UK HSE: Oil company fined for hydrocarbon release – lack of written procedures

What happened

The UK Health & Safety Executive (HSE) has prosecuted an oil company after they failed to provide written safety procedures for the depressurisation of an oil well, which led to the release of more than 1000kg of hydrocarbon gas at the Beryl Alpha production installation in the North Sea, in June 2014.

What went wrong?

A production technician was set to carry out a depressurisation task on a well, a task he had performed on previous occasions. However, he was not provided with any written safety procedures; the expectation was that he would carry out this complex task from memory.

Four flammable gas detectors detected gas in the area and automatically activated the platform water deluge system. The general platform alarm sounded, and all 134 workers went to their muster stations. The gas release continued, and the installation remained at muster stations for more than six hours.

What was the cause?

Investigation found that deficiencies in the company’s safety management system (SMS) led to a release of more than 1000kg of hydrocarbon gas. They had failed to carry out a risk assessment for depressurising gas lift wells, which meant there was a lack of suitable written procedures.

The use of a formalised written procedures would have ensured that this task was carried out correctly in a safe and consistent manner across all staff shifts, preventing the safety critical emergency shutdown system from being disabled during well depressurisation. The prolonged duration and magnitude of the release was a direct consequence of the inadvertent defeating of the emergency shutdown system in this instance.

The company pleaded guilty to breaching the Offshore Installations Prevention of Fire and Explosion, and Emergency Response Regulations 1995 (PFEER) and was fined £400,000.

The HSE inspector noted, among other things, that “the depressurisation of an oil well is a safety critical task, and so should have been formalised in a written procedure to set out a specified sequence of operations to perform the task correctly and prevent potential fatal consequences.”

Members may wish to refer to:

• For want of a watchman the ship was lost (USCG) [a causal factor: lack of specific written instructions]
• Fatality: Trapping in machinery (2003) [no written procedures existed at that time]
• Lifeboat damaged whilst being lowered on davit [there were no written procedures or instructions covering the circumstances]