Cullen Report Research Articles

What difference has the Cullen Report made? Empirical analysis of offshore safety regulations in the United Kingdom's oil and gas industry

Anecdotal evidence from the United Kingdom's offshore oil and gas industry indicates that risk-based safety regulations, introduced in the aftermath of the 1988 Piper Alpha disaster which killed 167 offshore workers, have improved safety outcomes such as reducing fatalities and dangerous occurrences. However, the empirical dimensions of this supposed improved safety record in the literature is scanty. This paper explores the relationship between the safety regulatory regime and safety outcomes in the UK offshore oil and gas industry from 1995 to 2011 using multivariate regression analysis based on the generalized linear modelling framework. We assess the trend and impact of the regulatory changes implemented through the safety case regulations on major hazard risk indicators such as hydrocarbon releases controlling for technical factors such as type of offshore facility, facility location, water depth, production levels, and external factors such as oil prices, acting as a measure of the prevailing macroeconomic activity level. The results show a statistically significant industry-wide decline in hydrocarbon releases between 1995 and 2011 (average marginal effects), after controlling for location, water depth, installation type, installation age and other factors. This reflects both the commitment of operating companies and the regulator to reducing major accident hazards in line with the principles underlying the safety case regime. Other offshore jurisdictions could focus major accident reduction efforts predicated on goal-setting safety case principles which identify key safety-critical elements of an oil and gas installation and put in place risk-based mitigation measures.

Flexor Tenorrhaphy Using Absorbable Suture Materials

BackgroundNonabsorbable sutures are favorable for repairing flexor tendons. However, absorbable sutures have performed favorably in an animal model.MethodsTwo-strand sutures using the interlocking modified Kessler method with polydioxanone absorbable sutures 4-0 were used to repair completely ruptured flexor tendons in 55 fingers from 41 consecutive patients. The medical records of average 42 follow up weeks were analyzed retrospectively. The data analyzed using the chi-squared test, and Fisher's exact test was used for postoperative complications. The results were compared with those of other studies.ResultsAmong the index, middle, ring, and little fingers were injured in 9, 17, 16, and 13 fingers, respectively. The injury levels varied from zone 1 to 5. Of the 55 digits in our study, there were 26 (47%) isolated flexor digitorum profundus (FDP) injuries and 29 (53%) combined FDP and with flexor digitorum superficialis injuries. Pulley repair was also conducted. Concomitant injuries of blood vessels and nerves were found in 17 patients (23 fingers); nerve injuries occurred in 5 patients (10 fingers). Two patients had ruptures (3.6%), and one patient had two adhesions (3.6%). Using the original Strickland criteria, all the patients were assessed to be excellent or good. Also, fibrosis and long-term foreign body tissue reactions such as stitch granuloma were less likely occurred in our study. Compared to the Cullen's report that used nonabsorbable sutures, there was no significant difference in the rupture or adhesion rates.ConclusionsTherefore, this study suggests that appropriate absorbable core sutures can be used safely for flexor tendon repairs.

Anesthesia Dogmas and Shibboleths

Anesthesia Dogmas and Shibboleths

20 Years on lessons learned from Piper Alpha. The evolution of concurrent and inherently safe design

It has now been well over 20 years since the North Sea Piper Alpha disaster in 1988. There have been many lessons learned; some documented others just etched in memory. The event chronicled many significant changes in the offshore industry. The emanating point for most sweeping changes has been the Cullen Report and the UK North Sea industry. This paper reviews some of the critical lessons and identifies many ‘secondary’ finer points that constitute important learnings. The paper looks at major changes instigated by step changes in safety criticality. It is argued that the ‘second tier’ modes of failure such as corrosion, materials degradation, environmental cracking, erosion, plant ergonomics, etc. need to be better examined. These mechanisms are dangerous threats to the integrity of deep subsea assets, and it is noted that such root causes of failure as witnessed or predicted have yet to be fully appraised. The authors’ use wide experiences and case histories to highlight such concerns, offering rational fit-for-purpose solutions. The industry disconnections between, urgency to build, knowledge transfer, and management of change, are refocused. Powerful advances in risk-based mechanical, process, materials, and corrosion engineering are emphasized and the use of key performance indicators (KPIs) are reasoned for best life-cycle integrity. To keep up with the pace of growth in the deepwater sector, methods of concurrent and inherently safe design have evolved in a world where the practicalities and costs of modification, repair and retrofit are extremely difficult. Hence getting it right at the outset is paramount. Thus the drive for purposeful investment, at design is more justifiable, than the traditional practice of postponing costs (and problems) to operations. In this way the ominous ‘gray’ zone between the two cost centers is better bridged for reasons of safety and commercial advantage.

Feeling the heat, can’t stand the pressure? Risks to borehole integrity when drilling in ultra-HPHT environments

Finding new hydrocarbon reserves is not getting any easier. Despite the historically high prices of oil and gas, there remain significant cost pressures to economically and efficiently exploit hydrocarbon reserves accessible to multinational companies. One potentially cost-effective way of adding new reserves and production is via ‘infrastructureled exploration’. This involves exploring for reserves that are deeper or laterally off-set from developed fields and existing production facilities. Both pose significant, albeit different, drilling challenges. It is the challenges associated with drilling in deeper, hotter and more highly pressured environments that are described here. The term ‘HPHT’ is commonly used to describe wells that are hotter or higher pressure than most. The term came into use upon the 1990 release of the Cullen report on the Piper Alpha platform disaster in the UK sector of the North Sea. Here, HPHT is formally defined as a well having an undisturbed bottomhole temperature of greater than 300°F (149°C) and a pore pressure of at least 0.8 psi/ft (ca. 15.3 lbm/gal, or 1.83 g/cc) or requiring a blowout preventer with a rating in excess of 10,000 psi (68.95 MPa). With combined bottomhole conditions of 20,000 psi (137.9 MPa) and 420°F (215°C), Mobile Bay, off the coast of Alabama, USA, still holds the record as the world’s hottest and highest-pressure offshore producing environment. As exploration foci are targeting deeper and deeper formations, a new terminology is developing that further classifies HPHT conditions (Figure 1). Three levels of HPHT severity are defined: Tier I refers to wells with reservoir pressures up to 15,000 psi (103.4 MPa) and temperatures up to 350°F (177°C). Most HPHT wells drilled to date fall into this category. The Tier II category defines the current focus of ‘ultra-HPHT’ wells, defined as having bottomhole fluid pressures of up to 20,000 psi (137.9 MPa) and temperatures of up to 400°F (204°C). Several deep gas wells currently being planned (or being drilled) in coastal regions of the Gulf of Mexico fall into this category. Tier III defines ‘extreme-HPHT’ conditions, with reservoir pressures up to 30,000 psi (206.8 MPa) and temperatures up to 500°F (260°C). Several deep gas reservoirs onshore North America and in the Gulf of Mexico – both on the Shelf and in deep water – would fall into this category - see Figure 2, adapted from Baker Hughes (2005).

Authoritative Sensemaking in a Public Inquiry Report

This article analyses the Cullen Report into the Piper Alpha disaster in order to research how public inquiry teams represent their efforts to make sense of events as authoritative. It is argued that inquiry reports are highly convention-governed sensemaking narratives that employ various forms of verisimilitude in order to bolster their authority. They are also monological storytelling performances that function hegemonically to impose a particular version of reality on their readers. The investigation of the means by which inquiry reports accomplish verisimilitude and hegemony are important as they may shed light on how this form of public discourse depoliticizes disaster events, legitimates social institutions, and lessens anxieties by concocting myths that emphasize our omnipotence and capacity to control.

An experiment with two‐way offers into court: restoring the balance in pre‐trial negotiation

Defendant offers into court is common procedural device aimed at increasing the probability that pre‐trial negotiations will lead to out of court settlement. Both in the UK following the Woolf Report and the Cullen Report and in the USA, the idea of extending the arrangement to plaintiff offers into court has been suggested. This paper presents an extension of the theoretical work by Chung on defendant offers into court under the US rule to cover the English rule and to extend to two‐way offers into court. It also reports on experiments conducted to measure the effect of moving to two‐way offers into court. The results suggest no impact on the propensity to settle and a statistically significant but empirically modest movement of settlement in favour of the plaintiff.

Creating a fire safety management system for offshore facilities

Fire safety management on offshore platforms has been a matter of major concern since the publication of the Cullen report into the Piper Alpha fire. In order to be able to achieve and maintain an acceptable level of fire risk it is desirable to consider the system as a “dynamic whole”. The intention in this research has been to construct a fire safety management system which is both efficacious and resilient. To this end a systemic approach to fire safety for an offshore platform has been pursued, employing the Viable System Model and the Failure Paradigm Method.

A Design-for-safety Methodology for Large Engineering Systems

Summary Both the Cullen report of the Piper Alpha disaster and the Carver report on ship safety have proposed that safety should be incorporated into maritime design processes from the initial stages and that more scientific and objective approaches are required in order to help prevent major accidents, to demonstrate safety and to describe the safe operational requirements of large made-to-order products such as offshore platforms and ships effectively and efficiently. In this paper, the characteristics of large made-to-order products are described and their design process is studied together with a proposed design framework. After investigating the current design-for-safety status of large made-to-order products, a generic design-for-safety methodology is proposed and discussed in the context of the general design process. This proposed design-for-safety methodology may form the basis for the further development of safety assessment procedures and safety-based decision-making modelling techniques. The phases in the proposed design-for-safety methodology are studied together with their objectives and requirements. Finally, concluding remarks are given.

Paying for the Piper: Capital and Labour in Britain's Offshore Oil Industry

Oil, imperialism and the British state - the origins of the crisis problems of union mobilization - the 1970s and 1980s prelude to action the summer of discontent Lord Cullen's Report `a profound change in culture' the strategy of containment paying for the piper? striking out - setting a new agenda the future of offshore trade unionism the restructuring of Britain's oil and gas - the supply industry conclusion - an unsafe future.

Reviewing the Firearms Control Debate

The purpose of this short essay is to review the criminological content in the British 'gun control' debate following the Dunblane killings. At first sight it might be thought that any such review would not take very long. The debate, however, which surrounded and summarily overwhelmed first the Home Affairs Committee and later the Cullen Report itself and formed the vital context for the Commons vote on the government's package of gun controls, did have its criminological moments. Yet one of the interesting issues in the whole series of commentaries and interventions following the Dunblane massacre was the relative absence of any dear or consistent criminological contributions and the comparative ease with which those which emerged were pushed aside. This is not the place to review, in detail, the precise statistical analyses employed; the article is more concerned with the parameters within which the debate was largely confined.

The Shadow of Dunblane

The massacre of sixteen children and their teacher in Scotland, at the Dunblane Primary School, earlier this year, shook the world. Hundreds of thousands of flowers were sent from all over the globe, as a gesture of sympathy and solidarity. Eight months later, the world carries on its normal business, but for the people of Dunblane there can be no return to normality. This article looks at some points raised by the Cullen Report, the Government inquiry into the massacre, particularly the emerging details about the background of the killer, Thomas Hamilton. These details are set alongside Jung's discussion of the Shadow archetype. The article also examines the role of the local churches at the time of the tragedy and thereafter, particularly the Cathedral at the center of Dunblane. The final section looks at some general reactions within the community to the killings.

ＨＳＥマネージメントプラン

This paper describes on the HSE Management Plan which has been established as the company policy for quality operation by Japan Drilling Co., Ltd (JDC). The HSE Management Plan is a management system on health, safety and environment which is very emphasized in oil industry to prevent an accident since Load Cullen's report was published after the investigation of the Piper Alpha disaster in July 1988.JDC considers that the implementation of the HSE Management Plan will produce a sustainable and on going improvements in HSE performance by influencing the behavior of people in the organization, from top management down through all levels of the workforce, and then accident free quality services can be delivered to a client.

Development and Implementation of an HSE Management System in Exploration and Production Companies

Summary This paper describes the experience to date with safety management systems (SMS's) and describes their implementation after the Piper Alpha disaster and Lord Cullen's report. It also shows the gradual expansion of these systems toward fully integrated health, safety, and environment (HSE) management systems. Our company policy, which was clearly stated before publication of Lord Cullen's report, is that work should not start until the appropriate controls are in place. Work based on this policy and on objective-setting SMS's within Shell IntI. Petroleum Mij. (SIPM) E&P coordination started in earnest soon after the publication of the report in Nov. 1990 and has continued without interruption since that time. Objective-setting systems may be defined as systems where the company management sets its own objectives or goals on the basis of functional rather than prescriptive requirements and then goes on to demonstrate how such goals have been, or are being, met. The paper ends with a projection of what may be expected in the future. Introduction Following the Piper Alpha disaster and the in-depth public inquiry led by Lord Cullen, the recommendation was made that all offshore installations on the U.K. continental shelf should have safety cases similar to those already required under the U.K. Control of Industrial Major Accident Hazards Regulations. This recommendation was given effect by means of the safety-case regulation within the U.K. with a Nov. 1993 deadline for the submission of safety cases. Shell Expro, as a major operator in the U.K. sector of the North Sea, had already begun work on its safety cases before publication of the Cullen report and was one of the companies that contributed to the so called "voluntary" safety cases before this date. It was apparent to E&P management within SIPM that the SMS and the safety case provided better assurance of safe operation and were of real value to Shell operations worldwide. (In this paper, Shell is sometimes used for E&P companies of the Royal Dutch/ Shell group in general, and Shell E&P is used if experience was gained through technical service agreements supported by SIPM E&P). It was also clear that a worldwide move toward such systems would take place. Thus, application of these systems was both good business and appropriate for all Shell E&P operating companies. As a direct consequence, an integrated project team (both project engineering and operations) was set up to implement SMS and safety cases throughout Shell upstream operations worldwide.

Offshore Safety Management Systems: Current Practice and a Prescription for Change

Safety performance on the UK continental shelf is normally of a high standard, although there are still many “minor” accidents. However, a comparative analysis reveals that major disasters in the North Sea have forced up fatality statistics, indicating that there is a need for improvement. The Cullen Report on the Piper Alpha disaster and the ensuing Safety Case Regulations are evaluated in light of safety performance. While the regulations are a major step in the right direction, apparently there are gaps in the provision. Such gaps cannot be filled solely by following the principles of total quality management. Problems with the regulations include the fundamental approach to public inquiries, the problems of objective versus prescriptive regulations, technological bias, the behaviour of management and management systems, communication problems, difficulties with quantitative risk assessment, key concepts within the regulations (ALARP and acceptance), change management, the nature of safety management systems and ignoring the natural environment.

海洋油・ガス生産設備の無人化操業の現状および動向

The highest economic justification category for offshore production are the unmanned operations. Personnel located on offshore platforms require support facilities such as accommodation and catering facilities on the platform and helicopter and/or service boats support from onshore facilities. Even with unmanned or de-manned operations there exists a requirement to temporarily accommodate supporting facilities which would cover a minimum requirement and be designed to the ultimate safety standards. Innovative SCADA/DCS technological applications can have a direct influence on unmanned or de-manned offshore operations.In offshore applications, economic technical and safety considerations involve the cost benefits achieved by unmanned platform operations thereby providing substantial economic benefits in offshore operation.Some of the safety aspects arising from the Piper Alpha North Sea tragedy and the subsequent recommendations outlined in Lord Cullen's report are included in this study.

The U.K. Offshore Operators' Response to the Piper Alpha Disaster

Summary This paper describes the U.K. government's inquiry into the Piper Alpha disaster and examines one organization's response to recommendations from that inquiry. Introduction Immediately after the July 1988 Piper Alpha disaster, U.K. offshore operating companies reviewed their "software" procedures, such as permits to work, and initiated "hardware" changes based on lessons learned from the disaster. These included provision for and siting of emergency shutdown valves, subsea isolation systems, prevention of smoke ingress to accommodations, provision for better marking and screening of emergency walkways, and improved firefighting systems. The government inquiry into Piper Alpha, headed by Lord Cullen, was given two tasks: to determine the cause of the disaster and to recommend how similar disasters could be prevented. The U.K. Offshore Operators Assn. Ltd. (UKOOA) contributed to the second task by providing the majority of expert witnesses. Lord Cullen's report recommended sweeping changes to the U.K. regulatory regime and listed 106 specific recommendations for consideration by government and industry. UKOOA immediately endorsed the recommendations, is monitoring their implementation, and is coordinating the industry studies needed to support a number of them. Background UKOOA represents the 36 oil and gas companies designated operators of licenses on the U.K. continental shelf. Its main objectives are to provide an industry forum for discussion of matters of mutual interest to its members and, as appropriate, to provide the industry with a means of communication with the U.K. government and other relevant bodies. Its strength lies in the work of its committees. Volunteers from UKOOA's member companies comprise the 40 permanent committees and subcommittees. The Piper Alpha disaster shocked the industry and the general public. In the aftermath of the personal tragedies came the inevitable self-examination and uncertainty. The designs and operating procedures, which for so long had been considered dependable and safe, now looked vulnerable. What had gone wrong? What could be done to prevent a similar accident?

GOODWYN ‘A’ DRILLING FACILITIES

The Drilling Facilities Package designed and developed by Atwood Oceanics Australia Pty. Ltd. for operation on Woodside Offshore Petroleum Pty. Ltd.'s Goodwyn 'A' Platform will break new ground in the development and application of offshore modular drilling rig technology when commencement of offshore drilling is achieved. These facilities are among the largest, specifically designed, offshore demountable drilling rigs in the world today.Initially, Woodside performed sufficient engineering to determine a design specification for the Drilling Facilities which detailed the types of equipment necessary and the final performance characteristics required by the finished facility to drill the Goodwyn 'A' production wells.Following award of the Drilling Facilities Contract to Atwood Oceanics in 1989, Woodside's role was essentially related to technical interface and contract administration management. The responsibility for the design, fabrication, commissioning and operation of the Drilling Facilities lay with Atwood Oceanics.The Drilling Facilities consist of fifty-two (52) small modules, each weighing up to 105 tonne. These modules are assembled into three (3) major structural packages, these being the Drilling Support Facilities, weighing some 1300 tonne, the Sub-Base weighing 1100 tonne and the Derrick weighing 260 tonne. Total operating weight of the facilities will exceed 4500 tonne.The modular design of these facilities was developed by Atwood Oceanics from previous modular rig design of relatively simple facilities and technical scope, up to the high capacity, technical complexity and flexibility in design demanded for operation on the Goodwyn 'A' Platform. Following the issue of the Cullen Report on the Piper Alpha Disaster, extensive control and monitoring safety systems were included in the design. These systems have had an adverse impact on the modular concept due to the large increase in electrical interfaces, however the modular concept remains sound and viable.Modular rig design has allowed a Drilling Facility to be developed which has accrued savings in design, fabrication, fit-out, transport and installation and has resulted in reduced overall installed weight. These savings are real and demonstrable when compared with conventional large-module drilling rig packages of similar scope and complexity. Unlike its North Rankin 'A' development, Woodside elected to have the Drilling Facilities for Goodwyn 'A' designed, procured, fabricated and commissioned by an experienced drilling contractor, who will then operate and maintain the rig during the drilling phase (P.Scott et al., 1991). Woodside will realise substantial cost savings at the point when the facilities are installed and ready to drill. Further savings will accrue during drilling operations by allowing the drilling contractor more autonomy and responsibility (eg. maintenance of the complete drilling facilities will be by contractor personnel).The relative ease of removal of the facilities and potential for re-use on other installations will generate additional significant cost benefits in the future.The Drilling Facilities are state-of-the-art in their applied technology and are capable of year-round, self-contained operation for the drilling of highly deviated, long reach wells of up to 72° deviation from the vertical and up to 7000 m along hole depth.This paper provides an overview of the design, fabrication, fit-out, onshore commissioning, transport and installation of the modules which comprise the Goodwyn 'A' Drilling Facilities, for which Atwood Oceanics were awarded a Commendation for a High Standard of Engineering Achievement at the Institution of Engineers, Australia 1992 Engineering Excellence Awards.

Development and production prospects for UK oil and gas post-Gulf crisis: A financial simulation

The operating environment within which North Sea oil and gas exploitation is taking place is both uncertain and subject to continuous change. Some of the major influences, such as oil price movements, are exogenous, being determined essentially by factors outwith the province. Others, such as the implementation of the recommendations of the Cullen Report 1 on safety issues, have arisen from factors within the province. In an extractive industry with production subject both to natural and inevitable depletion, and to repletion through the development of new discoveries, there is an inherent dynamic whose overall consequences are not immediately obvious.