Rig Safety Case Notes - Sep2021

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Safety Cases – Brief Notes re application to small drilling rigs

Compliance

The EU Offshore Safety Directive 2013_30 applies to EU nation states – not individual companies.
Individual EU nation states are required to put their own national legislation, regulations and standards in
place to comply with the directive. The UK has been a leader in this but other states eg Denmark, Germany,
Norway have their own different local legislation and regulations.

An individual company could not legitimately claim compliance with the Directive.

An individual company can demonstrate alignment with aspects of the Directive eg preparation of a report
on major hazards, identification of SECEs etc, etc. The form of demonstration should be explicit and
limited to be credible.

In my opinion the most suitable basis is compliance with the IADC HSE Case Guidelines. This is the
international drilling industry standard and HSE Cases to this standard should be generally acceptable in
all jurisdictions – as is claimed by IADC. In my opinion, the biggest weakness of the IADC guidelines is
ALARP – discussed later.

Major Hazards Assessment

In my opinion the most important scenarios are blowout, ship collision and simultaneous operations.

MAHRAs should focus on the big issues and be consequence driven.

FERA

I have not seen adequate analysis of fire and explosion.

Important aspects are structural collapse eg of the derrick and failure of the accommodation, and impact
on EER.

EERA

EERA is a critical aspect for small drilling rigs. On the recent Pattison Rig blowout in Oklahoma all personnel
should have been able to escape but a number of people died due to inadequate escape arrangements.
The EERA should highlight such vulnerabilities and come up with potential solutions.

Where rigs do not meet SOLAS guidelines for the number of lifeboats there is potentially significant
vulnerability.

This should be addressed in the ALARP assessment.

Smoke and Gas Ingress

Again, on a small rig without pressurized accommodation potential smoke and gas ingress potentially
forcing early evacuation is an important aspect to be assessed.

QRA

A simplified approach to QRA has been adopted. This is in general a good thing - there can be too much
effort wasted on massively detailed but not necessarily reliable QRAs.
However, for example, to assess blowout risk it has been assumed that all personnel on the rig will be
fatalities. This is quite inappropriate, no such case has arisen, and a very distorted risk profile is generated.

ALARP

The ALARP demonstration is the most critical part of the case to demonstrate that risk is tolerable.

I have not seen adequate identification of potentially significant risk reduction measures or their
assessment.

SECE

Identification of and definition of performance standards for SECEs is also highly critical to maintain
control of risk.

Often large systems are identified when critical equipment and components need to be identified that
should be the focus of planned maintenance.

The performance standards prepared do not focus on the critical aspects and are obscured with
unnecessary detail.

PRB

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