HSE Case
Implemented post-Piper Alpha, HSE Cases have become a crucial document for demonstrating the adequacy of the management of Major Accident Hazards (MAH). However whilst serving the needs of Regulators and Company Auditors, there has been increasing dissatisfaction with the value they add to Operations personnel even when translated from “Design Cases” to “Operations Cases”.
A survey amongst Asia Pacific OIM’s yielded common concerns with the current Cases, independent of asset type and operating area (including Regulatory environment), among them:
- Lack of transparency between daily operations and a Case that “sits on a shelf”.
- Change management.
- Difficulty in easily understanding/comprehending major hazards.
- Unwieldy documents that are a “catch-all” for any Health, Safety, or Environmental related issue.
- Remedial actions that are seldom closed.
A closely related issue is Technical Integrity on aging platforms and the tolerability of equipment state with HSE Cases that don’t provide any tangible/practical guidance on the ‘acceptability’ of barriers.
To address these concerns Shell Exploration & Production Asia-Pacific (Shell EPA) is implementing a program to “Operationalise” HSE Cases. At the core of the program is the objective to refocus HSE Cases on Major Hazards and provide a roadmap to Company systems (centered on Technical Integrity) that will provide effective barriers during the operational phase.
No element of the program is ‘revolutionary’ but in its entirety provides a cohesive and transparent means of communicating Major Hazards to Operations personnel and providing them a tool to demonstrate that they have the right systems in place to maintain barriers. The Cases are highly focused on Operator’s needs, and draws in global best practices from within the Company and Industry.
This paper outlines the issues leading up to revamp of Cases, the framing of the program and core issues, the selected way forward on Case content, elements required for success, and roll-out/accountability requirements.
The original intent of Safety Cases was as a demonstration that a Company had appropriately controlled Major Accident Hazards (MAHs) on an installation and reduced the risks that arise from them down to As Low As Reasonably Practicable (ALARP) levels. Additionally, Cases were used to demonstrate that an HSE Management System (HSE-MS) was in place and that correct provisions for escape, refuge, evacuation and rescue were provided.
Other countries have followed the lead of the UK and since adopted the Safety Case approach. The uptake of comprehensive mandatory Safety Case requirements in the Asia Pacific has been slower (with the notable exception of Australia and New Zealand), although this is increasing with more AP countries incorporating Case requirements into their Health and Safety laws. Many international oil and gas Operators have adopted the concept as good practice and implemented Cases irrespective of (the lack of) legal requirements.
Safety Cases have evolved over time to include health and environmental (and sometimes security) hazards and are more commonly termed “HSE Cases”. They are also routinely applied in other activities such as drilling as well as onshore facilities, pipelines, etc. The focus of this paper is on offshore production installations and assumes some familiarity with HSE Case use.