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Email response by Bill Campbell sent to James Brewer, the author of an article published today by Lloyds List: Lloyds List: Shell and BP get safety thumbs up

From Bill Campbell

James – your article contains some flaws.

Information recently given to MP’s and which may I hope lead to a parliamentary inquiry. 
Rather than Shell being the ‘best of the best’ it has by a significant factor the worst safety record, either from the period 1999 till Sept. 2003 when the Fatal accident occurred on Brent Bravo, and/or certainly afterwards, the data below is accessible to the public and you can log on yourself to confirm this.
After the fatalities since 2003 – with no recommendations for improvement flowing from the inadequate Fatal Accident Inquiry the situation deteriorates

The importance of this data is that it is irrefutable, cannot be challenged because it is historic data in the public domain, the worry for those who represent workers offshore and MP’s is that it reflects after the fatalities a significant increase in non-compliance by Shell, and more importantly, an increase in high potential incidents.  If this trend continues the next major accident event is not only possible, but inevitable. It’s just a matter of time.

There has been an increase in high potential events!

There has been eight high potential incidents since the fatalities up to the beginning of this year, five of which related to loss of containment of hydrocarbons in enclosed column shafts.  The majority of these high potential incidents were in utility shafts, enclosed areas escape from which is difficult even in simulated conditions wearing full breathing apparatus.  The consequences of an explosion in these shafts could be catastrophic causing partial or complete collapse of the supporting cellar deck structure.

There has been an increase in enforcement actions!

Discounting onland sites etc and mobile drilling rigs the HSE website from late 2003 till the present day list some 181 enforcement actions shared amongst some 30 Duty Holders of Offshore fixed and manned installations.

68 of these notices were issued to Shell and BP constituting 38% of the total, Shell lead in the poor performance table with 40 or 23% with BP at 15%. 
BP have had no prohibition Notices whilst Shell have had 8.  The remaining 113 enforcement Notices are shared by 28 Duty Holders an average of 4 each.  To give you an idea in the absolute difference the next worst offenders to Shell and BP are Petrofac with 14, Maersk with 11 and Amoco and Conoco with 8 each.

Prosecution Data

In the same period Shell have been prosecuted 5 times whilst BP have had 4 prosecutions.  So Shell and BP share 9 of the 22 prosecutions completed against offshore Duty Holders for offshore fixed and manned installations since 2002 with 8 Operators picking up the other 13.  3 of the Shell prosecutions related to the unlawful killing of two workers in Sept. 2003.

So lets be clear, the info I now give you is owned by the HSE, it is their data and it is in the public domain.  The info lists all enforcement actions, and the breaches of legislation relevant to these actions placed on Shell to reduce risks immediately (Prohibition Notices) or after a specified and agreed period of time (Improvement Notices).
Enforcement Notices
Since 2003 Shell have been served with 42 Enforcement Notices for its fixed and predominantly manned installations in the North Sea, cica 30 of these Notices were to reduce risks that had the potential to cause a major accident event with the potential for multiple fatalities, 12 were to reduce the risks of potential single fatalities (for example related to the guarding of machinery).  
In all there were 30 Improvement Notices and 12 Prohibition Notices issued since 2003
Put another way, using statistics in a way that perhaps gives more clarity and raises more concern, over the 46 month period since the fatal accident in Sept. 2003 the rate of issue if you wanted to express it as an average would be one every 40 days or so.  Given the overlap of the time required to complete the enforcement Notices Shell have continually in one part of their offshore business or other been in breach of legislation since that date and a number of very serious Notices are still ongoing.

In 2003 either live or issued were 5 Notices covering 11 breaches of the HS at Work Act or its daughter legislation the offshore Safety Case  Regulations.  In 2004 there were issued 12 Notices with 20 breaches.  In 2005 there were issued 9 Notices with 20 breaches.  In 2006 there were 12 notices with 29 breaches.  In 2007 year to date there has been 4 Notices with 8 breaches.
Of the 88 breaches, some very serious indeed, and as an indication of what the HSE consider as proportionate response, prosecutions have resulted on only 5 occasions, three breaches being related to the deaths in 2003 and two other breaches.  This makes the Offshore Safety Division of the HSE based in Aberdeen the most lenient and reluctant enforcement authority in the HSE’s UK organisation.
For the remaining 85 breaches there has been no prosecutions.  As the HSE likes to use percentages, always fraught with danger because of their ambiguity, however this means that less than 6% of all the breaches have led to prosecution.
What do I mean by serious – a few examples

    * To give you some examples on 26/7/06 and improvement Notice was only raised after the intervention of workers, a corrosion report was available to Shell Managers condemning the stairs in the utility shaft of Brent B but this was subverted and the workforce had been allowed to continue using the stair oblivious to the risks of so doing, no prosecutions followed as far as I am aware since they do not appear of the database – this indicates continuation of negative safety culture even after the fatalities and on the same facility where the fatalities took place.
    * On 5/4/07 Shell failed to report to the HSE as required by Law a dangerous occurrence re the release of gas into the atmosphere, again no evidence of prosecution.  HSE are proud to publish a decline in gas leaks but how much of this is due to the extraordinary pressure put on Offshore Managers not to report, they get it in the neck, you will no doubt be aware from NHS that key performance indicators often do not lead to improvement but to much energy being expended in making red signals appear as green.
    * The fatalities in Sept. 2003 were caused in the Utility Shaft of Brent B, a very risky area given that it is enclosed and access/egress is not easy and takes time but on 2611/04 on Brent Bravo HSE raised concerns about the lack of training given to persons entering these shafts, and on Dunlin on 8/12/04 concerns about the lack of BA sets and training in the use of these in its shafts – these were all areas found lacking in the report of the Sheriff at the Brent B Inquiry.
    * I could go on and on, but just look at the most recent Notices served on Anasuria a Floating Production and storage vessel 14/5/07 essentially saying that the stability controls for the vessel are impaired – in short the vessel may not be able to maintain c of g and equilibrium if influx of water occurred and will break its back or sink, unless it happens in a perfect storm persons on board should escape. 
    * A number of Improvement Notices related to the follow up from BB fatalities are still ongoing so these risks have not yet been reduced to an acceptable level, for example the run down lines to the oil cells which are severely corroded, it was leakage from an unapproved repair on such a line that caused the fatalities when that repair failed.

    Although there were considerable and significant Enforcement Notices issued prior to the fatalities they did not, by the HSE admission in testimony given to me, prevent the situation offshore deterioration, but suffice to say the level of enforcement actions post the fatalities – using the HSE data – has not fallen but risen three-fold as has the level of dangerous occurances.
    Construction Standards
    Your quotes from Mr Costa may have been misinterpreted by you because he talks about parameters not relevant and not used in the design of North Sea facilities, category 3 hurricane is as Gulf of Mexico measure.  Whilst hurricane force winds are not uncommon in the North Sea there has never in recorded history ever had a hurricane as we understand it.  I am not sure if you are a technical persons but suffice to say North Sea installations are generally designed to withstand 100 storm criteria related to the combination of three parameters.
    • Wind velocity (a hurricane parameter)
    • Maximum and significant wave height and periodicity
    • Storm Currents that may impact of the installation foundation

    These criteria are much in excess of cat 3 which relates only to wind velocity, so if the Copenhagen experts are such they have either been misquoted by you or they are not apparently competent.
    The Oil Companies spend lots of money offshore
    Shell in the North Sea are currently committed due to the after effects of the fatalities to spending some $1.6 billion, described by van der Veer as an improvement but actually an avoidable loss due to years of neglect by the Company under its Touch Fuck All policy leading to the fatalities for example.  The risks to offshore workers will not return to the levels specified in their individual Safety Cases till this work is fully completed – so much for a well managed, safety conscious environment.
    Bill Campbell
    11 September 2007 and its sister websites,,,,, and are all owned by John Donovan. There is also a Wikipedia article.


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