BSEE and Stop Work Authority
Most of the process safety discussions at this site for the last few months has been to do with OSHA and the EPA. However, there is another United States agency that has a similar standard. It is BSEE (the Bureau of Safety and Environmental Enforcement). Its process safety equivalent rule for offshore production facilities is SEMS (Safety and Environmental Management Systems). (Our book on this topic is Offshore Safety Management.)
BSEE issues Safety Alerts on a regular basis. These Alerts are usually to do with incidents that occurred, and the lessons that we can learn from those incidents. Today they published Safety Alert No. 457 Broken Breaker Bar Injury with Medical Evaluation Guidance.
The incident that they describe provides many lessons learned. The one that I would like to focus on is.
Use Stop Work Authority when they see unsafe acts or conditions in the
workplace.
With regard to this incident ‘Stop Work’ seems to be a minor factor. But the topic is important in the bigger picture.
In drilling operations (as distinct from production), conditions are constantly changing. There is always uncertainty as to downhole conditions. Hence control parameters, such as the weight of the drilling mud, need to be constantly evaluated and changed as necessary. In this environment ‘Stop Work’ authority is vitally important. If anyone on the drilling rig perceives that there could be an imminent blowout, he or she must have the authority to stop drilling immediately. (This may mean activating a blowout preventer — the image shown at the head of this post.)
OSHA has carried this ‘Stop Work’ philosophy from the offshore environment into its proposed updates to their process safety standard, particularly, Update to OSHA's PSM Regulation: Part 5: Oil and Gas-Well Drilling.
Although there is certainly a role for Stop Work Authority in any process that uses flammable or toxic chemicals, this topic is more applicable to drilling oil and gas wells, than to steady-state, chemical/refining operations. The following is a quotation from the post,
OSHA’s process safety standard has its roots in the chemical industry.
Companies such as Monsanto, ICI Americas, DuPont and Dow were instrumental in its development. A feature of this industry is that the processes that it operates are, by and large, steady-state. If operating conditions change, then those changes are usually gradual (say if a catalyst loses activity). A second feature of these industries is that they often handle highly hazardous chemicals. These chemicals are often used in complex, proprietary processes. Hence, it is not possible for the OSHA standard to cover all the different industries. (Which is one reason for the standard being performance-based.)
The PSM standard was then applied to oil refineries. Once more, conditions on a typical oil refinery are generally steady-state. Some activities such as the filling and emptying of tanks are dynamic, but basically today is the same as yesterday and, we hope, tomorrow. There is less concern with highly hazardous chemicals than there is with chemical processes (with some exceptions such as the use of hydrogen fluoride in alkylation).
But applying the PSM standard to oil and gas drilling is a stretch. By definition, conditions are dynamic — yesterday, today and tomorrow have to be different. Moreover, there is always uncertainty. In spite of the seismic surveys, no one can be sure what the formation looks like or what it contains. Hence, the use of techniques such as Management of Change are quite different from what they would be in a chemical plant or refinery.
It is also important to recognize that “stopping work” on a large refinery or chemical plant can create its own hazards. It is one thing to stop work because a worker is not wearing the correct PPE; it is something else again to bring a large, continuously operating facility to a screeching halt.
