Investigation, Regulation & Practices

In the late 1960s and early 1970s, there were three offshore events which focused the attention of the US Geological Survey (USGS) on tightening the regulations for offshore safety affecting the petroleum production offshore industry. These were the Unocal Santa Barbara blowout, the Chevron Main Pass platform fire, and the Shell Bay Marchand platform fire. In 1971, a report was prepared by the National Aeronautics & Space Administration (NASA) for the USGS entitled “Applicability of NASA Contract Quality Management and Failure Mode & Effect Analysis (FMEA) Procedures to the US OCS Oil and Lease Management Program.” USGS also contracted General Electric (GE) and Southwest Research Institute (SWRI) to analyze several offshore platform facilities. In May 1972 the USGS published the “OCS Lease Management Study” stating that design specifications for a safety program be implemented by the industry and that hazard analysis should be part of the application for new platforms and associated production equipment. The USGS published in the Federal Register the intent to require an FMEA analysis for each new installation as well as major modifications to existing installations.

In 1972 the API formed the Offshore Safety & Anti-Pollution (OSAPE) committee to be a part of the API Standards Committee. The chairman of this committee was Larry Smith, Engineering Manager of Shell in New Orleans. One of the first jobs of the committee was to respond to the Federal Register notice. An OOC technical sub-committee, chaired by Ken Arnold, Offshore Division Mechanical Engineer for Shell, was tasked with studying the previous reports from NASA, GE and SWRI.

Ken presented a paper titled “A Systems Approach to Offshore Facilities Design” to the 1973 API Division of Production Annual Meeting in Denver. The techniques, as shown in Ken’s paper, were expanded by the OSAPE 14C Committee and were published in 1974 as API RP 14C. RP 14C has been updated periodically since 1974 and has been adopted in concept with minor revisions as an ISO International Standard. 

Recognizing the pioneering efforts of the following individuals and organizations that pioneered the development of these regulations and associated practices:

Ken Arnold, Bob McConnell, Larry Smith, American Petroleum Institute, Shell

In 1990 the National Research Council’s Marine Board submitted a report to the Minerals Management Service (MMS)  concluding that the MMS’s prescriptive approach to regulating offshore operations had forced industry into a compliance  mentality.  This compliance mentality was not conducive to effectively identifying potential operational risks or developing  comprehensive accident mitigation.  The report recommended that a less prescriptive and more systematic approach to managing safety in operations was needed.

In 1992, MMS published their intent to develop a Safety and Environmental management Systems (SEMS) rule for  managing safety in a way that recognizes that safety is largely dependent on proper human behavior.  SEMS would require  operators to manage safety taking dependent on proper human behavior.  SEMS would require operators to manage safety  taking into account management principles of planning, organizing, implementing and evaluating.

As a result, in 1993 API RP-75 (SEMP) was developed in cooperation between MMS and API as a guideline for operators  to meet the objectives of the proposed SEMS rule.  At the same time, API also produced a companion document, FP-14J,  a guideline for safety design and hazards analysis. In 1994, MMS formally recognized implementation of RP-75 as meeting the spirit and intent of SEMS. Rather than making SEMP mandatory, MMS asked operators to voluntarily adopt it.  MSS in cooperation with the Offshore Operators Committee held a series of public meetings, seminars, and workshops to promote and encourage implementation.

In 2006, based on incident investigation findings and performance reviews with operators, MMS identified a need for performance improvement in four areas: hazards analysis, operating procedures, mechanical integrity, and management of change.  These areas were part of RP75.  After several meetings, both the MMS and industry decided it was best to adopt RP75 as a whole rather than some of its elements in isolation. On October 15, 2010, MMS published 30 CFR Part 250 Subpart S – Safety and Environmental Management Systems.   This Rule incorporates by reference, and makes mandatory, RP 75, Third Edition.

Recognizing the pioneering efforts of the following individuals and organizations that contributed to this technology:
Ken Arnold, Henry (Hank) Bartholomew, Virgil Harris, Charles (Chuck) Liles,  John Rullman, Alan Spackman, Peter Velez, Robert (Bob) Waldrup, and Jeff Wiese, API (American Petroleum Institute), Exxon (now ExxonMobil),  IADC (International Association of Drilling Contractors), M.M.S. (now BSEE), Newfield Exploration, OOC, Paragon Engineering Services and Shell.

The development of standards, guidelines, and Rules to ensure safe design, quality construction, and verify that offshore equipment was built to a recognized standard, helped the industry. These Rules also assured domestic and foreign regulatory authorities, charged with safety on their continental shelves, that the equipment being used to explore for oil and gas in their waters was safe. The American Bureau of Shipping (ABS) led an industry effort by forming a Special Committee to write Rules by which structural and mechanical fitness-for-purpose of Mobile Offshore Drilling Units (MODUs) could be assured. The ABS Rules for Building and Classing Mobile Drilling Units was first published in 1968. In large part, the later International Maritime Consultative Organization (IMCO) rules for MODUs were based on these. Many engineers and naval architects within the industry, the ABS, and U.S. Coast Guard (USCG) contributed to developing the Rules. The Committee was made up of drilling contractors, oil companies, designers, building yards, USCG, and ABS specialists. The names of the 1968 ABS MODU committee are given below.

Recognizing the pioneering efforts of the following people and companies who contributed to the development of this technology:

Frederik H. “Henry” Ackema, Norman D. “Scotty” Birrell, Richard L. Brown, Garvin W. Cooper, H.E. Denzler, Jr., John C. Estes, D.H. Falkingham, G.B. Grafton, John R. Graham, James W. Greely, Edwin Hartzman, M.D. Korkut, Dean A. Kypke, C.W. Levingston, Sam H. Lloyd, Charles O. Macdonald, Robert H. Macy, Foster T. Manning, Richard M. Marsh, William A. Martinovich, W.L. McDonald Jr., Walter H. Michel, A.R. Newman, M. O. Pattison, F. “Tim” Pease, Ralph E. Scales, George L. Temple, American Bureau of Shipping, Avondale, Bethlehem Steel, Chevron (ChevronTexaco), Conoco, Earl & Wright (Kvaerner R. J. Brown) Friede & Goldman Ltd., Global Marine (GlobalSantaFe), Humble Oil & Refining Co. (ExxonMobil), Kerr-McGee, Mobil, ODECO (Diamond Offshore), Pan American Petroleum (BP), Reading & Bates (Transocean Inc.), Santa Fe International (Transocean, Inc.), SEDCO (Sedco Forex), Shell, The Offshore Co. (Transocean Inc.), U.S. Coast Guard, WODECO. 

On 6 July 1988, gas condensate ignited on Occidental Petroleum’s Piper Alpha platform in the North Sea. In a brief 22 minutes, 167 of the 229 people onboard were killed in what is characterized as the most deadly disaster in offshore oil industry history.

Lord Cullen of Whitekirk, one of Scotland’s most-respected jurists, led the public inquiry. Originally charged with determining what happened on Piper Alpha, Lord Cullen proactively undertook to develop recommendations to prevent recurrence of such a disaster. Wisely rejecting a prescriptive approach, he developed comprehensive objectives and made 106 specific recommendations to initiate a new and improved safety regime.

Ultimately, anyone wishing to operate a fixed or mobile installation offshore UK was obliged to submit a Safety Case. These are documents providing full details for managing Health, Safety and Environment issues. Because a goal-setting approach was used, operators are able to choose the best methods available to achieve the objective. As a result, reportable offshore industry accidents had declined more than 75% by 2001.

Most importantly, Lord Cullen’s report reassured all stakeholders—the oil industry, the UK Government and its citizens—that offshore oil and gas operations could be conducted safely if a rational, goal-oriented approach were implemented, together with effective application of technology and stringent inspection procedures.

For his exceptional attention to detail, perseverance, foresight and integrity that has resulted in a “step-change” in offshore safety performance, the Oilfield Energy Center recognizes:

The Right Honorable Lord Cullen of Whitekirk

Following the tragic destruction of the Piper Alpha in July 1988, a public inquiry into the incident was led by Lord Cullen of Whitekirk. The report included comprehensive objectives and made more than a hundred recommendations for a new approach to safety – commonly referred to as a Safety Case. Ultimately, anyone wishing to operate a fixed or mobile installation offshore UK was obliged to submit a Safety Case. These are documents providing full details for managing Health, Safety and Environmental issues.

After the publication of the Cullen Report, drilling contractors operating on the UK Continental Shelf came together under the auspices of the IADC North Shore Chapter to work on a set of guidelines. The precursor to the present Guidelines, the 1992 IADC Preparing a MODU Safety Case, states that the intent was that “[IADC] should commission a workbook to guide member companies through the necessary steps in the production of a Safety Case. The approach was to set out a methodology and the objectives to be achieved to guide users in what subjects need to be addressed and how they might be effectively organized into a Safety Case. It was soon recognized that the initial Guidelines were too focused on satisfying the particular concerns of an individual regulation within an individual country and would benefit not only from a more holistic approach to management, but also by incorporation of concepts put forward by other regulators toward the goal of more effective HSE management. Thus, the present form of the Guidelines was adopted and issued in 2003.

Today, the IADC HSE Case Guidelines are the leading authority for constructing Safety Cases on a worldwide basis. They are utilized by both Contractors and Operators around the world. As part of IADC and its members’ commitment to safety, the Guidelines are available free through the IADC’s website.
Recognizing the pioneering efforts of the organization that contributed to this technology:

International Association of Drilling Contractors (IADC)

On February 15, 1982, during a severe storm, the semisubmersible mobile offshore drilling unit (MODU) Ocean Ranger capsized and sank on location 170 miles off the coast of Nova Scotia in 180 ft. of water.  All 84 crewmen were lost, including some who escaped in lifeboats but did not survive until rescue.  At the time, the Ocean Ranger was one of the largest, most technological advanced and modern MODUs in the world; thus its loss was of significant concern to Canadian and international governments, MODU designers, certification and regulatory agencies and societies, and especially the offshore oil and gas industry.  A Canadian Royal Commission was formed, and after an exhaustive and critical investigation, two reports were issued in 1985 that had significant and immediate impact on the design of MODUs, their regulation, classification and safety at sea.  Other incidents had occurred before in the offshore oil and gas industry, but the Ocean Ranger investigation and recommendations uniquely centered on the entire scope of marine technology, training, competency, regulations and their enforcement, and safety at sea.  This was the first time the industry was brought together to study safety as a system rather than its individual parts.  The reports and resulting recommended actions served as a model for future investigation methodologies, such as Lord Cullen’s Piper Alpha incident report in the North Sea and the Gulf of Mexico Macondo incident. The recommendations had a significant influence on all offshore vessels and structures beyond MODUs and the offshore oil and gas industry in general. 

Causes of the Ocean Ranger incident were multiple, including faulty design features, inadequate crew competency requirements, lack of required crew training, poor and confusing government involvement and oversight, poor understanding of emergency operation procedures, inadequate lifesaving equipment, ineffective emergency response, and approval of equipment by the registration agency despite non-compliance with agency rules..  A summary of recommendations and their impact follows: 

  1. MODU Design:  Recommended stability requirements stated that the down-flooding angle was to be controlled by the first opening – such as chain lockers.  No portholes could be installed below waterline in the down-flooded mode and two-compartment damage was a mandated requirement.  Pumping water by the ballast system should be capable at the maximum allowable down-flooding angle.  Classification societies such as American Bureau of Shipping (ABS), Det Norske Veritas (DNV), Lloyds of London and others adopted the recommendations, as did Regulators including United States Coast Guard (USCG). 
  1. Safety Equipment:  Recommendations were made that regulator and classification entities tighten and strengthen regulations on life saving equipment such as lifeboats, launch mechanisms for lifeboats, life preservers, survival suits, servicing requirements for safety equipment, etc.  International Maritime Organization (IMO), USCG and others adopted the recommendations and guidelines. 
  1. Training and Competency of Marine Personnel:  Prior to the incident there were no training and licensing requirements for marine officers, Offshore Installation Managers (OIM), ballast control operators and/or barge engineers on MODUs.  The USCG, followed by other foreign equivalents, set up requirements for training, strict licensing, drills and recertification dates.  Simulators of ballast systems followed and are now a requirement for training.   
  1. Marine Operating Manuals:  Major enhancement of marine manuals was recommended and required, thus giving detailed data, procedures and necessary information to operate MODUs.  This recommendation and its resulting implementation had a significant impact on onboard documentation, resulting in accurate information available daily to all crewmen and those in charge. 
  1. Coordination between all Agencies, Societies and Regulators:  The Ocean Ranger incident tragically showed that all classification and regulatory entities involved in MODUs and their operation needed to develop cooperative lines of authority and assignment of duties, which has since been done.  This effort spilled over into every aspect of the offshore oil and gas industry.   
  1. Risk Analysis Applicable to the Offshore Oil and Gas Industry:  The concept of weighing risk was suggested and then adopted by many entities insofar as assessing impacts of operating an offshore oil and gas location.  System analyses of risk and the concept of ensuring safety critical systems were applied to MODUs.  DNV followed this approach as one of its services. 
  1. Metocean Criteria:  The concept of matching metocean criteria to facilities and operations was initiated and implemented in what is now standard operating procedure. 

In summary, the Royal Commission investigation, reports and recommendations resulted in major changes and improvements to all types of drilling rigs as well as the overall offshore oil and gas industry. 

Companies Honored:  Canadian Ocean Ranger Royal Commission 

Individuals Honored:  T. A. Hickman, Ewan Curlett, Derek Muggeridge, David Grenville and Bevin LeDrew all of the Royal Commission, and Ralph Loomis (ODECO) now Diamond Offshore Drilling Co.

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