COS Highlights Bureau of Safety and Environmental Enforcement Safety Alert No. 402

Dec 8, 2020

The Center for Offshore Safety (COS) highlights the recommendations contained in the Bureau of Safety and Environmental Enforcement (BSEE) Safety Alert No. 402, Common Operator Deficiencies in Process Piping Cause Gas Release Incidents.

COS and BSEE are aligned with the goal of enhancing operational excellence, safety, and environmental stewardship in the U.S. Outer Continental Shelf (OCS) through Safety and Environmental Management Systems (SEMS). COS’s focus is entirely on the continual improvement of SEMS via learning, development of good practices, and sharing of industry knowledge regarding SEMS.

SEMS allows operators to take a systematic approach to managing risk based on their individual operations.   For all operators, a fundamental of SEMS is to ensure that all hydrocarbons are continuously contained within the piping and equipment designed to contain them. This protects the environment, protects the workers, and supports mitigation of major incidents. Incorporated into the BSEE SEMS regulation, the SEMS element in API Recommended Practice 75 Third Edition “Assurance of Quality and Mechanical Integrity of Critical Equipment” addresses how operators can manage the design and integrity of their assets to establish and maintain a safe operating environment.

BSEE’s Safety Alert highlights an increased number of gas release incidents that have occurred in the U.S. Gulf of Mexico Region from production equipment and piping leaks. BSEE notes these gas releases resulted from deficiencies in Quality Assurance and Mechanical Integrity (QAMI) programs and are often the result of corrosion and deterioration. 

Mechanical Integrity programs are a key part of systematic management of risk via a SEMS. Mechanical Integrity is delivered through many parts of a SEMS including the design process, maintenance plan, surveillance plan, and operating procedures and practices. SEMS manages risk by designing out hazards to the extent possible and then actively managing the remaining hazards to ensure they do not escalate to incidents.

The BSEE Alert also points out the applicable American Petroleum Institute (API) Standards and Recommended Practices that could have helped address the noted issues in the alert. COS supports the use of standards and recommended practices as an important part of SEMS. Sound and effective standards and recommended practices form the basis and foundation for essentially all elements of SEMS. The importance of the use and inclusion of standards in design, operation, and all phases of risk management of SEMS is clear.

API RP 75 Third Edition – the basis of SEMS – in element General “Section 1.5 - Standards, Regulations, and References” and in element Safety and Environmental Information “Section 2.2 Process Design Information” references and defines the inclusion and utilization of standards in SEMS. As an example, in API RP75 Section 2.2, API 14J Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities is specifically referenced and should be used in developing and implementing an effective QAMI. Other standards that should be incorporated in a QAMI include API RP 14E – Design/Installation of Production Platform Piping Systems and API 570 – Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping Systems. Additionally leak detection methods in an effective QAMI should include primary protection, secondary protection, and location of safety device requirements from API 14C - Recommended Practice for Analysis, Design, Installation of Basic Surface Safety Systems for Offshore Production Platforms (7th Edition, 2001).

COS is focused on promoting the highest level of safety through effective SEMS in the offshore oil and natural gas industry. COS facilitates a collaborative and knowledge sharing environment that supports the industry in learning from this and all BSEE Alerts. COS will fully consider this BSEE Alert in our work plans for good practice development. The COS Asset Integrity Subcommittee (AISC) will build on the recently published document, COS-3-06 Guidance for Developing and Managing Procedures, which supports effective QAMI and will create or revise other good practices important to further supporting and enabling mechanical and operational integrity.

Continual improvement is fundamental to SEMS and COS will support the industry in learning from this BSEE Alert. COS is committed to supporting industry collaboration and knowledge sharing and will work with BSEE and operators to enhance QAMI effectiveness and operational integrity in general through SEMS.