Alternatives for Inspecting Outer Continental Shelf Operations (1990) / Chapter Skim
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2. Current Inspection Program: Evolution and Practice
2. Current Inspection Program: Evolution and Practice
Pages 20-38
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From page 20... ...
~ i) PRESENT INSPECTION PRACTICE Overview of Inspection Program All oil and gas operations conducted on the OCS are inspected periodically by the MMS.
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From page 21... ...
It should be noted, however, that initiation of both drilling and production operations involves a series of permit approvals directed to assuring that a facility is safe (i.e., that it has in place a plan for achieving safety performance goals, as well as effective safety procedures and equipment) before drilling or production operations can begin.
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From page 23... ...
The PINC list for production operations was derived in part from the American Petroleum Institute's Recommended Practice Standard 14C, which covers safety systems for offshore production platforms. The lists recently have been expanded to address workover operations.
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From page 24... ...
MMS officials take the position that because process upsets resulting from human error, poor maintenance, and unexpected operational events can be sensed and controlled by safety systems, inspecting the system for compliance with PINC list requirements is a valid means of ensuring systems safety and integrity. In essence, then, the current inspection program and practices conform to the MMS's interpretation of public law as derived principally 5G-400: "is each operation performed in a safe and workmanlike manner, and are the necessary precautions taken to prevent health, safety, or public hazards?
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From page 25... ...
Evolution of the Safety Practices for Drilling Operations Requirements regarding procedures to be used to determine casing depths and mud weights, as well as procedures for kick detection and requirements for control devices, are imposed by MMS regulations carried over from the USGS. These requirements are based on the findings of informal reviews by various American Petroleum Institute (API)
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From page 26... ...
The combination of process flow diagram and SAFE chart, along with the feedback of data from inspections, ensures that the MMS design review for safety devices is comprehensive. SAFETY PERFORMANCE RECORD The safety of OCS operations can be measured in terms of accidents and resulting deaths and injuries, as well as pollutant (primarily oil)
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From page 27... ...
Injunes and Fatalities A primary aim of the MMS inspection program is to ensure that OCS operations do not expose operating personnel to unwarranted physical hazards. In order to assess the relative risks in various industries, it is useful to compare injury and fatality incidence rates.
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From page 28... ...
. This report supplements the previously published Accidents Connected with Federal Oil and Gas Operations on the Gulf of Medico Outer Continental Shelf, Volume I (OCS Report MMS 86-0038)
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From page 29... ...
Personnel on manned platforms Type of activity Production operations Drilling operations Subtotal (iii) OCS personnel Total 1 0,385 3,784 14,1 69 20,936 SOURCE: U.S.
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From page 30... ...
On this basis, the maximum and minimum fatality incidence rate for OCS operations are 16.5 and 33.0, respectively. To bring these figures into perspective, the fatality incidence rates in various industries in the private sector are given in Table 2-5, for 1983 and 1984 (Bureau of Labor Statistics, 1986~.
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From page 31... ...
bTable 2-2, covering years 1984, 1985, and 1986. TABLE 2-5 Fatality Incidence Rates Industry 1983 1984 Agriculture, forestry, and fishing 12.7 16.3 Mining 27.6 41.4 Construction 26.3 22.8 Manufacturing 4.3 4.4 Transportation and public utilities 13.3 16.9 Wholesale and retail trade 3.3 3.1 .
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From page 32... ...
TABLE 2-6 Causes of Accidents Involving Fatalities in the Gulf of Mexico, 1982-1986 Description of cause Number Number of events of fatalities 1. Handling heavy loads (including crane accidents)
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From page 33... ...
offshore spillage probably contributes less than 5 percent of the world offshore spillage. The data indicate that since 1977 there has been no obvious long-term trend in spillage rates from offshore oil and gas operations.
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From page 34... ...
compared to those TABLE 2-8 Major Accidents in the Gulf of Mexico OCS Regiona Fires and explosions Blowouts 1970 7 2 1971 1 2 1972 0 1 1973 3 2 1974 0 1 1975 4 2 1976 0 1 1977 3 0 1978 7 2 1979 3 1 1980 7 4 1981 3 1 1982 8 2 1983 4 3 1984 6 1 1985 3 1 1986 1 1 aAII fires or explosions that result in equipment of structural damage of $1 million or more. Both production and drilling related events are included in the number.
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From page 36... ...
The rest can be related in a general way only to the PINC G-400. This PINC asks the question, his the operation performed in a safe and workmanlike mannerly It is described informally by MMS as a "catch-all" PINC, since it is not specific and is sometimes used by inspectors to cite poor operational procedures and general housekeeping.
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From page 37... ...
37 TABLE 2-12 Analysis of Reported Accidents Involving Fatalities in the Gulf of Mexico, 1982-1986 Number Number Number Potentially Reported of of of violated cause accidents fatalities injuries PINGS 1. Handling heavy 16 16 5 G400 loads (including crane accidents)
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From page 38... ...
38 Thus, if possible violations of the Catch-all PINC G-400 are disregarded, most of the accidents would have occurred even though the operator might have been in 100 percent compliance with all other PINCs at the time of the accident. The hardware-oriented PINCs seemingly are not tied closely to current accident experience—this observation does not imply that fatalities have not been averted as a result of these PINCs being enforced—rather it is meant to suggest that the safety-enhancement limits of a hardware oriented inspection program are being reached.
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