Rigzone Reader: Hazardous Area Equipment Needs More Oversight in US
This article presents the opinions of the author.
It does not necessarily reflect the views of Rigzone.
For some time now, I have read various articles following the aftermath of the Deepwater Horizon tragedy two years ago this month, on how the industry should minimize the possibility of this type of incident from happening again, and ways of minimizing any future potential risks.
There have been several articles, such as "API: Significant Enhancements to Offshore Safety Made Post-Macondo," and new legislation coming into play introduced by the Bureau of Safety and Environmental Enforcement (BSEE) and the U.S. Coast Guard.
Furthermore, there have been various Safety and Environmental Management Systems (SEMS) and other recommendations stated and legislative enhancements put in place to try to prevent this type of disaster, but not much mention of the other potentially hazardous equipment.
To date, I am forever amazed at the lack of attention paid to, and legislation enforcement on, what has to be one of the most critical pieces of equipment in the oil and gas industry: Hazardous Area Equipment (HAE). The name of this equipment says it all.
As mentioned above, I cannot really say I have seen any significant improvements made on Hazardous Area Equipment Safety or legislation to enhance safety on such critical equipment. From my observation to date in the U.S., HAE is almost uncontrolled. All the articles seem to revolve around well control, which I must agree is critical too.
However, for those that fail to realize the importance of HAE, the following will give you a quick insight on its importance and also how other countries around the world view the significance of this equipment as it pertains to safety.
Generally, Hazardous Area Equipment is approved and rated electrical equipment that has to meet special construction standards in order to prevent or control sparking. Most normal electrical equipment fitted in households and at most industry sites can cause sparks or arcs. As you can appreciate, you do not want sparks or arcs (source of ignition) in any location where there is the possibility of an explosive gas being present, such as oil rigs, platforms and refineries.
It appears that the U.S. hasn't grasped the gravity of the situation. The importance of essential legislation to reduce potential explosions in regards to Hazardous Area Management cannot be overstated.
Such legislation would call for all personnel working with this equipment to be trained when installing, carrying maintenance, or supervising/managing this equipment to ensure it is safe. These personnel should be able to demonstrate their competency and provide evidence of the knowledge and skill requirements in this area before they are allowed to work on the equipment. In addition, there should be regular inspections by either a third party or government agency to ensure this equipment is in good order and safe.
In Europe, Australia, Brazil, and in many other parts of the world, it is a legislated requirement that:
- Each rig or facility has a current hazardous area equipment register (a record of equipment and inspection record) – not just a list.
- All Hazardous Area Equipment are required to have detailed inspections after installation.
- All Hazardous Area Equipment are required to have regular inspections at a set period of time.
- All technicians that work on HAE are required to have specialized training on the selection, installation and maintenance requirements (there are accredited courses in HAE available in the U.S., such as API and CompEx).
One would hear that there is legislation in place in the U.S. that requires the above, but it has not been enforced in any effective manner and there are many holes in terms of enforceability and affectivity. In addition, most people who are responsible for enforcing safety on this equipment, such as the U.S. Coast Guard and classification societies, to my knowledge have not received any specialized training for HAE that is required in other parts of the world such. There is little to no evidence enforcement authorities look at this equipment with any urgency or conviction; nor have they issued many directives assuring this equipment is made safe and complies with U.S. or international standards for that matter.
The shocking thing is that most of these rigs are built overseas, the equipment is installed in shipyards, and in many cases, without the personnel being trained or equipment fitted being approved. Once the rigs are constructed they can enter the U.S. offshore area and operate with little real follow up inspections on this equipment to ensure the equipment is safe.
Let's put it quite simply, without a source of ignition, a gas release, no matter how large or small, is just a gas release. If there is no source of ignition, there will be no explosion, even if there is an explosive gas present.
In summary, this article makes a point on how important Hazardous Area Equipment is, and it is somewhat bemusing why there is so little attention paid by the enforcement authorities to such critical equipment in the oil and gas industry in the U.S. to date.
With this article, I would like to think that someone in a position of authority can address the concerns stated above, and others can gain a better understanding of this equipment's importance. The main aim here is to improve the safety requirements of the oil and gas industry in the U.S.
If the government and legislative authorities here in the U.S. (BSEE, the U.S. Coast Guard and OSHA) are truly serious in preventing these types of catastrophes from happening again, it is imperative for them to put legislative safeguards in place for managing Hazardous Area Equipment. We need to fall in line with the rest of the world, and learn what they have already learned through other major catastrophes like the 1988 Piper Alpha incident where 167 people lost their lives.
Have we had to endure the Deepwater Horizon incident to no avail?
Unfortunately "Self-Regulation" has not worked in this situation in the U.S. Even though there are some oil companies and rig owners that realize the importance of these issues mentioned above, I must state that they are currently addressing the safety of Hazardous Area Equipment, but there are also many that have little or no concern on these issues either through ignorance or other reasons.
Is the value of life, the value of the environment and the cost of an incident not worth the cost of changing the way we manage Hazardous Areas and Hazardous Area Equipment?
Mr. Mark Tranfield, Chairman and Managing Director is the founder of the OCS Group of Companies and has served the Marine and Offshore industry for 30 years. He is an experienced, qualified lead auditor in the Quality Management and ISM systems. Mr. Tranfield holds a First Class Certificate of Competency in Marine Engineering, is a Graduate Mechanical Engineer and also a Graduate in Business Solutions. He spent his early career at marine related industries, which included serving the several departments of the Australian government on the aspects of safety and inspections audit. From 1971 to 1999, he actively involved in the various large capital Oil and Gas offshore projects around the world. In 1999, Mr. Tranfield established Offshore Commissioning Solutions (OCS) – now widely known as OCS Group- in Houston, the USA. With extensive project management and commissioning experience, Mark developed OCS' Project Development, Control and Commissioning software, which is now used extensively on most of OCS' new build and upgrade projects.
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