How does subsea processing safety policy impact safety? Lessons learned from the Brazilian experience

Abstract

This paper is about the influence of safety regulations on the way major accidents are identified and managed. A case study is presented based on the Brazilian experience in subsea processing units. The oil and gas industry is devoting increased interest to subsea processing due to the limitation of easily accessible oil and gas reservoirs. There are more than 48 units already installed in Brazil. Most of the safety requirements in Brazil's E&P policy are based on offshore units. However, for subsea structures, there are different risks, environments, and operational conditions. In 2015, Brazil presented a safety regulation named SGSS (Technical Regulation of Operational Safety Management System of Subsea System). This regulation explicitly addresses risers and introduces only general safety requirements to other subsea installations and equipment. Thus, this paper assesses the Brazilian subsea safety regulation and the results of this policy implementation through the Brazilian Petroleum Regulator (ANP) inspections and incident communications. The example demonstrates the inefficiency of the policy to promote safety. This paper then proposes simplifying regulations, introducing new technology requirements, and a technical committee to improve safety to subsea equipment.