Learning from High Risk Industries

If there was another devastating disaster offshore on the lines of Piper Alpha, most companies operating or working in the North Sea would be vastly better prepared to handle it than they were 15 years ago. Every offshore oil and gas installation now has a personalised safety case, with detailed emergency response plans, a comprehensive safety infrastructure offshore, and a trained workforce, whose prime responsibility is the safety of themselves and their fellow workers.

Having learned some hard lessons, high risk industries have responded by setting standards and embracing tough new regulations. They have adopted policies supporting emergency response best practice, and have nurtured their culture with the aim of making safety everyone’s priority. As a result, today’s oil and gas industry represents what is often considered to be industry best practice in the UK for emergency planning, preparedness and response. It makes good sense for other companies to align their emergency planning with this or other high risk sectors.

Regulation
The introduction of a stringently regulated environment has contributed to much of the improvement. Relevant regulations include Design Control Regulations (DCR), along with Prevention of Fire Explosion and Emergency Response Regulations (PFEER), for offshore, and the Control of Major Accident Hazard (COMAH) regulations for onshore (fig. 1)

The improvement is also due to the empowerment of the offshore installation manager (OIM) on a production platform. He now has the authority to shut down oil and gas production. Advances in global positioning and communications systems also make it unlikely that an offshore installation with an emergency would be out of touch with the mainland, the Maritime Coastguard Agency or its parent company and its support.

OIMs are highly trained for emergencies, and safety teams are integral to the day to day function of the installation, whether on a drilling rig manned by 40 people, a floating production storage and offloading unit or a production platform with 140 men and women on a structure that is sitting on the seabed in 400ft of water. And the UK oil and gas industry sets the tone for the planning process in other industries.

Assessing the risk
The oil and gas industry is high risk by anyone’s estimation – volatile liquids, flammable gases, toxic H2S, heavy equipment in a remote and often hostile environment, often hundreds of miles away from normal emergency services and medical units. It represents 30,000 people working in an environment that must be self-sufficient, self-reliant and resourced for any eventuality.

Whether the emergency involves a scenario like Piper Alpha, or the upturned hull of the Aleksander Kjelland oil production platform in a Norwegian fjord, the planning process can anticipate risks before they turn into disasters, and put in place operational solutions to prevent the worst happening. In addition, companies operating in the high risk sector are subject to all of the normal risks associated with running a large business where continuity and assurance to stakeholders are of great importance. Risk assessment and scenario identification are not limited, therefore, to operations. but are also tied into the business activity.

At the root of the planning process is the assessment of risk, and what you actually need to prepare for. With detailed risk assessments that identify all the scenarios that could have serious impact on both operations and business, an organisation can evaluate its potential problems, tackle the factors that might trigger a nightmare scenario, and prepare the work force to minimise the impact on people, property and the environment should the worst happen.

Emergency response plans must be based on scenarios that are clearly linked to the risks. There must also be a clear learning linkage between risk management and emergency response, with relevant experts working closely to ensure that this happens. Only then can the organisation, training and competency of the individuals fulfiling key roles be properly addressed (fig. 2).

The risk identification and assessment process for operations and business is the first step in preparing to respond to any incident. Put in place the proper procedures when a serious incident happens, and you will have gone a long way towards creating the opportunity to have a well-managed incident – as well as demonstrating to your insurance company that you are a good risk. This important planning process will address your organisation’s need to maximise survivability and minimise loss at operational, tactical and strategic levels, and will result in the development of an emergency response and crisis management system to properly manage your calculated risks, including business continuity.

It is essential, therefore, that emergency response planners offer the broadest range of relevant skills, look at how the emergency services will interface with your organisation, consider the community relations in the vicinity of your plant, determine how you might respond to a kidnap or a terrorist threat or attack, and work with the local authority to manage transport, cleanup, medical assistance or evacuation.

Emergency response planners also need to consider business continuity scenarios and tie them into the emergency response arrangements, using the best practice associated with risk and scenario linkage. Therefore, as well as the more obvious insured requirements, such as damage to property and third parties, plus injuries to employees or others, they need to consider a large number of unseen and often uninsured risks. These include, clear-up costs, legal costs, public relations expenses, man-hours lost in investigations and legal wrangles, and, of course, loss of business continuity and assets. Plans must cover the hidden part of the iceberg as well as the part that lies above the surface (fig. 3)

However, comprehensive planning only provides the foundation for an effective response. Organisations must ensure that the necessary resources are available to support the plan. They must analyse training needs and run effective training programmes that build confidence and competence. It is essential to phase the training programme so that people fully understand their individual and collective roles and responsibilities. Too often, pressured training contributes to destroying people’s confidence and understanding, rather than increasing it.

It is vital to ensure that key people or those fulfiling mission-critical roles are competent. This involves identifying standards and using them when training such individuals, combined with some form of assessment. Such standards can easily be built for individual organisations, or can be adopted from an industry body, such as COGENT (the oil and gas industry training standards body).

Investing in preparedness is cost-effective. Skilled emergency response specialists ensure that your organisation builds up a matrix of protection for itself. They will not only assess operational vulnerabilities, but will also ensure that business risks are tied into the arrangements, including compliance in the countries where the organisation operates. They can develop the right people to manage the company through a crisis, provide methods of consistently applying standards worldwide, and build a system of response capability that will minimise the impact of an incident, and generate peace of mind across the senior management team. Using a process built on the learning from the high risk sectors draws upon a solid base of expertise and experience (fig. 4).

Bringing the organisation’s corporate culture into the equation is essential. Taking account of employee behaviour and fears is part of the planning and communication process, and facing the outside world with a good media spokesman may prevent loss of customers and failure to save the business.

No emergency response plan is complete without assessment and preparation for environmental risks, whether pollution or damage to local communities. Public perception plays a significant role in how pollution is handled. For example, in the oil industry, dispersing spills with detergent may look responsible and effective, but leaving nature to disperse light oil naturally is often the more environmentally sensitive response. Environmental impact might be an important factor in your plan, but clean-up processes need to be publicly acceptable these days.

Political uncertainties
Political instability may be relevant. Companies operating with hazardous processes on a day-to-day basis know the risks and where their vulnerabilities lie, but they need to combine that knowledge with other considerations if they have a facility located in a political hotspot. How do you plan in these circumstances? Again, the oil and gas industry has experience here.

Emergency response specialists working in this sector must ensure that the scenarios used to build the plans are born out of both intrinsic and extrinsic risk. Extrinsic risk is particularly relevant to working in remote locations, which is typical for the oil and gas industry. It encompasses a wide range – from extreme weather in Kazakhstan, rebels in Angola, tribal unrest in Nigeria, war in Iraq, the outbreak of a serious infectious disease, through to political instability in Indonesia. All scenarios are built into the emergency response arrangements.

This makes companies in the oil and gas industry less susceptible to changing world, regional or country events. With clearly mapped-out processes for protecting their people, the environment, their plant, and their business, all married into one system, the aim is to build resilience, so they can absorb shock and recover as quickly as possible

Consider the magnitude of risks being managed by oil and gas companies, as well as other high risk operators, on a day to day basis. Ten thousand project construction workers within the vicinity of an operating plant in a remote desert location, which produces sour gas (high H2S content), presents a huge risk, which the operator must reduce as much as is reasonably practical. Mitigation through preventative action is half the equation. The other half is about effective response systems, equipment availability and proper training for all involved. If arrangements are put in place to manage this type of risk, the risk associated with potential conflict, the evacuation of staff out of the country, or the reaction to a terrorist threat, can be managed using the same response arrangements.

Obviously the risks associated with working in certain locations are high. In some circumstances, the consequences of an incident could be severe even with well made plans. However, through following a comprehensive risk assessment process, the organisation can at least fully appreciate these risks in advance and take the necessary actions to keep them as low as reasonably practical.

Exporting best practice
Companies in the high risk sector, such as those operating in the North Sea, have to demonstrate their ability to respond to an emergency. They must maintain manning levels to include the necessary level of trained personnel capable of responding to a major accident. Basic induction training to the right level for each role is mandatory. With over a dozen different subcontracted organisations employing staff on an offshore installation, cultural differences have to be overcome. A host of different companies have to interface, work together, communicate effectively and operate to the same high standards of safety.

Preparedness planners with North Sea oil and gas industry expertise are now exporting their skills to other industries and to other countries. Their new clients encompass a wide range of sectors, which include distilleries and food manufacturers who are concerned to adopt best practice. They are also being asked to provide services to clients in regions outside Europe, using standards created by UK and European legislation (fig. 5).

Organisations in any business environment are exposed to an increasingly diverse range of risks. At the same time, roles and responsibilities are being redefined as stakeholders demand accountability for safer, sustainable, legal and ethical operations. The lessons learned and subsequent approach to emergency response within high-risk industry are comprehensive, and cater for a whole range of risks, intrinsic and extrinsic for operations and business.

Jim Walker is business manager of Rubicon Response Limited, which advises high risk industries on how to plan and prepare their responses to incidents.

Tel: 01224 729814

Emergency, crisis and business continuity management
Adopting a comprehensive approach to emergency planning, using lessons learned within the high risk sector, involves the following.

Assess: conduct assessments to determine the needs of the organisation and make plans for any remedial action.

Develop policy: produce an emergency response policy which satisfies legal and regulatory requirements and complies with internal and external regulations.

Prepare plans: build a plan that incorporates the tactics and procedures that your organisation will use in an emergency.

Organise resources: look at appropriate facilities, equipment and specialist resources. Build a team that will deliver the right response.

Training: develop training programmes to achieve levels of acceptable competence in emergency response, and run simulation exercises to test the system.

Exercise Validate your organisation’s capability to respond once the plan is in place, and allow responders to practise.

BCM guide
BSI, in conjunction with the Business Continuity Institute, has published a guide which establishes the process, principles and terminology of business continuity management (BCM). PAS 56 Guide to business continuity management describes the activities involved in establishing a BCM process, and gives recommendations on good practice. It provides a generic BCM framework for incident anticipation and response and describes evaluation techniques.

The Guide costs £52, or £26 for BSI subscribing members. It can be obtained from BSI, Tel: 020 8996 9001, E-mail: orders@bsi-global.com