Story Highlight
– Isolation failures cause serious risks on offshore installations.
– HSE finds serious deficiencies during inspections and enforcement.
– Operators not following existing isolation procedures effectively.
– Critical gaps identified in hazard identification and planning.
– Updated guidance will emphasize safe isolation inspections.
Full Story
Concerns about hydrocarbon releases within offshore structures on the UK Continental Shelf have resurfaced, with the Health and Safety Executive (HSE) noting that improper isolation practices are at the forefront of these safety issues. These incidents, far from being minor, carry the potential for grave consequences, including serious injuries or even fatalities if ignited.
In light of these risks, the HSE has committed to raising awareness around these critical safety failures, sharing insights from its inspections and investigations to aid operators in enhancing their safety protocols. This proactive approach aims to prevent accidents by ensuring that all workplace safety measures are properly implemented and adhered to.
Scott Templeton, Principal Specialist Inspector in HSE’s Energy Division – Offshore, emphasised the gap between written procedures and actual compliance. He stated, “The problem is not the procedures on paper, it is that people are not following them. Most UK operators have isolation procedures that broadly follow HSG 253 (the guidance on safe isolation of plant and equipment).” He reiterated that sustainable improvements in safety practices necessitate a unified commitment from all levels of a company. “Effective and lasting improvement requires everyone involved in isolations, from senior management to those carrying out work on the plant, to share a genuine commitment to achieving and maintaining isolation procedures and practice to the required standard,” he added. The HSE plans to release updated inspection guidance soon to clarify the assessment criteria for operators, reaffirming that safe isolation will continue to be a primary focus in inspections.
Recent HSE inspections have highlighted several critical inadequacies in offshore isolation practices. Among the most concerning findings is the failure of certain company standards to meet the requirements set out in HSG 253. In some instances, duty holder ‘selection tools’ established isolation standards that are lower than those mandated by HSG 253. Furthermore, the identification of hazards has proven inadequate, with risk assessments often overlooking essential factors such as trapped fluids, pressure sources, and non-return valves. The reliance on electronic systems has also led to a troubling ‘copy and paste’ approach that fails to accurately reflect the risks associated with specific tasks.
Another alarming issue is the lack of adequate planning for isolations. Duty holders are often opting to proceed with complex isolations involving multiple passing valves and extended boundaries, rather than waiting for appropriate shutdowns. This practice compromises safety by failing to ensure that risks are reduced to as low as reasonably practicable (ALARP). Additionally, inaccuracies in piping and instrumentation diagrams (P&IDs) have caused significant challenges, with plant drawings not matching the actual conditions. This misalignment often results in flaws in the design and execution of isolation measures.
The presence of missing or insufficiently detailed method statements further compounds the risks. Clear step-by-step guidance is vital for safely applying, testing, and removing isolation measures, yet many operators find themselves without adequate instructions, increasing the likelihood of human error.
To tackle these issues, all deviations from established isolation standards must undergo rigorous risk assessment and receive approval from a technically competent and operationally independent individual—typically based onshore. It is essential that operators closely adhere to control measures outlined in risk assessments.
Operators are encouraged to engage with several critical reflective questions to evaluate their current practices effectively. These include:
1. **Procedures**:
– Do your isolation protocols comply with HSG 253?
– Are they explicit about safely venting and depressurising systems?
– Are method statements comprehensive and detailed?
2. **Risk Management**:
– Under what circumstances are single block and bleed isolations permitted on hazardous fluids, and how is ALARP upheld?
– Is there a defined acceptable leakage rate concerning isolation valve integrity?
– How is integrity validated in complex situations, such as during flare header operations?
– What criteria are established for ensuring cleanliness before breaking containment?
3. **People**:
– What strategies are in place to reduce potential human error?
– Is your training and competency assessment adequate for everyone involved in isolation tasks?
– How effective is your approach in identifying high-risk activities, particularly when multiple jobs occur concurrently?
4. **Assurance**:
– Does your monitoring system adequately capture procedural breaches?
– How do you manage deviations from prescribed isolation practices?
– Is there a process in place to evaluate plant modifications aimed at reducing isolation-related hazards?
– How effectively are problematic valves identified and addressed?
The HSE indicates that risks associated with isolation exist throughout all phases of operations, from initial planning to final completion. Merely having good procedures is insufficient; a collective commitment from senior management down to frontline workers is crucial for ensuring compliance with safety protocols.
Engagement between the HSE and the industry has intensified aimed at sharing best practices and driving improvements in safety standards. As part of its outreach, the HSE recently hosted a webinar dedicated to process isolations within the offshore oil and gas sector. This session is highly recommended for all professionals involved in isolation activities across the UKCS, from design through to implementation, approval, and auditing.
Those interested in gaining further insights can access the recorded session via the Health & Safety Matters website. The comprehensive guidance provided by HSG 253 on safe isolation of plant and equipment remains a valuable resource for operators striving to enhance their safety measures and prevent future incidents. As the HSE continues to emphasise, the problem of isolation failures is entirely preventable, placing the onus on organisations to take the necessary steps to safeguard their operations.
Our Thoughts
The article highlights significant failures in isolation practices on offshore installations, which have led to hydrocarbon releases that pose serious risks. To avoid such incidents, operators must ensure strict adherence to established isolation procedures, particularly those outlined in HSG 253. Key safety lessons include the necessity of thorough hazard identification and risk assessments that accurately reflect the actual operational conditions, rather than relying on generic templates.
Relevant regulations breached include the failure to meet HSG 253 requirements and inadequacies in risk assessments, leading to non-compliance with the Health and Safety at Work Act 1974, which mandates that employers ensure the health and safety of their employees. Additionally, the Management of Health and Safety at Work Regulations 1999 requires comprehensive risk assessments and the implementation of appropriate control measures.
To prevent similar incidents, organizations should invest in robust training programs, ensure detailed method statements are provided, and maintain accurate piping and instrumentation diagrams. Regular audits and monitoring can help detect procedural violations early. There must also be a commitment across all levels of the organization to prioritize safety and compliance in isolation processes, reinforcing a culture of safety in offshore operations.
