Safety Case in GoM: Method and Benefits for Old and New Facilities

Abstract

Abstract The purpose of Bureau of Safety and Environmental Enforcement (BSEE)'s Safety and Environmental Management Systems (SEMS) is to enhance safety of operations in the Gulf of Mexico (GoM) region. One of the four principal SEMS objectives is to encourage the use of performance-based operating practices. However, the current U.S. Regulatory framework for offshore operations in GoM does not provide the adequate tools to focus on the specific risks associated with a facility. The adoption of a Safety Case regime would steer the operations in the GoM towards this goal. Operators could take over the Safety Case as a significant input for the development of their Risk Management and Asset Integrity Management (AIM) programs for existing operating facilities as well as new facilities being planned. The paper discusses the application of a Safety Case and how the Operator can demonstrate that the major safety and environmental hazards have been identified, the associated risks are estimated and how these risks are managed by achieving a target level of safety. Throughout the Safety Case road map, the identification of the Safety Critical Elements (SCEs) and the associated Performance Standards represents one of the corner stone of the AIM Strategy. Introduction of the Safety Case would not imply a complete overhaul of the current Regulation, but would lead to a continuous and adequate enhancement of the Regulatory requirements towards a performance-based approach. It would include a prescriptive-based policy, combined with a performance/goal-oriented process, considering the specific risks inherent to the installations and the demonstration of how these risks are managed. With help of an example the paper discusses how application of Safety Case for existing facilities would highlight particular risks that may have been misjudged, taking into account the current state of its installations and the actual operational procedures in place. Further, this paper shows how existing Risk Management and AIM systems could be revised based on identification of SCEs and definition of the associated Performance Standards. This would also give the Regulator a quantified picture of current operations in the GoM and assist in re-defining the distribution of its resources and efforts in order to have an efficient review and verification impact. For the new facilities, the introduction of the Safety Case at the early stages of design would ease the integration of the overall risk management plan at each level of organization. The Regulator would have the ability to cross-analyze the risk results arising from the Formal Safety Assessment studies with the risk management plan drafted by the Operator. This paper investigates the possible integration of a performance/goal-oriented regime into existing Risk Management and AIM systems.