Loss of Containment Manual
Reducing Offshore Hydrocarbon Releases
This document, originally designed to give guidance to inspectors under the Key
... [Show More] Programme 1
- ‘Reducing offshore hydrocarbon releases’ initiative, indicates ten important elements relating
to the management of the integrity of the process containment envelope and provides advice
on topics for inspection within each of the elements. The maintenance of high standards of
operation in these areas should help to minimise the frequency of occurrence of offshore
hydrocarbon leaks.
Asset Integrity Programme
This programme, known as KP3 ran from 2004 to 2007. It focused on the effective
management and maintenance of safety critical elements. Inspectors using a template, which
covered a number of key topics, obtained an overall picture of industry performance. One
topic, relevant to loss of containment prevention, where performance was poor was Topic C –
Maintenance of safety critical elements.
Offshore Hydrocarbon Releases
HSL was asked to identify the main causes of major and significant releases between 2001
and 2007 using the Hydrocarbon Releases Database. Information was obtained on systems,
equipment types, equipment causes, operational causes, procedural cause and operational
mode. The key issues and underlying causes relating to hydrocarbon releases are
summarised below.
• Evidence suggests that piping systems, including flanges and valves collectively
continue to be a major source of Hydro Carbon Releases (HCRs), with piping being the
single largest contributor. Instruments (i.e. Small Bore Tubings (SBTs)) contribute the
second largest single source of HCRs. Gas Compression is the operating system
having the highest number of HCRs.
• Incorrectly fitted equipment is the most widespread operational cause followed by
improper operation (i.e. human factor issues) where operational failures are reported.
• Non-compliance with procedure (i.e. human factors issue) is the most common
procedural cause where procedural failures are reported.
• Reported experience of inspection and survey on SBT systems suggests that 26% of
fittings examined are found to contain faults, e.g. under-tightness, incorrect or
mismatched components, leaks, incorrect or poor installation, etc., and that this failure
rate has remained constant from 2001 to 2007.
- 3 -
Part 1 - Management of process integrity
This part involves onshore inspection. It reviews the way in which process integrity is
managed, and is intended to examine and reinforce the role of onshore management.
Item Inspection Topics Guidance Notes
1.1 Policy / Record of Arrangements
1.1.1 Is there a policy statement,
and / or any other record of
the arrangements for
managing process safety, or
is it rolled into the overall
SMS?
If so, is it adequately
defined, communicated, and
put into practice?
Is process integrity
adequately included in an
SMS improvement
programme?
A good policy statement, or record of arrangements, would
include principles such as:
• inherent safety
• hierarchy of prevention, detection, control, mitigation
• role of risk assessment and ALARP principles
• maintaining up to date documentation
• competence, and adequacy of resources
• working within a safe operating envelope
• control of changes that impact on process safety
• maintenance / verification of safety critical systems
• line management monitoring
• independent management and technical audits
• establishing basic causes of accidents / incidents
• reviewing process safety performance
• continuous improvement, with improvement plans
• Principles of quality management e.g. ISO 9000.
Legal
Basis
An employer has a legal duty under s.2 (3) of HSWA to have a written policy statement
with respect to health and safety. This statement of his general policy should include the
organisation and arrangements for carrying out that policy, including those applicable to
process safety. MHSWR, Reg. 5 requires a record of arrangements for planning,
organisation, control, monitoring and review of preventive and protective measures. A
policy statement addressing process safety management will help define the management
requirements. Senior management should endorse the policy, which should be adequately
communicated; commitment to it should be visibly demonstrated.
1.2 Accountabilities / Responsibilities / Resources
1.2.1 Accountabilities etc.
Are responsibilities /
accountabilities for process
integrity adequately defined
and allocated (e.g. between
operational and technical
functions)?
Responsibilities for process integrity should be assigned,
and accountability reinforced through job descriptions.
There should be a senior figure in the organisation to coordinate general safety policy implementation, and a
safety management programme with objectives and
performance criteria. Process safety may have a separate
programme, or it may be integrated into the general
programme.
Responsibilities should generally be allocated to line
managers, with specialists acting as advisers.
Responsibilities and accountabilities should be clearly
assigned (e.g. responsibilities should be allocated
between operational and technical functions, with a
nominated technical custodian for process integrity) and
appropriately reinforced (e.g. through performance
reviews). Line management should be actively involved in
monitoring performance, and evaluating the achievement
of performance criteria.
1.2.2 Technical Support There should be sufficient resources and expertise for [Show Less]