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Shell Brent: Progress with safety – fact or fiction

EXPERT REPLY TO A LETTER PUBLISHED RECENTLY BY UPSTREAM

PROGRESS WITH SAFETY- FACT OR FICTION!

In reply to the letter from Bjorn Edlund, Upstream 23rd June, 2006

The Platform Safety Management Review (PSMR) was actually commissioned because Shell had experienced a number of serious incidents and the internal audit process was raising increasing numbers of serious findings.  A culture of denial seemed to prevail in Shell Expro with up to 18 months passing before audit actions could be accepted by auditees, in many cases after the actions had be wordsmithed in such a form that they were no longer meaningful.

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, that is levels that are unacceptable to society.Â

Although Mr. Edlund stresses the importance of the improvement plans put in place post PSMR the facts are that 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 in 1999 recommended to immediately reduce risk 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 Internal Audit department in Aberdeen related to PSMR, they had gone missing and that the PSMR files held in the Hague had to be replaced in 2003 by me, they had also gone missing.  Also contrary to what Mr. Edlund implies in his letter no audit was carried out on Brent Bravo in 2000, but on Brent Charlie

As an indication that things had not improved from 1999 an internal investigation team reviewed the situation in the Brent Facilities in 2003.  On Brent A, Brent D, Brent C and Brent Delta in the weeks following the major accident event it was observed by this team, set up by the Production Director, that there were

– 97 temp repairs on pipework of which 40 of which were not approved

– 56 gas detectors, 26 toxic gas detectors, 9 oil mist detectors, 5 flame detectors, 1 smoke detector, and 1 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. And many detectors were observed to be inhibited for long periods

A number of ESDV’s had their leak-off test results falsified which may be a criminal offence and which coincidentally was exactly the same finding as in 1999

Plus, and most importantly, the persistence of a negative safety culture where to violate, break the rules, operate equipment dangerously, falsify test records appeared to be normalized behavior.  This litany of deficiencies was common on all the other 11 Shell offshore installations covered by the technical integrity review team

The above is supported by an independent review of Shell operations by Offshore Safety Division of the HSE. In internal Notes obtained by me from them they state that the conditions on Brent facilities deteriorated from 1999 to 2003, and were if anything worse in 2005, note this being two years after the fatalities.

Mr. Edlund makes the comment that Shell are 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, have submitted Safety Cases for all their offshore installations.  In summary the Offshore Installation Safety Case Regulations places a duty on a Duty Holder to insure 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 have operated with criminal 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 the remedial action to immediately reduce those risks in 2003, were not so made aware.  This again is in breach of legislation related to the requirements to formally pass information related to health and safety to the workers on offshore installations, as and when, these risks arise.

Mr. Edlunds 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 the 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

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