The Management of Safety-Critical Elements – Finding the Gaps in Your Operation

On 20^th April 2010, a blowout of BP’s Macondo well in the Gulf of Mexico led to the deaths of 11 workers on Transocean’s Deepwater Horizon drilling rig, and the release of an estimated 4.9 million barrels of oil. Following this incident, a UK-based inquiry concluded that independent verification of well design, well equipment and safety and environmental critical element (SECE) was a critical factor in reducing the likelihood of such an event being realised on the United Kingdom Continental Shelf (UKCS).

At Vysus Group we have a completely unique overview of all aspects of asset operation due to the breadth of our service lines, which range from rig inspection to production and process facility specific asset management and optimisation services. What this unparalleled perspective gives our objective and impartial eye, is visibility to a variety of existing and emerging trends, both good and bad in nature.

One service that has proven to be of increasing value to a growing subset of our client base has been the review of SECE maintenance. Within this type of study, we conduct deep-dive reviews regarding the efficiency and effectiveness of performance standards, helping our clients to build upon the regulatory requirements set out in the 2015 Offshore Safety Case Regulations.

These bespoke reviews are integral in the proof of legislatively compliant risk management, to a level as low as reasonably practicable (ALARP), as well as containing the expert interpretation of the application of sections of the Offshore Safety Directive Regulator’s (OSDR) Competent Authority (CA) document, Offshore SECE Management and Verification Inspection Guide (Date: 01/03/2020).

Depending on client requirements, these reviews generally involve an examination of measurable criteria relating to the performance standards, generally in terms of functionality, availability, reliability, survivability, and interdependence. This is then followed by a further study of the suitability, logic, accuracy, and application of the applicable assurance tasks, maintenance tests, checks and inspection activities.

As a result of these inspections and our experience, we would like to share five common findings. The reason behind the sharing of this information is the hope that responsible and diligent professionals will use this information when checking their own systems and processes and so proactively manage the latent risk that our engineers and inspection specialists often uncover:

1. Vague/poorly defined/ no standards of SECE performance.
2. Aspirational availability statements with no actual assurance analysis.
3. False positives from SECE testing that requires pre-emptive equipment checks.
4. SECE equipment omitted from a recognised formal programme of testing.
5. Maintenance tasks wrongly categorised as having SECE relevance.

Unfortunately, the duty holder is invariably unaware of these issues. We have even found examples where issues have been in place for an extended amount of time and have grown to a concerning magnitude, with a complexity and nature that are beyond the conventional verification activities and scrutiny of the appointed Independent Competent Person (ICP).

Our assessment of the underlying causes has revealed three common occurrences:

1. The development of operational performance standards and maintenance programme in isolation of each other, and by different parties.
2. Lack of robust management of change (MoC) that does not sufficiently encompass the entire path of change (drawings, asset register, inspection, and maintenance programmes, etc.).
3. Insufficient planning and mapping of data during maintenance management system migration (for example, a move from Maximo to SAP upon change of asset ownership).

If you would like to discuss these findings or explore the processes that we at Vysus Group use to extract meaningful results from maintenance management data, feel free to get in touch with our Asset Management Consulting (AMC) team, we’d love to hear from you!