By Upstream staff
Letter from Bill Campbell: Former Shell International group auditor
In response to the letter from Bjorn Edlund (Upstream 23 June 2006), the Platform Safety Management Review (PSMR) was actually commissioned because Shell experienced a number of serious incidents and the internal audit process was raising increasing numbers of serious findings.
The PSMR covered all of Shell Expro but the significant concerns lay in the operation of the Brent facilities.
Brent Bravo in particular was being run with residual risks estimated by the team to be in the intolerable region.
Although Mr Edlund stresses the importance of the improvement plans put in place post-PSMR, these plans appear to have been totally ineffective or not fully applied.
What the Shell internal investigation actually reported was that it found no evidence that the short-term measures recommended in 1999 to reduce risk immediately on Brent Bravo were ever carried out and the long-term actions to reverse the negative safety culture were truncated when only 20% complete.
It also reported that almost no files were now available in Shell’s internal audit department in Aberdeen related to PSMR, as they had gone missing, and that the PSMR files held in The Hague had to be replaced in 2003 by me, as they had also gone missing.
As an indication that things had not improved from 1999, an internal investigation team reviewed the situation on the Brent facilities in 2003 in the weeks following the major accident.
It was observed by this team set up by the production director that there were:
•97 temporary repairs on pipework, 40 of which were not approved
•56 gas detectors, 26 toxic gas detectors, nine oil mist detectors, five flame detectors, one smoke detector and one general platform alarm point that failed to danger, that is, may not have operated on demand in the event of a major release of hydrocarbons
•A number of ESD valves that had their leak-off test results falsified, the same finding as in 1999.
Plus, and most importantly, the persistence of a negative safety culture appeared to be normalised behaviour.
These findings were supported by an independent review of Shell operations by the Offshore Safety Division of the HSE.
Mr Edlund makes the comment that Shell is committed to achieving continuous improvement in safety performance and part of this commitment includes a $1 billion integrity upgrade programme. This statement is extremely misleading.
Shell, as with other operators in the North Sea, has submitted Safety Cases for all their offshore installations.
The Offshore Installation Safety Case Regulations places a duty on a Duty Holder to ensure offshore installations are operated in compliance with their Safety Case at all times it is a criminal offence not to do so.
In allowing all of its 15 offshore installations (as covered in the technical integrity review in 2003) to deteriorate to the condition that now requires $1 billion expenditure, Shell has operated with neglect in that the risks on all its installations are not at ALARP (as low as is reasonably practicable) levels but are at levels probably unacceptable to society.
Their workers, who should have been made aware of these increased risks and of the remedial action to immediately reduce those risks in 2003, were not so made aware.
Mr Edlund’s improvements, if you can call them such, are in reality just to return the risk levels on the 15 offshore installations to the ALARP levels as published in their respective Safety Cases at the time they were issued and accepted by the OSD.
Until these levels are returned to the published and accepted ALARP values then the offshore workforce on the 15 installations are subject to heightened risk levels with the increased probability that a major accident event can occur in the interim period.
Former Shell International group auditor