Printed below is an email that I sent on Thursday evening to Mr. Michiel Brandjes, Company Secretary & General Counsel of Royal Dutch Shell Plc.
It mainly concerns a leaked Shell internal document related to Shell’s Drilling Campaign in the Arctic, which ended with Shell’s offshore reputation being left in tatters. As has been widely acknowledged in the mainstream media, we broke the news last night that David Lawrence, the Royal Dutch Shell executive most directly responsible for the “screw up,” has been fired. This is possibly in an attempt to save his incompetent bosses, Marvin Odum and Peter Voser, from the same fate.
JOHN DONOVAN EMAIL TO ROYAL DUTCH SHELL PLC COMPANY SECRETARY MICHIEL BRANDJES SENT 21 MARCH 2013
From: John Donovan <firstname.lastname@example.org>
Date: 21 March 2013 21:39:57 GMT
Dear Mr Brandjes
LEAK OF A SHELL INTERNAL DOCUMENT
What immediately took my eye is that Shell was well aware at that early stage of the need for de-icing equipment on helicopters, yet still ran into difficulties in that regard in 2012, allowing its employees to be passengers on helicopters that had insufficient de-icing equipment. That looks like criminal negligence to me.
I have no doubt the document is genuine, but give Shell this opportunity to confirm or deny its authenticity.
In the absence of any response by close of business tomorrow, I will take that as tacit confirmation that it is authentic and pass it on for analysis by experts including Mr Bill Campbell, the retired Group HSE Auditor of Shell International.
I then intend to supply the document, plus the analysis and any other information that arrives in the meantime from the same source, to the U.S. Department of the Interior. I am sure they will wish to take it all into account in deciding whether to ever let Shell drilling vessels anywhere near Arctic/Alaskan waters again.
We will also supply the information to other interested parties, including Greenpeace and US and UK legislators.
DISRUPTIVE ATTACKS ON OUR WEBSITE
I am sure you are aware from Shell’s close monitoring of our website of the continuing disruptive attacks that I have previously described in some detail. You have already denied any involvement by Shell in such activity.
As stated before, I am sure that you have been truthful in what you have said. At the same time, I am also sure you were kept completely in the dark about the international corporate espionage activities of Hakluyt on Shell’s behalf against Shell’s perceived enemies, that Shell admitted only after it was exposed by The Sunday Times. All kinds of undercover dirty tricks.
The first time I reported the cyber-attacks to the UK police they did investigate, but ran into practical and jurisdiction obstacles, because our server is located in the USA. When I brought them up to date more recently, I did not receive any response, not even an acknowledgement. It may be because there is no money involved e.g. not an attack on a banking website.
I intend to call in the police again. It would help if I was able to say that Shell would welcome an investigation.
Is it okay to say this and can I refer them to you for confirmation?
For a variety of reasons, I believe Shell is responsible for what is going on, but have no proof.
If the police can trace the responsible party and it becomes apparent that Shell has no involvement, that would surely be in Shell’s best interest?
Mr Brandjes, can you honestly say that you do not have a niggling doubt in your own mind that you have been deliberately kept in the dark this time as well?
No response has been received thus far from Mr. Brandjes. If one does arrive, it will be posted here on an unedited basis.
THIS IS THE ANALYSIS KINDLY PROVIDED BY MR BILL CAMPBELL, RETIRED HSE GROUP AUDITOR OF SHELL INTERNATIONAL, WHO HAD ACCESS TO THE LEAKED SHELL DOCUMENT AND THE U.S. DEPARTMENT OF THE INTERIOR REPORT. (MR. CAMPBELL LED THE SHELL AUDIT TEAM THAT UNCOVERED THE BRENT BRAVO SCANDAL, INCLUDING THE NOTORIOUS “TFA” CULTURE)
Will look in more detail but initial observations 2008 review compared with US government findings are:
The 2008 review covered a lot of ground, appeared comprehensive and found a significant number of activities still outstanding, some were clearly in progress but some were new activities recommended by the 2008 Shell audit or review. The gist of these recommendations were soft issues related to HR resources, both sufficiency and required competence, mainly in relation to contractors who in the main would execute the work activities utilising their own assets. Shell recognised concerns with the inter relationships with these contractors, for example roles and responsibilities of all parties, having clear and concise targets and objectives these were to be supported by key performance indicators yet to be developed. An example of this can be found in a hardware example that the variety of IT and communication systems needed to be compatible especially in an emergency but also to achieve the day to day targets efficiently.
What is clear is that some of the major finding on the 2008 review were not fully implemented when you compare the findings in 2008 with the 2012 government report some 4 years having passed. The US government findings highlight lack of essential controls in the management of its contractors by Shell indicating that in 2008 Shell recognised risks in essential controls but apparently had not terminated or otherwise mitigated these risks by 2012.
MORE DETAILED ASSESSMENT
Within the old SIEP guidance a PSUA, or Pre Start Up Audit, related to how HSE was to be managed would be planned for 14 days and would involve at least one site visit. This 2008 PSUA was a paper and interview affair of short duration (4 days) and did not involve site visits – but – this initial work was to be augmented by a follow up audit later that year according to the presentation information. Was this follow up work ever undertaken?
Given the lack of time and resources they covered a lot of ground and some areas they admit on the presentation view-graphs were not covered so they did not complete their initial TOR. this in itself raises concerns given the risks involved.
What cannot be assessed because we lack detail is how many of the 2008 recommendations were completed satisfactorily, the high level U.S. Department of the Interior Report does not as you would expect go into that level of detail.
All you can do is a rough comparative analysis ref the DOI findings and the 2008 concerns
The PSUA had concerns re integration of Shell, the Operator, with its principal contractors Frontier et al re forward planning, adequacy of training given the turnaround of contract staff, alignment of objectives, performance measurement, availability of key procedures for safety critical activities etc – it would appear from the DOI findings – All phases of the offshore Arctic program must be fully integrated and subject to strong operator management and government oversight – that Shell failed to fully implement the PSUA recommendations.
Despite the Operator being fully aware of the risks in 2008 these risks were not effectively managed. Note also that despite the US government assurances after Deepwater Horizon it would appear that the regulation of the operations in the Arctic region is still inadequate. It should be noted also that the Operator excluded regulation and permitting or external affairs generally from its PSUA terms of reference.
The 2008 PSUA raised concerns re planning and Operational readiness, lack of competent staff, lack of competent procedures, no actual Go/No-Go criteria existed etc – how much of this was completed is not known but again we can compare the Operators aspirations in 2008 with the DOI findings in 2012 that – Arctic offshore operations generally must be well planned, fully ready and have clear objectives.
Without labouring the point the comparative analysis demonstrates that the findings in the Dept of the Interior report were aligned almost fully synchronised with the risk exposures recognised in the short PSUA completed by Shell some 4 years earlier. Shell despite its best intentions never got where it wanted. There was a lack of what DOI define as strong management, or if you like in Shell speak effective management, and oversight, of its contractors by Shell. This is a similar in finding to the comments made by the Congressional inquiry into Deepwater re BP’s failure to manage TransOcean, Halliburton et al.
One of the most worrying recommendations made by DOI is that – Shell must understand and plan for the variability and challenges of Alaskan conditions . The clear implications of this is despite the propaganda and rhetoric emanating from The Hague re the subject of operations in the Arctic region, and despite the known and accepted risks, they were not adequately prepared.
The DOI Review confirmed that Shelf entered the Drilling season not fully prepared – the lack of adequate preparation put pressure on Shell’s overall operations – the Company was not allowed to drill into hydrocarbon bearing zones because its Arctic Containment System could not be certified, Shell encountered additional problems including significant regulatory violations and had serious deficiencies in it management of its Contractors.
As the Royal Dutch Shell CEO is fond of saying – Safety is, and will always remain our utmost priority, he can certainly talk the talk.
As our colonial cousins are fond of saying if you fail to plan then you plan to fail.