Safety Cases have precipitated a cultural change within the oil and gas industry. Operators and owners now understand, assess and own the Major Accident Hazards (MAHs) on their installations. This has led to better design and operations offshore (for example, the introduction of operational risk assessments). However, as time has progressed the information contained within the Safety Cases has become saturated making it less user-friendly for the workforce who it is aimed to benefit. This poses the question; how do we make our Safety Cases fit for purpose?
In most cases, over time information is only ever added to the Safety Case, meaning that it grows and loses focus. Often Safety Cases run into 1000+ pages which becomes impossible to manage effectively. Operators tend to verge on the side of caution, believing that ‘the more information the better’ with respect to meeting the regulatory requirements.
At present, the OGUK are developing a technical note for workforce involvement with regards to Safety Cases, which highlights the concern within the industry at present. This is the fourth initiative under the ‘Safety Case for the Future’ programme, which has previously covered guidance on what constitutes a material change, thorough reviews, and safety case content. One method which has been adopted by several operators has been to develop slimline Safety Cases or Safety Case lite versions of the document to try to close the workforce engagement gap which comes with additional costs and maintenance for the operator going forward.
In addition, during recent thorough reviews and audits DNV have noted that minor safety case changes can often be missed through the Management of Change (MoC) process. The significant volume of information within the Safety Case can make it difficult for users to identify where minor modifications may impact various parts of the case. On the contrary, where major modifications have taken place a large volume of detail is usually added to the Safety Case which can be overkill as to what is required and is inconsistent with the level of detail provided for the existing plant.
With high volume safety cases, a large number of figures and drawings are normally included to support the text. Often, this results in out of date figures where the original source (which may be a controlled drawing) has been updated out with the Safety Case itself. This has become an increasing issue in recent years where a number of North Sea mergers and acquisitions have taken place which result in processes and procedures regularly being updated. This can create a lack of consistency within an organization with respect to their Safety Cases or SEMS description where several assets are owned.The challenge is: how do we manage the safety case to make it efficient to update in the future, provide a robust demonstration of the case for safety, but be an approachable document that the workforce can use?
DNV Safety Case Rationalization: Outcome and Benefits
DNV have recently undertaken Safety Case rationalizations for several North Sea installations.
The most noticeable outcome from the Safety Case rationalizations are significant reductions in the length of the case from ~1000 pages to ~300 pages, which makes it much more accessible for the workforce and easier to manage. A reduction in size and more structured approach makes information easier to find making future updates (including MoCs) simpler without complex formatting.
Rationalization results in increased usefulness of the Safety Case, with a document that is focused on MAHs, SECEs and risk management. Safety Cases which have been rationalized by DNV followed a process to ensure any restructuring is traceable and thus have been well received by the HSE without the need for a material change submission.
Understanding the customer problem and addressing the needs of both the regulatory requirements and the workforce is key to DNV’s approach. With the introduction of the new Topic Assessment Guidance (TAGs) from the HSE in 2021, there is no better time to refresh the Safety Case.
If you want to know more or feel like your Safety Case could benefit from rationalization, please get in touch.