The organisation wrote an open letter to the offshore industry in April 2018 calling for it to do more to reduce hydrocarbon releases (HCRs).
HSE’s director of its energy division, Chris Flint, said at the time that several have come close to disaster: “Poor plant condition, and breaches of procedures are often immediate causes, but beneath that we often find a lack of leadership, a poor safety culture, and evidence that weaknesses have existed for some time, but haven’t been picked up through audit, assurance and review, and then dealt with.”
The letter coincided with publication of revised loss of containment inspection guidance and a Step Change in Safety best practice guide to prevention of HCRs. Industry trade body Oil & Gas UK, also responded at the time to say that, although HCRs were on a downward trend, there was no room for complacency. It provided much more detail in a December 2018 environmental assessment report that covered 2017.
In that time, the 451 accidental releases of oil and chemicals included 253 ‘unplanned’ releases of oil, totalling approximately 23 tonnes. However, that makes up only about 1% of the total oil that entered the marine environment; in the same period, 2,000 tonnes were legally discharged to sea with produced water.
The report points out that low frequency, high-mass releases account for most of the totals. For example, since 2011, oil releases of more than 10t made up less than 1% of the total number of releases, but 82% of the total mass released.
The report states: “The UK oil and gas industry does its utmost to minimise accidental oil and chemical releases by addressing the plant, process and people elements that could prevent or mitigate such releases. The industry invests in these barriers through maintenance programmes to ensure the integrity of equipment; the provision of multiple physical barriers, such as downhole safety valves, closed drains, and bunding; through development of handling procedures that minimise the potential for releases; and in ongoing staff training and competence management to ensure personnel manage any risks to the environment.”
On 21 December, HSE released more details of meetings it had with offshore operators. In particular, it identified two good practices: using structured protocols for senior leaders to follow when attending offshore installations, and specifically defining process safety behaviour expectations for each role.
HSE said that good progress had been made in sharing lessons from incidents, and lessons from HSE inspection findings.
It also said that its inspections over the past year had found that audit and assurance systems remain a priority for improvement. Other particular weaknesses were observed in change management, and safe isolation and reinstatement of plant. Those were also significant causes of several hydrocarbon releases recently.