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US looks at risk-based approach to offshore safety

BSEE considering combining prescriptive verification with risk-based analysis to create a hybrid inspection programme to ensure safer offshore operations

US oil and gas regulators for years have used prescriptive methods to determine the frequency of equipment inspections. Such prescriptive safety programmes focus on understanding the ramifications of equipment failure.

Other oil and gas regulators have embraced a risk-based approach, which focuses on the probability of failure of a certain piece of equipment.

The different approaches make sense given the traditional mix of operators working in US waters, says Lars Herbst, Gulf of Mexico region director at the US Bureau of Safety & Environmental Enforcement (BSEE).

"Other countries are generally not as prescriptive in their approval analysis or verification, but the drawback from that is that much of the verification is left to the operators, which can cause problems," Herbst says.

9aa8fde545b4fe40b3ecdd01d4326a08 Photo: ANTHONY GUEGEL

"We are not giving up what we believe is critical."
Lars Herbst, BSEE

"The Gulf of Mexico has over 80 operators, where most other countries have far fewer operators. That results in better understanding of those operators and far fewer operations.

"However, the BSEE has indicated it is working on a proposal that would add risk-based inspections to its existing inspections programme. The proposal will likely be incorporated into the agency’s compliance inspections sometime next year.

Currently, Herbst says, the BSEE believes annual and unannounced compliance checks help keep the industry safe, but not all incidents are caused by the items the compliance inspections check for.

"We are not giving up what we believe is critical," Herbst says. "The change is actually not eliminating what we have now but adding an additional inspection method that addresses root causes of incidents in a safety management approach versus a prescriptive check list."


Sharing lessons

The proposal draws heavily on experience from multi-year pilot programmes focused on compressor fires and gas leaks. Performance-based risk inspections and facility-based risk inspections will likely be a cornerstone of the expanded inspection programme, Herbst says.

For facility-based risk inspections, the BSEE would report back to the operator about its findings.

For performance-based risk inspections, the BSEE would share the results, as most would involve industry-wide issues.

"If we’re not sharing those things, then industry is not learning from our findings," Herbst says.

Much of the industry’s risk-based experience in the Gulf of Mexico has been in the realm of approving new technology deployments, and it seems likely that the new risk-based inspection methods will share similarities with the deep-water operations plan (DWOP) that the BSEE uses to assess new technology.

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"Our regulations could not keep up with new technologies, so we had to come up with a process that would allow us to review the new technologies. There were not always industry standards available.

"That’s when we get into more of a risk-based analysis - prove to us that it’s safe, or safer, compared to regulations and standards out there already," Herbst says.

"We are moving in that direction because we have to, particularly in deep water.

"Herbst says blowout preventers (BOPs) might eventually fall under the risk-based system with new means of BOP health monitoring.

"We think we’re going to get to a point where the new technology for monitoring BOPs in real time, and each component of the BOPs, can lead to better overall reliability of those systems," he says.

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