Hazard and Risk Register for Management of Major Upstream Hazards

Abstract

Abstract The process industry has been successful in controlling and reducing occupational health hazards, with close to a factor of 10 improvement achieved by several large companies over the past 20 years. The means for control of major hazards however has proven more difficult with a relatively steady number of major accidents, which has not shown a significant decline (e.g. Marsh100 Largest Losses) and in general is equally true for the upstream and downstream oil industry, even though these industries have quite different regulatory frameworks. In the USA, onshore major hazard industry is subject to the Process Safety Management Regulations (OSHA 1910.119) if parts of the facility exceed nominated inventory thresholds. Similar regulations apply from the EPA under the Clean Air Act Amendments, with additional requirements to carry out some worst case release scenarios. The PSM regulation was passed in 1992 and its focus is to ensure implementation of a safety management system that identifies process safety threats, ensures adequate mechanical integrity, manages changes, and investigates accidents. A fuller list of best practice requirements is available in CCPS (2007). Following a major accident at Texas City, the Baker Panel (2007) recommended that the whole industry review its implementation of PSM and to enhance several aspects. The Panel stressed the importance of compliance with PSM in full and suggesting a number of management commitment and process metrics recommendations. OSHA is currently undertaking full PSM audits of all US refineries under its control by 2009. The EU Directive for onshore process safety is covered in the Safety Case Regulations (e.g. COMAH in the UK). These have been through several revisions since their original issue in the 1980's to take account of actual accidents and lessons learned from other industries (e.g. upstream O&G). The barrier approach to risk management has received extensive treatment in Europe since the early 1990's, with strong reference to Prof Reason's swiss cheese model for accident causation. Shell used the bow-tie method to manage process safety at its Pernis Refinery in the Netherlands (Zuijderduijn, 2000) and at many other facilities globally. The EU sponsored the ARAMIS project that examined the Bow-Tie method in the early 2000's as a means to enhance process safety (Salvi and Debray, 2006). In Norway, a major project is looking at a similar method, titled Barrier and Operational Risk Assessment as a means to enhance process safety (Aven et al, 2006).