Chris Flint: Energy Regulator

Article by Chris Flint

Chris Flint speaking at the Safety 30 conference

I, along with several of my HSE colleagues recently attended the Safety 30 conference in Aberdeen. The conference marked 30 years since the Piper Alpha disaster in July 1988 that claimed 167 lives and forever changed the regulatory landscape in the North Sea.

I’m sure, like me, that those who remember watching the television pictures showing scenes of utter devastation and destruction, can never eliminate those images from their memories. There can be few incidents in Britain in the last 50 years that have had such a profound and lasting effect. 

At the conference, much of the conversation in the sessions, seminars and in the social areas focussed on the regulatory system and the importance of maintaining the three strands of that solid system: a good outcome-based regulatory framework focussing on goal-setting rather than overly-prescriptive guidance; an engaged duty-holder population; and a competent regulator.

When working well, the above strands can reinforce the importance of effective workforce engagement, not only because it is the right thing to do but also because it allows:

  • the expertise that exists among the people routinely exposed to risk in the industry to be demonstrated;
  • a common appreciation of the importance of safety case thinking as the foundation for having informed and challenging discussions about major hazard risk; and
  • a robust regulator prepared to question and challenge industry without prejudice.

In April I authored a letter from HSE to offshore operators warning them that they must do more to tackle hydrocarbon releases in the North Sea, after coming perilously close to disaster in recent years. The letter – which gives industry until 20 July to explain what measures it is taking to improve performance – certainly raised a few eyebrows. However, in my opinion a strong message was needed to ensure dutyholders are taking their obligations seriously in this area. At HSE, in return, we will guarantee to do our own analysis carefully and ensure we are clear about exactly why we think performance is where it is and what levers we need to pull to move it in the right direction.

Lord Cullen was at the event, and his report in the aftermath of Piper Alpha still warrants proper reflection to this day, as it has such a profound and game-changing impact on the offshore safety regime.

Reports of this nature do not always make the same impact, and it will be interesting to see how regulatory changes take shape after the Grenfell Tower public enquiry completes and Dame Judith Hackitt’s recommendations are implemented.

Lord Cullen’s presentation at the event reminded attendees of the three areas in which signs of danger were often missed and directly led to the deadly explosion aboard Piper Alpha:

  • previous accidents evidencing the possibility of failure (eg NASA Columbia explosion);
  • reports about danger being unheeded (eg Herald of Free Enterprise when warning lights for the bow doors weren’t fitted);
  • ‘routine’ dangers in the workplace not being dealt with (eg Texas City refinery failure to manage the use of temporary buildings)

The Safety 30 event highlighted the need for us all to continue to seek to improve the approach to regulating major hazard activity effectively. There were positive words from industry leaders about how to stay on top of process safety and how to continue to manage high-risk activity without losing the appropriate sense of unease. HSE actively wants that attitude to remain a daily part of its leadership behaviour.

However, HSE also needs to be vigilant about separating what gets measured from what actually reduces risk – two very different things and though the industry can be very good at the former, it should not be an end in itself. One speaker at the conference put it very well when he said: “safety is not the absence of incidents but the presence of defences”. And that’s the kicker; there simply must be a final link to effective process safety in everything industry does. 

We have added fresh perspectives each day in the run up to the 30th anniversary of the Piper Alpha tragedy. Read the rest of the series here.

Article by Chris Flint

Director of the Energy Division at the Health & Safety Executive

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