Performance-based regulatory system, which provides flexibility in compliance, to be adopted
When an accident happens in the petroleum sector, it affects the entire industry. Disasters like the sinking of the Ocean Ranger rig in 1982 (which killed 84 people) and the crash of the Cougar helicopter in 2009 (which killed 17 people) garnered widespread attention and serve as reminders that the Canadian offshore oil and gas industry needs to keep safety top of mind.
“We have seen catastrophic events in our offshore and there’s always that potential in the industry; we can never get risk to zero. Those events, while they are relatively low in frequency, they are high consequence,” says Scott Tessier, chair and CEO of the Canada-Newfoundland & Labrador Offshore Petroleum Board.
The majority of operations are 300 kilometers or more offshore and they come with a slew of safety risks. The facilities themselves pose OHS challenges in that they operate at extreme temperature and pressure; they have the potential for hydrocarbon release, fires and explosions; and workers are required to work at height, in confined spaces and in extreme weather.
“There’s icebergs and packed ice and fog and temperature considerations that the severity and the intensity of which you really don’t see elsewhere in the world,” says Tessier.
To ensure workers are ready to tackle the offshore environment, the board places heavy oversight on training and competency. It conducts regular audits and ensures all necessary certificates and credentials are in place. The most well-known training is likely the Basic Survival Training, a mandatory program of drills, exercises and simulations that every offshore worker — regardless of his role — has to satisfy before he can work offshore. It has to be renewed every three years.
Workers take the course at a facility that mimics the Atlantic Ocean. Winds of up to 70 knots, waves over 1-metre high, rain, thunder and lightning are all re-created inside the training facility. Some of the true-to-life exercises the trainees have to pass include: maneuvering through a 20-foot escape chute of netting and ladder rungs; getting into a slippery soft-bottom life raft; and jumping from 12 feet into a pool.
Some of the training takes places in the real Atlantic Ocean, such as getting into a lifeboat and experiencing the effects of a rescue helicopter hovering just above.
Workers must also complete mandatory training in a wide variety of other areas, including confined space, hydrogen sulphide (H2S), role-specific orientation, helicopter underwater escape training and security training.
Currently, legislation and regulations surrounding offshore work and occupational health and safety is very prescriptive — it states what must be done and how it should be done — but this is about to change. The provincial and federal governments are working together to adopt a more performance-based regulatory system, which provides flexibility in compliance by focusing on outcomes rather than on how those outcomes are achieved.
Tessier notes the prescriptive approach stifles innovation and technological enhancements, while the performance-based regime allows the industry to innovate. A performance-based approach is already being employed in Canada’s nuclear safety, transportation and aviation sectors.
“On the occupational health and safety side of things a degree of prescription is important, and welcomed, but robust management systems that are focused on reducing risk and the ability to leverage innovation to improve safety performance, it’s universally held that that is better-enabled through a performance-based regime, as opposed to a prescriptive one.”
One example is first-aid kits. Currently, the regulations are very prescriptive in exactly what a kit must include, right down to the number of bandages.
“Your first-aid kit in the galley is probably going to be different than if you’re in a welding shop versus the drill floor,” says Tessier. “They will now have the flexibility to customize and tailor first-aid kits to best suit the location and purpose of the work area.”
The new legislation includes several new additions, such as a wellness section that incorporates mental health. The performance-based regime is expected to be fully implemented sometime in the year 2020.
Fatigue is a big concern in the offshore industry. The typical rotation is 21-days offshore, where workers put in 12-hour days, followed by a three-week break back on land. Operators are required to put processes in place to manage fatigue before they can get authorization to begin work offshore. Recently, a code of practice was developed by operators, contractors, workers and regulators that summarizes the requirements around fatigue and defines roles and responsibilities.
Dropped objects are also a concern.
“It’s troubling because it’s fair to say that dropped objects, if not the top, are one of the most serious risks of injury, fatality and equipment damage,” says Tessier. “There’s potential for fatality in what would probably, to the untrained eye, look like a relatively routine dropped object.”
The board continually emphasizes the importance of prevention, and its officers check for measures to mitigate against the risk of dropped objects during safety inspections.
Being born and raised in St. John’s, N.L., the Ocean Ranger and Cougar disasters really hit home for Tessier. Every year he makes a point to attend the Cougar memorial service to remember the lives lost during the tragedy.
“It certainly drives home the responsibilities in the position I have as a regulator to ensure that safety is kept as the number 1 priority for everybody,” he says. “Just being in a room with the families of the victims of that tragedy, it’s a very powerful and poignant reminder of the responsibility the job carries.”
This article originally appeared in the October/November 2018 issue of Canadian Occupational Safety.
