November/December 2010

What can we expect as a result of the Deepwater Horizon accident?

By Paul Gruhn

The Deepwater Horizon accident in the Gulf of Mexico likely represents the largest environmental disaster ever experienced in the U.S. Everyone wants to know how the accident happened. Many people are already chomping at the bit to propose solutions. Predicting the government and industry response to the accident does not require a great stretch of the imagination. History repeats itself, and as we have seen in the past, increased regulation and scrutiny follow accidents of this magnitude. 

In 1974, a large explosion at Flixborough in the U.K. resulted in 28 fatalities and more than 100 injuries. As a result, safety regulations were passed that eventually became known as Control of Major Accident Hazards (COMAH). The early versions of this regulation specifically excluded offshore, as other regulations applied at the time that were considered adequate. COMAH regulations were extended to apply to offshore after the Piper Alpha offshore platform accident in the North Sea in 1988 that resulted in 167 deaths and complete destruction of the platform.

In 1976, the Seveso accident at a chemical plant in Italy resulted in a dioxin release serious enough to require burying the plant. That accident led to the entire European Community working together to pass what eventually became known as the Seveso II Directive.

As a result of the Bhopal accident in India in 1984-a significant chemical leak that resulted in 3,000 deaths and more than 200,000 injuries-the U.S. chemical industry formed the Center for Chemical Process Safety within the American Institute of Chemical Engineers. The essential goal of the group is to improve industrial process safety by developing industry guidelines prior to any potential government regulations.

Accidents in Norco, La., Pasadena, Tex., and Channelview, Tex. (all within a few years of each other), motivated the passing of U.S. OSHA (Occupational Safety and Health Administration) 29 CFR 1910.199 (Process Safety Management (PSM) of Highly Hazardous Chemicals) in 1992. That regulation mentions safety systems and states that operators need to follow industry standards. ISA has interpretation letters from OSHA stating OSHA recognizes the ISA84 standard (the 1996 version and the 2004 IEC 61511-based version) as good engineering practice, and those who follow it will be considered to be in compliance with the relevant portions of the PSM regulation.

Many in the U.S. believe the API 14C standard (American Petroleum Institute Recommended Practice for Analysis, Design, Installation, and Testing of Basic Surface Safety Systems for Offshore Production Platforms) is adequate for achieving safety on production platforms. However, API 14C does not apply to drilling platforms such as the Deepwater Horizon. Others have voiced concerns that due to the size and complexity of today's deepwater production platforms, API 14C may no longer be adequate. These people have suggested a move away from the prescriptive nature of standards such as API 14C to performance-based standards such as ISA84 (IEC 61511).

Considering the magnitude of the risks associated with the Deepwater Horizon accident (11 fatalities, destruction of the platform, and one of the largest environmental disasters in U.S. history), a government response will be demanded by the public.

Offshore operators will no doubt complain over potential changes and stricter regulations as loudly as many did when the OSHA PSM regulation passed. However, OSHA has documented that accidents have gone down more than 20%, and organizations are reporting higher productivity as a result of implementing process safety management.

A variety of preliminary and partial reports have been released regarding the Deepwater Horizon accident. Until a complete report is released (comparable to the Chemical Safety Board and Baker Panel report on the Texas City accident in 1995, including the management practices that were considered a contributing factor), it is difficult-if not impossible-to speculate as to what really went wrong, why, and how the accident could have been prevented.

The Deepwater Horizon accident, its causes and proposed solutions, has been discussed within the ISA safety list serve (e-mail broadcast system) and the ISA84 committee. It is the general consensus of the group that it would be inappropriate and premature to make a statement or suggest any recommendations at this time. It will first be necessary to thoroughly research and document the complete background and history of the accident. Such investigations and reports take time. For example, it took two years for the Lord Cullen report to be released describing the Piper Alpha accident. It took more than eight months for the internal BP report on Texas City, and two years for the Chemical Safety Board report.

We can anticipate that as a result of the Deepwater Horizon accident, stricter government regulations will be enacted for offshore operators, who will also be expected to follow more stringent performance-based safety standards.

ABOUT THE AUTHOR

Paul Gruhn, P.E., works for ICS Triplex and Rockwell Automation. Gruhn is a voting member of the ISA84 standards committee. The opinions expressed here are solely his and are not intended as representing the ISA84 committee.