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Shell North Sea platform safety allegations against Shell executives and the HSE by former Shell Group Auditor Bill Campbell

 By John Donovan

Below is the full content – every word – of a statement former Shell Group Auditor Bill Campbell sent to Shell, the HSE, the news media and other interested parties on 6 March 2008. Associated documents will be added ASAP to this article which was first published to coincide with a related report broadcast on TV Channel 4 News in the UK at 7pm on 6 March. Bill Campbell appeared on the report. Bill and I had discussions on the subject with a Channel 4 News Producer prior to the broadcast.

Channel 4 News has accepted an invitation from Shell to visit the Brent Bravo platform linked with the notorious “Touch F*** All” safety culture which put production and profits before the lives of Shell employees; two of whom later perished in a preventable accident for which Shell was fined £900,000 ($1.8 million USD approx).

Leaflets setting out the highlights of the latest allegations by Mr Campbell are being prepared for distribution this month at Shell offices in Aberdeen, The Shell Centre and at The Hague HQ of Royal Dutch Shell Plc.


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The Strange Case of Hill vs Hill

This correspondence is FAO of Michiel Brandjes who is the Royal Dutch Shell (RDS) Secretary and General Counsel to the RDS Chairman Jorma Ollila. 
It is also directed FAO Greg Hill who at the time of the fatalities on Brent Bravo in September 2003 was the Production Director accountable for the Health and Safety of circa 1,500 direct and indirect employees on the 17 offshore installations data from which is attached on a Zip File. 
Greg Hill played another key role in that from 16th June 2006 onwards he was appointed to head a Crisis Reaction Team based in London.
  Why this is important will be explained below in the Case of Hill vs Hill. 
A number of TV and Newspaper journalists are copied.  These journalists either met Hill in 2006 or were given briefings from his Crisis Reaction Team in the form of strong and categorical rebuttal of the allegations made against Shell by BBC Scotland and by the Oil Industry Magazine Upstream.  The Guardian and the London Times for example covered both the allegations and the rebuttal in significant detail.
This correspondence is also copied to Geoffrey Podger, CEO of the Health and Safety Executive (HSE).  At my instigation in a letter to the HSE Chairman he requested a senior HSE official Ian Whewell to carry out an investigation into the conduct of HSE officials in relation to the fatal accident investigation and the failure of those officials to pass information, vital to a public Inquiry into the fatalities, to the Procurator Fiscal. 
A number of Members of Parliament (MP) are also copied.  The MP’s have shown an interest in these matters and I copy them as witnesses and so that they are aware that these charges have substance, most of them have for example been copied on previous correspondence with HSE and the data from the post fatalities Shell Integrity Review. 
Much of what is said here has also been copied for circulation to the UK Parliamentary Select Committee responsible for holding the Health and Safety Commission and its Executive branch accountable for their performance in reducing risks to protect people at work in the UK.

Hill vs Hill – The involvement of Greg Hill as Production Director November 2003

In August 2006 after Ian Whewell had completed his investigation and in the presence of an independent witness Mr J Molloy, Secretary of the trade union OILC and Mr Kevin Myers a Technical director for the HSE, both copied on this correspondence, Whewell confirmed that in the early weeks of November 2003, Shell had requested a meeting with HSE.
I understand the HSE officials who met with Shell were Tom McLaren and Taf Powell who at the time was Head of the Offshore Safety Division in Aberdeen.  The Shell officials were Greg Hill along with his Managing Director Tom Botts.
At this meeting Greg Hill presented the data shown in the attached Zip File.  This data is from a post fatalities Technical Integrity Review which was a field wide review commissioned by Hill to give him some assurance that the essential control weaknesses evident on Brent Bravo were local to that facility and not widespread across the whole of the North Sea operations.  The Review carried out its research with some urgency and produced its interim report by 5th November 2003.  Hill did not get the assurance he had hoped for, in fact the common failure modes causing the deaths on Brent Bravo were witnessed on all the other 16 installations covered in the Zip File data.
The Review used as its basis the major audit carried out in 1999 and the Review Team and its leader found significant similarities between 1999 and 2003, this is documented.  The Review found that there had been a collapse in essential controls related to health and safety in five main areas across the 17 offshore installations including Brent Bravo.  The Zip File gives the detail but in summary what Hill presented to the HSE officials, it is stated that he opened the presentation by telling the HSE officials that he was shocked and horrified by what his Review Team had found and that-

1. A handful of temporary pipework repairs raised as a concern in the 1999 audit had grown to circa 500 almost half of which were not approved by a technical authority and therefore potentially defective – it was a loss of containment from a defective repair that was the initiating event leading to the fatalities

2. Thousands of Fire and Gas sensors couldn’t be relied upon to operate in an emergency for various reasons and had been designated to be in a ‘Fail to Danger’ condition

3. Principal Pipeline ESD valves were either in failed condition or not meeting performance standards on 10 installations, some had been purposefully inhibited from operation – in addition to this up to 14 ESD valves were known to have failed in August 2003 on Brent Bravo and the platform started up with a number still in a failed condition.  The failure of one of these valves contributed significantly to the deaths

4. Operating process equipment knowingly in a dangerous condition first witnessed on Brent Bravo in 1999 was still ongoing across the field -the operation of a degasser vessel with its level control valve known to be passing and unable to hold the liquid level contributed significantly towards the deaths

5. Hill explained that his Review Team found chronic weaknesses in the application of key safeguarding procedures such as the permit to work system across the field -failure of the deceased persons to raise a permit prior to entering the enclosed space was a contributory factor leading to their deaths

More worringly Hill stressed that the above symptoms were supported by evidence of a negative safety culture both onshore and offshore and there were also concerns he said with regard to lack of resources in key areas. 
The Review found that staff in key positions lacked the ability to take technical overview of systems they were responsible for.  Offshore crewmembers appeared afraid to “FLAG” problems they have with the hardware on their installations and staff were willing to continue to operate with systems in potentially dangerous condition.  As a result of this his Review Team questioned whether leaders and managers in the organisation had “conditioned” our crewmembers and staff offshore not to challenge.  In relation to Human Resources there was evidence of a lack of competent people, specifically corrosion engineers to tackle the repair epidemic and a lack of supporting corrosion data.

Hill vs Hill – The involvement of Greg Hill as Crisis Team Leader in June 2006

Looking at one failure mode alone i. e defective pipework repairs, the initiating event was caused by a unapproved and defective temporary repair but over 200 or so unapproved repairs were discovered up to the end of October but no immediate prohibition Notices were served with production uninterrupted on all the installation with the exception of Bravo. 
By late October some 8 materially defective repairs had been discovered on hydrocarbon lines so the probability for another loss of containment must have been dangerously high in the interim period from the 11th September to the discovery and rectification of the defective repair.  In fact for all defects found on all installations no Enforcement Notices were ever issued by the HSE other than for Brent Bravo.
The conditions were truly appalling, and to make it easy for the Journalists and MP’s I have attached along with the Zip File a summary of the findings of the Review Team in tabular form related to temporary repairs, Emergency Shutdown Valves and Fire and Gas Detection Systems.
Ian Whewell, who is now the Head of the HSE division in Aberdeen from his investigation findings notified me in writing that McLaren and Powell sought no assurances that in November 2003 Shell had made any attempt to assess the risks of continued operation or to inform their workforce.  Because Enforcement Notices were not raised by the HSE this communication channel to formally notify the workforce, as required by Law, was also closed. The workers offshore therefore remained blissfully unaware of the risks they were experiencing by just being on these installations.
Now from 16th June 2006 onwards, and as witnessed by the media representatives copied on this correspondence, and carried on most, if not all British and Scottish Regional Newspapers Greg Hill authorised the following rebuttal as head of the RDS Crisis Reaction Team.

• His press release stated that Shell made significant progress in implementing the 1999 Audit findings. 

• All this he stated resulting in a marked improvement in safety performance and Shell absolutely rejected any allegation that it operated its installations at unacceptable risk levels

• And finally that safety was Shell’s number one priority

He authorised these Press Releases in the full and certain knowledge that they were purposefully false and misleading, lies in other words.  How else could any sane and reasonably minded person not come to that conclusion. 
So the same man, shocked and horrified by what he found in 2003, who failed, an act of criminal neglect, to take any reasonable measures to reduce risk by shutting in production, less than three years later, and in stark contradiction to the evidence he provided to the HSE,  misleads, and with a degree of success, Society as a whole by defending the indefensible.

The involvement and collusion of the Chairman and other Directors of RDS in this cover-up

Here the reader needs to refer to the attached extract of a letter from Michiel Brandjes to me on 28th February 2007.
I had previously written to the RDS Chairman Ollila asking him to investigate this cover-up.  He refused to do so stating that he and his fellow Directors considered that these issues had been investigated fully. 
In relation to the Press Releases by Greg Hill, Jorma Ollila and his Board in the third paragraph of the attached letter state that the information I provided (essentially the information in this correspondence provided now to journalists and MP’s) did not change the responses we (RDS) made in public last summer when these issues were raised by me through the media. 
So here you have the Chairman, and the Directors of a Company, which in 2004 and over a period of three years or so, lied openly about its hydrocarbon reserves, and is in the process of settling $millions in claims with respect to that malaise, quite frankly, at it again.

I have no doubt they may get away with it if the MP’s, Trade Unionists, and journalists copied on this correspondence do not take some action to hold this Company accountable for its morally reprehensible and criminal behaviour.
Of one thing you can be sure, Shell will not in any way deny these charges.  They simply cannot.  To do so would embarrass the enforcing authority, the Regulator, for it is they who provided me with the evidence against Shell.  They will simply ignore it.
Shell has also in all my dealings when asked raised no objection in Law to the public disclosure of all this because they are simply not in a position to do so. 
Shell will simply brazen it out, hang on in the hope that TV and Newspapers do not report this, its only sticks and stones that will break their bones, names will never hurt them.  For Ollila and Van der Veer and Brinded the concept of honour is as a traditional commodity not useful in the cut and thrust of modern life.  To admit the truth would lead to the collapse in confidence in this Company for a second time in recent years.  Directors would be required to resign. The already jittery stock market would react with a fall in share price, a rise in oil price would be inevitable and this modern scandal would rumble on with Trade Union leaders questioning whether this basketcase of a Company can any longer be trusted to secure the health and safety of its many employees offshore.
I have been in correspondence with the Lord Justice General of Scotland, Lord Hamilton, and the Lord Advocate Elish Angiolini on these issues and particularly with respect to the role played by HSE officials about their failure to take any action in 2003.  Both these parties have raised no objection in Law to these issues being put into the public domain.
Serious allegations have been made against McLaren and Powell and remain as yet unanswered by Geoffrey Podger.  The MP’s copied on this correspondence are aware of these allegations.  Mr.Podger has also repeatedly failed to disassociate HSE from the public statements made by Shell.  This failure points to a collusion with Shell since 2003 and all this I hope will eventually lead to a police investigation. 
Suffice to say correspondence from the Lord Advocate fully supports the evidence provided above.  In a written statement to a Member of the Scottish Parliament (MSP) she states that there was in her opinion evidence of many failures prior to the fatalities in an organisation where production clearly took priority over safety.  These failures did not just materialise on that fateful day.  And with respect to temporary repairs, she speaks about the haphazard way these pipework repairs were managed over a prolonged period of time. 
I am ever hopeful that Greg Hill et al. will eventually get the opportunity to explain themselves to a police officer in an interview and under caution. 
So Mr Brandjes you can assure the Board that this train has still a few miles to run.  
Bill Campbell






3. Shell Internal Document: Expro BD Riser ESD Valves: History From 1999


4. Brent Bravo Follow Up VG Pack for Greg Hill


5. Shell Internal document: Feeback on temp repairs inventory


6. Shell Internal document: FG ESD Traffic Lights Rough Assessment


7. Shell Internal document: FG Performance Assessment


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