Strategic approach to managing Safety & Environmentally Critical

Elements (SECEs)

Ian Thomas, September 2015

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for a safer world
Introduction

It is a requirement Offshore Directive 2013/30/EU that operators and owners

establish schemes for independent verification of safety and
environmentally critical elements (SECEs)

In the UK, follows requirement for closer integration for management of

environmental impact and major hazards specified in SCR 2015:

• Regulation 9 (Establish scheme and written record of SECEs)

• Regulation 8, Schedule 3 (Integrated SEMS)

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Focus

This presentation shall focus on:

• Major accident hazards and the environmental element within the SECEs

We shall look at identification and management of SECEs:

• Definitions and considerations

• Quantification and impact assessment

• Key steps in the identification process

• Management and assurance

• How we can support you.

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Focus

We are concerned with Environmental incidents as

defined by EU Directive / SCR 2015.

Environmental incidents within scope must exhibit

two key characteristics:

1. Related to major accident

2. Exhibit significant & lasting environmental

damage.

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Definitions – major environmental incident

1) An environmental incident resulting from any event referred to in

paragraph (a), (b) or (d) in Reg 2 of SCR 2015.

a) fire, explosion, loss of well control or the release of a dangerous

substance

b) major damage to the structure

c) Failure of life support for diving operations

d) death or serious personal injury to five or more persons

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Definitions – Significant & lasting environmental damage

2) An environmental incident is further defined in terms of significance and lasting

damage. That is, an incident which results, or is likely to result, in significant adverse
effects on the environment in accordance with Environmental Liability Directive
2004/35/EC

Environmental damage to the following:

a) damage to protected b) water damage, which is any damage c) land damage, is any land
species and natural that significantly adversely affects contamination that creates a
habitats. the ecological, chemical & amenity / significant risk to human health
commercial status.

Damage means a measurable adverse change relative to

baseline condition
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Definitions – significant & lasting environmental damage

Further guidance regarding definitions regarding lasting damage and setting of

thresholds for an environmental incident can be located in:

a) The Habitats Directive 92/43/EEC regarding conservation of natural habitats and of

wild fauna and flora

b) Birds Directive 79/409/EEC

c) Water Framework Directive 2000/60/EC regarding water damage

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Considerations for quantification when setting thresholds

Oil spill scenarios & response Times < 25 miles from

Type of hydrocarbon inventory and beach
proximity to shoreline Oil Quantity
(Estimate)
Oil
Type
Aerial
Surveillance
Block Specific Vulnerability (JNCC 1999)

Capability
1 (very high vulnerability) All other categories
ITOPF classification / Oil type (high, moderate and low
vulnerability
0 to 25 tonnes 1 Within 4 Monitor and Monitor and natural dispersion -
hours natural dispersion – No dispersant requirement
1. Group I SG < 0.8 e.g. Kerosenes / Gasolines (dispersant requirement
assessed on case by case
basis)

2. Group II SG 0.8-0.85 e.g. light crude, gas oils 2; 3 and 4 Monitor and dispersant within
1 hour
Monitor and dispersant available
but no “within 1 hour
requirement”

3. Group III SG 0.85-0.95 e.g. medium crude 25 to 100 tonnes 1 Monitor and Monitor and natural dispersion -
natural dispersion – No dispersant requirement

4. Group IV SG> 0.95 or Pour Point > 30 degree

(dispersant requirement
assessed on case by case
basis)
2, 3 and 4 Monitor and dispersant within Monitor and dispersant available
2 hours but no “within 2 hour
requirement”

100 to 500 1 Monitor and Monitor and natural dispersion -

tonnes natural dispersion – No dispersant requirement
(dispersant requirement
assessed on case by case
basis)
2; 3 and 4 Monitor and dispersant within Monitor and dispersant within 6

International Tanker Owners Pollution Federation 6 hours hours

>500 tonnes 1 Monitor and Monitor and natural dispersion -

Limited (ITOPF) natural dispersion –
(dispersant requirement
No dispersant requirement

assessed on case by case

basis)
2; 3 and 4 Monitor and dispersant within Monitor and dispersant within 18
18 hours hours

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Considerations for quantification when setting thresholds

Physical and chemical properties of

hydrocarbon

• Viscosity
• Mobility
• degradability,
• molecular weight
• Toxicty
• Ability to bioaccumulate biomagnification
• Ability to react with other substances / synergistic
effects etc).

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Considerations for quantification when setting thresholds

Metocean factors

• Weather and sea state conditions

• Hydrographic conditions

Seasonal and temporal factors

• Time of year and time of day (breeding / migration

seasons)
Special Areas under MARPOL
Annex1 in the North-East Atlantic
OSPAR Maritime Area

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Considerations for quantification when setting thresholds

Guidance available, but there are no prescriptive thresholds.

Example: Impact quantification

The level of harm that would constitute a Major Accident to the Environment (MATTE) is defined
as follows:

a) 2 ha or more of contamination to the littoral or sub-littoral zone;

b) 100 ha or more of open sea benthic community;
c) 100 or more dead sea birds (500 or more gulls);
d) 5 or more dead/significantly impaired sea mammals

Source Chemical and Downstream Industries Forum (CDOIF) 2014; reflecting:

• Seveso Directive
• DETR 1999 COMAH regulations

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Stage 1: Identification of SECEs with safety function

Stage 1
Identify Major Accident Hazards using safety case
Use existing guidance to
Identify structures, plant,
equipment and IT as safety
Identify system (structure, plant & IT) which can cause, prevent,
critical. detect, control mitigate, rescue or help recover from a major
accident

Identify systems for prevention of fire and explosion and

emergency response

Record items identified as SECEs (Safety)

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Identify MAHs

Major Accident Hazards

Identify Major Accident HC.001 Loss of containment from Production Riser/ Turret System
Hazards HC.002 Loss of containment from Crude Separation/ Stabilisation System
HC.003 Loss of containment from Gas Compression System
• HAZID HC.004 Loss of containment from Gas Dehydration System
HC.005 Loss of containment from Fuel Gas System
• Safety Case HC.006 Loss of containment from Flare System
HC.007 Cargo or Slops Tank Fire/ Explosion
HC.008 Hydrocarbon release from Cargo Handling System
HC 009 Loss of containment from well blowout
NP.010 Loss of containment from Methanol Chemical Injection System
NP.011 Engine Room Fire/ Explosion
RF.012 Accommodation Fire
DO.013 Impact from Dropped Object/ Swinging Load
AA.014 Helicopter Crash
MA.015 Vessel Collision
MA.016 Personnel Transfer Failure
SF.017 Structural Failure or Loss of Stability of FPSO
OH.018 Confined Space Entry
OH.019 Asphyxiation
OH.020 Impact to Personnel during FPSO Reconnection to RTM
OH.021 Dropped Fast Rescue Craft

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Identify systems with safety role in MAH

Identify threats & Assess consequences / impacts &

Apply objective method to assign preventive controls assign recovery controls

identify those systems which

have a safety role in Major
Accidents

• Bow tie

Control Recover

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 Example Bow tie

Example Bow-Tie: Systems which have a safety role in Major Accidents

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List of SECEs with safety role

1) Access, escape and evacuation 10) Active Fire Protection (water)

routes 11) Electrical fault protection
2) Ballast and bilge 12) Emergency electrical power supplies
3) Blowdown, pressure relief and 13) Escape lighting
flare
14) Emergency shutdown
4) Active Fire Protection (chemical)
15) Risers and pipelines
5) Flammable gas detection
16) Fire and smoke detection systems
6) Communications external
17) Firewater systems
7) Drainage (hazardous open)
18) Foam systems
8) Communications internal
19) Portable firefighting equipment
9) Gas systems hydrocarbon
containment

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Stage 2: identify SECEs with environmental role

Fire, explosion, loss of

Stage 2 Establish criteria/ thresholds for a major environmental incident
well control or release of
a dangerous substance

Second review
cycle to identify Identify Major Environmental Incident from list of MAHs
Confirm scenarios with
potential for significant
those SECEs that environmental
(consider scenarios a, b & d) consequence
have an
environmental role.
Bow-Tie Analysis to
Identify systems (plant, equipment, IT ) that interact with the hazard or condition
confirm SECE with an
(cause, contribute to or prevent or recover from a major environmental incident) environmental role

Use EIA, Aspects register

Evaluate the consequence of system failure and whether consequence and OPEP to evaluate
significant & lasting
constitutes and environmental incident impact

Generate list of SECEs

Confirm SECE has an environmental role

Performance standards,
compliance routines link
Establish an assurance and verification scheme to manage SECEs to maintenance system

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MAH with environmental impact

Identify MAHs with potential Major Accident Hazards

environmental impact
HC.001 Loss of containment from Production Riser/ Turret System
• ENVID HC.002 Loss of containment from Crude Separation/ Stabilisation System
• Primary focus – loss of
hydrocarbon inventory HC.005 Loss of containment from Fuel Gas System
HC.007 Cargo or Slops Tank Fire/ Explosion
HC.008 Hydrocarbon release from Cargo Handling System
HC 009 Loss of containment from well blowout
DO.013 Impact from Dropped Object/ Swinging Load
MA.015 Vessel Collision
SF.017 Structural Failure or Loss of Stability of FPSO

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 Stage 1. Example Bow Tie output

(only those systems which have a safety role in Major Accidents)

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Stage 2: Example Bow Tie Output

SECEs with a role in an environmental incident.

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List of SECEs with safety and environmental role

Safety Function Environmental Function

BOP and well control  

Emergency shutdown  

Blowdown, pressure relief and flare  X

Access, escape and evacuation routes  X

Risers and pipeline  

Escape lighting  X

Lifeboats  X

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Summary

• Simple 2 stage process HAZID

• Existing operators – need to review MAHs Establish criteria/ thresholds for a major
environmental incident
& SECEs for environmental implication Identify Major Accident events
using safety case
using existing information and Identify Major Environmental Incident
from list of MAHs
transparent procedure. (consider scenarios a, b & d)
Identify system (structure, plant &
IT) which can cause, prevent,
• New entrants will need to run process detect, control mitigate, rescue or Identify systems (plant, equipment, IT )
help recover from a major accident that interact with the hazard or
from start, as described. condition

• Collaborative effort required. Identify systems for prevention of Evaluate the consequence of system
fire and explosion and emergency failure and whether consequence
response constitutes and environmental incident

Confirm SECE has an environmental role

Record items identified as SECEs

Establish an assurance and verification

SECE (safety) scheme to manage SECEs

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Where do we go from here / what can LR offer ?

Focus of SCR 2015

• to reduce the risks from major accident hazards to the health and safety of the workforce
• to increase the protection of the environment

Specifically:
• Regulations require confirmation that the likelihood of a major environmental incident has been
identified and its environmental consequence assessed.

Reg 9 • establish a verification scheme for ensuring that the SECEs will be suitable;
and where provided remain in good repair and condition.
• produce a written record of the safety and environmental – critical
elements and specified plant
Reg 8 Schedule 3 • SEMS and integration of environmental impact into major accident risk
assessments in the safety case.

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Where do we go from here / what can LR offer ?

Specifically, we can help you with:

1. Identification of SECE (safety and environmental function)

2. Quantify consequences (both safety and environment impact)

3. Advice regulatory compliance strategies

4. Establish performance standards

• functionality – what is SECE required to do?

• availability – for what proportion of time will the SECE be capable of performing

• reliability – how likely is the SECE to perform on demand

• survivability – does the SECE have a role to perform post event

• interactions – do other systems need to be functional for the SECE to operate

5. Assurance in the management of MAH and SECE (e.g. audits, SEMS processes, procedures and policies)

6. Develop verification scheme

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Ian Thomas
Department Manager
Aberdeen
T + 44 1224 267 485 / Mobile +44 7785 515 403 E
[email protected]

Lloyd’s Register Consulting

www.lr.org/consulting

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