Heavyweight Offshore Safety Issue: Obesity

We hear a lot about the growing obesity problem in America, but it is really a worldwide phenomenon and one that is hitting the oil patch.  Oil and Gas UK, the British counterpart to API, said in its 2014 health and safety report that the average weight of offshore workers in the UK has jumped by 19 percent since the 1980’s.

What are the implications of this for the oil and gas industry?   Certainly increased health concerns like heart disease and diabetes.    In the offshore world, there is a new concern involving helicopters.   In the aftermath of a catastrophic helicopter accident last year, the UK is concerned about whether oilfield workers who are too large are able to escape from a downed chopper.   Interim measures included size restrictions on passengers.    Oil and Gas UK is currently researching the problem with a study on 600 oilfield workers.  The study involves computer modeling and creating 3D mannequins to study the best way to improve helicopter egress.

Oil companies in Europe may have another problem that U.S. companies don’t.  According to  Ledingham Chalmers, a British law firm, an EU judge is considering whether to treat being substantially overweight as a “protected characteristic” under EU employment law.   that would apparently prevent employers from taking any action that could be considered discriminatory against overweight workers.   You can read more about the issue here.

Amazing Video -Shark Turns Into Bait

OK, this may be a reach, but this video of a shark turning into a snack for a grouper is a reminder of a fundamental flaw in a lot of our hazard analysis.

One of the mistakes we make in managing hazards is to confuse protection with prevention.  Protection means workers are at risk and we take steps to keep them safe.   Prevention means we remove the risk completely and workers are not at risk.   The biggest difference is that when we protect, we can never forget that the risk didn’t go away.

But we make that mistake all the time.   We do our bow-tie analysis, we create a barrier for all of the hazards and we convince ourselves (at least on a subconscious level) that we have prevented a catastrophic event.   However, we haven’t.  We hope we have protected workers, but the hazard never went away.

This is a pretty amazing video, if nothing else  because it reminds us that, no matter how big your teeth are or how thick your armor, you are just bait for some other fish when things go wrong.  The moral is:  Big and mighty hazard controls protect, but they don’t prevent incidents.  They can actually become their own weakness if they lull us into a false sense of security.



Confined Space Incident Kills 3: The Never Ending Threat

Confined space fatalities are a continual threat that seem to defy training and experience.  How do we prevent them?

The  Marine Accident Investigation Branch (MAIB) just released the investigation report on an confined space incident on a ship that killed three.   This tragedy played out in two parts:

  • Multiple deaths as one crewmember after another went in to help a fallen co-worker.  In this case, one and possibly two crewmembers went into the oxygen-deprived environment of a forward hatch.  The third victim, the Chief Officer, yelled down to them and then, without any consideration of the danger, climbed down after them.
  • The failed rescue effort that followed.  According to the investigation a fourth crewmember donned a  breathing apparatus (BA) set with a mask that didn’t fit.  Two stevedores working onboard also went in, one with an emergency escape breathing device (EEBD) and the other with no apparatus at all.   The three managed to recover the bodies and get out but all of them suffered severe breathing problems.

The full report can be viewed here.  Thanks to Maritime Executive for calling attention to it.

quesion mark guy 2Confined space fatalities may be the most heartbreaking of incidents because they so often involve multiple deaths, as one person after another ignores the danger to save a co-worker.   From a training perspective, confined space is different from so many safety topics.  You can teach someone to use safety gloves and wear steel-toed shoes.  But teaching about confined space means overcoming hard-wired instincts and that means looking at how our brains work.

Here’s what happens – When you a worker passed out in a confined space, it triggers a 100,000 year-old response that has been with us since early man was wandering around the African plains trying not to get eaten.  One of the most primitive parts of your brain, the amygdala, hits the panic button and takes over.   It is fight or flee time and your nervous system floods your body with adrenalin.  It is common for people in an emergency to say they can’t “think straight” and they are right.  Scientists say the amygdala “hijacks” the pre-frontal cortex, the part of your brain that thinks things through and makes decisions.

In the case of a confined space incident, your amygdala makes the decision to go in and pull your buddy our, to fight instead of flee. The rush of hormones surging through your brain makes it impossible for your steady-thinking pre-frontal cortex to assess the risk.  All of that training you got in a classroom goes out the window.

So how do we address this problem?   Training under hand-on conditions with scenario role-playing, company rescue plans that are actually stressed to workers and drilled and routine reminders at safety meetings and other venues.

We need to start bu recognizing that confined space is one of those topics that can’t just be taught in a half an hour in the classroom.

Big Jump In OSHA’s Severe Violator Enforcement Program

The year has seen OSHA back away from several high profile initiatives, but one area OSHA is not shying away from is its Severe Violator Enforcement program.  The SVEP  “concentrates resources on inspecting employers who have demonstrated indifference to their OSH Act obligations by committing willful, repeated, or failure-to-abate violations.”

According to an article in the National Law Review,  there was a nearly 25% increase in companies placed on the program last year.  The program is only four years old and there are now 423 sites on the list.   Companies on the list face additional return inspections and added charges if warranted.

According to the article, more than half the companies on the list have no more than 10 employees, sp clearly enforcement is skewing toward small businesses.  Only about 15% of the companies have more than 100 employees.

This fits a pattern we have seen with OSHA in a number of area.  The agency has been frustrated in its ability to push through new regulations and continues to face resource shortages.  However, once OSHA nabs a violator, it appears to be pursuing higher penalties and increased oversight.

Offshore E&P: The Risk/Safety Disconnect

The Bureau of Oceans Energy Management (BOEM)  is looking for public input on whether it needs to rewrite its regulations on risk management and financial assurance for offshore energy projects.   The fundamental goal of the regulations is to make sure that the taxpayer doesn’t wind up holding the bag if, for some reasons, an oil company can’t or won’t manage a lease from cradle to grave.

In light of some of the changes and increasing costs offshore, BOEM wants to update its risk and financial regulations, so it is releasing an Advanced Notice of Proposed Rulemaking (ANPRM) that asks more than 50 questions.   You can read more about the ANPRM here.

What is striking about the proposal is the nearly complete disconnect between BOEM’s effort to manage risk and sister agency Bureau of Safety and Environmental Enforcement’s  (BSEE) efforts to manage safety.   The ANPRM asks what risk measures BOEM should look at and how it affects individual projects, but here are some of the works that do not show up in the questions:

  • Safety management
  • SEMS
  • Compliance
  • Incidents of Noncompliance (INCs)
  • BSEE Performance Improvement Plans  (The most powerful tool BSEE has to force compliance)

In other words, BOEM does not seem to be looking at actual safety performance in looking at risk.

A little background may be in order.   Risk management is generally the process of identifying, prioritizing and controlling risks caused by uncertainty or unpredictable events.   Risk can include natural disasters (hurricanes, etc.), financial strength (potential for bankruptcy, etc.), exposure (insurance, etc.) and, significantly, safety performance.    Safety management involves  identifying, prioritizing and controlling hazards to humans and property.    For a look at how much overlap there is between risk management and safety management, take a look at this presentation from the Atlanta Safety Council.

In a practical sense, risk management lives in the world of loss control and insurance.  Safety management belongs to the safety department and, increasingly operations departments.   But just about everyone in business understands the connections.  If you don’t control accidents, your insurance goes through the roof.   We have also seen a number of cases offshore where there was a connection between significant incidents and the responsible party’s financial health.

All of which makes it curious that BOEM would not be more interested in how a company manages safety as a function of risk or to use the quality of a company’s safety program as a way to offer lower financial requirements.  It seems out of sync with the direction that insurers have been moving for years.



BSEE Releases Report Card on The 1st Round of SEMS Audits

Offshore oil and gas companies had to have their SEMS plans audited by last November.  A lot of people have been hoping BSEE would release more information on the results, especially from a lessons learned standpoint.

BSEE just released a report that looks at the audits.   It is definitely the 10,000 foot view, but reading between the lines the message is:

“Good first effort, but a lot of things need to change.”

The primary problem identified in the report is that the whole audit structure is focused on measuring compliance with the overall regulation.  BSEE wants future audits to look at:

  • Whether the SEMS program and the individual elements are effective.
  • What companies are doing right in terms of best practices instead of just focusing on deficiencies.

BSEE also gives some clues as to the direction it will head for the next round of audits.

If you would like a copy of the report and an analysis I have written of what this means to industry, contact me here.

Mass X Velocity = Huge Mess For Heavy Lift Transport

By any measure this video perfectly captures someone’s really bad day.   I don’t know much about it, except that it appears to have happened in Whiting, Indiana back in 2010.  What appears to be a new coker unit for a refinery rolled off the heavy lift trailer when it was trying to make a turn.  Luckily no one was injured.   But, ouch, things really go wrong when you try to break the laws of physics.

Government Study On Heat-related Fatalities

The Center for Disease Control just released a study of heat-related fatalities.   The short version is that employers need to do more to acclimatize personnel who work in heat.  The CDC studied 20 OSHA investigations into heat-related deaths or injuries.   In 13 of the cases, a worker died.   According to the CDC, in nine of those 13 cases, the workers died within three days of going on the job.    That means a full two thirds of the deaths involved workers who were brand new.

The study showed that in all 20 cases, companies did not have heat illness prevention programs or the programs were found to be inadequate.  The CDC also said that companies had no provisions for acclimatizing new workers to the heat, meaning allowing workers to “gradually build up workloads and exposure to heat by taking frequent breaks for water and rest in shade or air conditioning.”

You can read the news release here.

So the question is, what does your heat program look like?

Future of Process Safety Management in The Oilpatch

One of the most important safety initiatives facing landside oil and gas is sitting on a desk at the White House awaiting review.  A special multi-agency task force presented recommendations to the Administration in late spring, including a recommendation that the OSHA safety rules known as Process Safety Management be applied to upstream oil and gas.

I recently authored an article for the Association of Energy Service Companies’ (AESC) Well Servicing Magazine that looks at the background of the PSM proposal and where it goes from here.   You can access the article here.

Incidentally, if you find the article valuable, you might want to subscribe to AESC’s Well Servicing Magazine.  It is a valuable source of information about the issues affecting the landside oil and gas industry.    Subscriptions are free and you can access the sign-up here.

Happy Anniversary – Now Get Back To Work!

LinkedIn is good for a lot of things.   Apparently one of them is to remind you know about significant events that you either didn’t remember or wouldn’t have thought were that significant anyway.  Yesterday, LinkedIn reminded me that my company, Lifeline Strategies, is one year old.

At a Chinese restaurant that night, here is what my fortune cookie said:

1 year fortuneThe experts say the first year is the toughest one for every business.   Studies show that something like 25 – 50% of new businesses fail in their first year, so I guess a one year anniversary is something worth celebrating.

When went out on my own last year, my goal was to take a lot of years experience in a lot of different environments and use that to help companies address the growing need for safety and competency management.    Lifeline Strategies mission has been to help those companies organize, improve and execute management strategies that help them connect their policies, training and risk management into effective programs. So far, that approach has paid off.

This year, I have had the opportunity to work with a growing list of clients to create and improve:

  • Safety management programs, especially for companies that need to meet customer SEMS requirements
  • Commonsense skills, knowledge and training assessments for offshore workers
  • Leadership skills for supervisors, managers and other offshore personnel

If there has been one thing that I have learned this year, it is that the most important thing that a new company needs to thrive is help from other people.   Of course, that includes clients  who pay for your services.   But it also includes friends and even competitors who are free with their encouragement, advice and the occasional criticism (always constructive, of course).

So on this anniversary, let me simply say “Thank You”  to all of the people who have been so generous with their support in the challenges and the joys of the past 12 months.