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Wells,
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Utilities.
INTRODUCTION
SEQUENCE OF EVENTS
A major turnaround and upgrade modifications commenced in July 1988, including the replacement of the gas
conservation module. Occidental decided not to shut down
the platform during the turnaround as originally planned and
the Piper Alpha reverted to its initial Phase 1 mode of operation, that is, operating without a gas conservation module.
Since the detailed sequence of events has been extensively reported, most notably in the report of the subsequent
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public inquiry (known as the Cullen Report) [1], the following is a brief summary of the major contributory events:
On the morning of July 6, 1988, pressure safety valve
(PSV #504) on one of two Condensate Pumps (Pump A) was
removed for routine maintenance. The open condensate
pipe was temporarily sealed with a blind flange that was
either not rated for the normal pressure or was not tightened
properly. Because the routine maintenance work was not
completed by the end of day shift (6:00 pm), the engineer
noted on the work permit that the job was incomplete and
removed the permit from the job site to the control room,
but neglected to inform the night shift.
The diesel and electric fire pumps were on manual control during the evening of July 6 as divers were working on
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Significant improvements have been made in the UK offshore industry since Piper Alpha, including improvements in
both hardware and safety culture. The following details
some of the lessons learned:
Safety Case
The Safety Case regulations [5,6] came into force in 1992,
and by late 1993 Safety Cases for every platform and rig had
been submitted to the HSE, who accepted the last of them
by the end of 1995. The Safety Case must describe and justify
the platform/rig design, the inherent hazards and residual
risk (As Low As Reasonably Practicable), and the means of
managing the residual risk to ensure health and safety. These
means are known as the Safety Management System (SMS)
which embraces the elements of both process safety and
occupational safety. The Safety Case must be maintained up
to date over the lifecycle of the platform/rig, and is the basis
for periodic audits. The regulations were revised in 2005 to
reflect the experience gained from the early Safety Cases.
The Safety Case is backed up by a regulator with
adequate and competent resources. The former regulators
inspections had been superficial and had not revealed latent
deficiencies in safety management when Pipers work permit
system was audited in 1988 before the incident. The HSEs
inspections by contrast are now thorough and conducted in
depth by knowledgeable and experienced inspectors.
The Safety Case has forced a more robust and systematic
assessment of major hazards and has driven risk reduction
much more so than OSHA PSM [7], EPA RMP [8], MMS SEMP
[9], or what BSEE SEMS [10] is likely to achieve. This has
probably reduced the likelihood of a similar incident occurring in UK waters by several orders of magnitude. It is a best
in class regulatory regime second to none, a lesson for other
regimes around the world, and a fitting legacy in memory of
those who died on Piper Alpha.
While the safety case regime is best in class, the practice
of developing the Safety Case is sometimes not without fault.
Some operating companies have allowed the Safety Case to
become a paper exercise produced by consultants. It has still
driven risk reduction, but much of the potential learning and
understanding has been lost as a result of the operating companies employing consultants to write the document instead
of doing it themselves. Some of the consultants in turn have
developed voluminous documents that, at the very least,
would benefit from a concise but comprehensive summary
manual. Such a manual could be read in a day by a new
manager or employee, who would then have a good understanding of the platform design, its residual risk and how the
SMS manages those risks. Thus, the Safety Case could
become an excellent training tool.
Forthwith Studies
A number of Cullens recommendations are related to
inherently safer design (ISD), including the mandatory
use of:
Systematic analysis of fire and explosion hazards,
Analysis of smoke and gas ingress into living quarters,
and the requirement for a temporary (safe) refuge capable
of surviving the initial fire/explosion and any escalation
for a reasonable duration to permit evacuation and
escape,
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Safety Culture
Culture is the result of everything that happened or failed
to happen. The quality of leadership and commitment to
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Emergency Response
It is unclear if there was sufficient time for a more effective emergency evacuation. Most of the personnel with
authority to order evacuation were killed in the first blast
which destroyed the control room. The second explosion
occurred 22 min later. By the time rescue helicopters reached
the scene, flames over 300 ft in height prevented safe
approach.
The Piper area of the North Sea had a dedicated firefighting and rescue semisubmersible vessel, the Tharos, which
included an extending gangway bridge. By chance, the
Tharos was moored in the vicinity of Piper, but its arrival at
Piper was delayed by 30 min due to its thrusters cutting out.
Then, Thaross fire monitors did not discharge water until 14
min after the fire pump was started, due to too many monitors being opened. Tharos attempted to extend its gangway
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LITERATURE CITED
1. The Hon. Lord W.D. Cullen, The Public Inquiry into the
Piper Alpha Disaster, HMSO, London, 1990.
2. F.P. Lees, Loss Prevention in the Process Industries, Hazard Identification, Assessment and Control, Elsevier, London, 1979 (and subsequent editions).
3. M.P. Broadribb, The application of formal safety assessment to a new installation, Risk Analysis in the Offshore
Industry Workshop, Aberdeen, UK, October 1990.
4. M.P. Broadribb, The application of formal safety assessment to an existing offshore installation, International
Conference Proceedings - Management and Engineering
of Fire Safety and Loss Prevention, Aberdeen, UK, February 1991.
5. HM Government, Offshore Installations (Safety Case)
Regulations 1992, Statutory Instruments, 1992 No. 2885,
Health and Safety, UK, 1992.
6. S.T. Maher, G.D. Long, R.S. Comartie, I.S. Sutton, and
M.R. Steinhilber, Paradigm shift in the regulatory application of safety management systems to offshore facilities,
Process Saf Prog 33 (2013).
7. US Department of Labor, Occupational Safety and Health
Administration, Process Safety Management of Highly
Hazardous Chemicals, 29 CFR Part 1910.119, 1992.
8. US Environmental Protection Agency, Accidental Release
Prevention Requirements: Risk Management Programs
Under Clean Air Act Section 112(r)(7), 40 CFR Part 68,
1996.
9. US Department of the Interior, Minerals Management
Service, Safety & Environmental Management Program,
Voluntary program based upon American Petroleum Institute, Recommended Practice for Development of a Safety
and Environmental Management Program (SEMP) for
Offshore Operations and Facilities, API RP 75, 1994.
10. US Department of the Interior, Bureau of Safety and Environmental Enforcement, Safety and Environmental Management Systems, 30 CFR Part 250 Subpart S, 2010.
11. HM Government, The Offshore Installations (Prevention
of Fire and Explosion, and Emergency Response) Regulations 1995, Statutory Instruments, 1995 No. 743, Health
and Safety, UK, 1995.
12. Talisman Energy (UK) Ltd., Piper B, Infrastructure Code of
Practice, Talisman Energy Ltd., Aberdeen, UK, 2004.
13. New Piper B reflects Piper A safety lessons, Oil Gas J 91
(1993).
14. CCPS, Guidelines for Risk Based Process Safety, CCPS,
New York, 2007.
15. HM Government, The Offshore Installations (Safety Representatives and Safety Committees) Regulations 1989,
Statutory Instruments, 1989 No. 971, Health and Safety,
UK, 1989.
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CONCLUSIONS
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16. Step Change in Safety, Strategic Plan 20102015, Aberdeen, UK, 2010, Available at www.stepchangeinsafety.
net, Accessed on December 21, 2013.
17. S.H. Kadri and D.W. Jones, Nurturing a strong process
safety culture, Process Saf Prog 25 (2006), 1620.
18. CCPS, Building Process Safety Culture: Tools to Enhance
Process Safety Performance; Piper Alpha Case History,
CCPS, New York, 2005.
19. M.P. Broadribb, What have we REALLY learned bit by bit? Oil
& Gas UK Piper 25 Conference, Aberdeen, UK, June 2013.
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