in office, so the chances of PSM in the oilfield could depend on the politics of the next administration and whether there is another big industrial accident in the meantime.

Beyond that, the process itself may determine the outcome.   Sometimes agencies come out with proposals that push for the sun, the moon and everything in between.   The tackle so many perceived problems and there is so much opposition from so many different groups that the whole initiative falls apart.

On the other hand, when a proposal is this large and touches on so many areas, the opposition from one group, such as oil and gas, may get lost in the background.  The proposal goes through because, once the administration is committed to making it happen,  it pushes through every part of it.   As the saying goes, “in for a penny, in for a pound.”

So it is hard to say whether oil and gas will be included in the end.   Of course the bests defense against new regulation may be to prove you don’t need them by not having any serious accidents.

 

Death at Sea – When No is The Only Right Answer

121030042324-bounty-uscg-horizontal-galleryThe Coast Guard has released its investigation of the sinking of the Tall Ship Bounty and resulting fatalities back in 2012.   If you are not familiar with the story, it is one of the most tragic marine accidents in recent history because it was so preventable.  The sailing ship, built for the movie, “Mutiny on the Bounty,” sunk in Hurricane Sandy 100 miles off the coast of North Carolina.   An inexperienced deckhand died and the captain, who has never been found, is presumed dead.

The Coast Guard has just released the investigative report.  It is gripping as any fictional sea story(thanks to attorney Dennis Bryant for covering it in his blog.)  The main finding of the report is that the Bounty should never have left the dock in the face of the hurricane.  The specific finding is a textbook description of a failure to assess risk:

bounty ROI

 

 

 

 

 

 

 

 

The Coast Guard also found that the owners categorized it as a recreational vessel and, by doing that, avoided many of the safety requirements of commercial vessels.

This is important for anyone involved in maritime, but there are lessons here for safety-related decisionmaking in every field.  The hardest call to make is “no.”    When we plan a project and assess the hazards, we hope that the result is to green light the project.   If there are risks, we develop controls that manage those risks at an acceptable level.  How often are we willing to just say no?  If you can remember a case where a project was shelved because the risks were too high, you probably remember it because those decisions are so rare.

The strange thing is that, in most cases, it takes more courage to make the decision to “stay at the dock” than to head into the face of a hurricane.   That courage has to start at the top within a company.

New Report Weighs In On Macondo – Now What?

The Chemical Safety Board, an independent government group that investigates chemical incidents, has thrown a wildcard into the debate over offshore safety.    The CSB met in Houston last week and released a part of its report on the causes of the Macondo Disaster.  One of the findings is a doozy.

It has been generally accepted that the drill pipe buckled  after the blowout preventer’s blind shear ram failed and the explosion occurred.  However, after a lengthy investigation, CSB says it believes the drill pipe buckled in the early moments of the well failure and that the buckling is what caused the blind shear ram to fail.   The reasoning is highly technical and is based on the theory that a phenomenon called “effective compression” occurred.   According to CSB, oil and gas rising up through the the riser caused pressure in the annular space to drop, while the pressure inside the drill pipe continued to rise.  This pressure differential caused the pipe to buckle.  Instead of cutting the pipe cleanly as was intended, the bend in the pipe caused the blind shear ram to puncture the pipe, increasing the oil release.   This animation video explains the CSB theory:

It is a controversial theory and there will be a lot of debate over whether it was accurate.  However, if correct, it means that one of the largest contributors to the uncontrolled release at Macondo could repeat itself.

The question is, what happens now.   It has been four years since Macdondo and both industry and government agencies that oversee offshore oil and gas have undergone transformation change.  We now have SEMS, we have created one new agency and the oil companies have advanced the technologies to control well blowouts.  But no one has proposed a radical redesign of BOPs….until now.

R.I.P OSHA I2P2

Without any public announcement or fanfare, OSHA appears to have killed its injury and illness prevention program (I2P2), at least for the rest of the Obama’s Administration’s time in office.   I2P2 has repeatedly been listed as a top priority for OSHA and was at one time scheduled to come out as a proposed rule this summer.    It would have required companies to adopt an overall health and safety program, similar to a safety management approach, to identify and control hazards in the workplace.

However, as Roy Maurer reports on the Society for Human Resource Management website, OSHA has quietly removed I2P2 from its Regulatory Agenda.  The agenda lists upcoming rules and their status and when a proposal is removed, it means it is largely dead.

That is not to say that OSHA doesn’t strongly believe that I2P2 is necessary or that identifying and addressing hazards is the best way to address safety in the workplace.    As Maurer points out, the agency may have just run out of time.  It has a full plate of other initiatives and the administration only has two-and-a-half years left in office, with much of that caught up in hard-fought congressional and then presidential races.    That probably doesn’t leave enough time to jump through all of the hoops it takes to push through a major rulemaking initiative.   Which doesn’t mean that I2P2 won’t be back if the next administration supports it.

Companies should also remember that the General Duty Clause pretty much requires employers to recognize and address all hazards, whether they are covered by regulations or not.   I2P2 is a more formal, documented way to do that, but the responsibility to ID hazards will only become stronger no matter what rules come out in the future.

Special Workshop Helps Contractors Meet SEMS II

More than 50 contractor companies have sent their personnel through this one-of-a-kind training workshop in the last year.  The SEMS workshop for Contractors takes the often confusing SEMS regulations and translates them into the steps contractors need to take to meet their operator customer requirements.

We have just set up the next workshop:

June 24th:  Lafayette, LA
Click here for more information or to register.

If you would like to put on a SEMS workshop at your office for your staff, contact me at KenWells@LifelineStrategies.com.