Meeting the obligations of the new offshore safety regulations with your people

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Meeting the obligations of the new offshore safety regulations with your people. Presentation IMAREST Houston, Human Engineering Lloyd's Register

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  • The Lloyd’s Register Group comprises charities & non-charitable companies, with the latter supporting thecharities in their main goal of enhancing the safety of life and property atsea, on land and in the air - for the benefit of the public and the environment.
  • The interactions between the three components are crucial to the success of the system, and human factors professionals are concerned with the optimisation of the organisational component and the interaction of the organisation with the other areas. The organisational element is optimised through the specification of appropriate job roles, the assurance of competence, and by matching manpower levels to workload demands. The interactions between the organisation and assets (i.e. People, technology and equipment) are supported through user-centred design to ensure that all plant is fit for purpose. Lastly, processes and systems of work are put in place to control human error and to protect people from the hazards present in the work environment. In this way we work to ensure that the integrated systems of people, plant and process function effectively and efficiently to achieve their intended purpose and avoid doing harm to people or the environment.
  • Each dimension is made up of factors and items. A Dimension can have more than one factor (for example manpower and fatigue management are two aspects of workload). Items from factors can also contribute to anoather dimension (for example having a responsible person in charge of training will contribute to both training and leadership performance.
  • Meeting the obligations of the new offshore safety regulations with your people

    1. 1. Lloyd’s Register: Human Engineering Limited Meeting the obligations of the new offshore safety regulations with your people W Ian Hamilton & Michael Suerth IMAREST Houston 4th May 2011
    2. 2. Lloyd’s Register: Human Engineering Limited Overview • Introducing Lloyd’s Register • The importance of skilled behaviour in offshore operations • Stricter regulatory control • Improved asset design • Meeting the demand for control of human error • Meeting the demand for competence assurance • A framework for organisational integrity
    3. 3. Lloyd’s Register: Human Engineering Limited Introduction to Lloyd’s Register • Global provider of advisory, technical & assurance solutions • Enhance clients’ quality, safety, environmental & business performance • Origins dating back to 1760 • Employs approx 8000 staff, drawn from over 90 nationalities • 240 offices • 80 countries
    4. 4. Lloyd’s Register: Human Engineering Limited Introduction • Human Engineering is the human factors and ergonomics consultancy of Lloyd’s Register. • Our customers operate complex asset intensive, systems. • We provide services in: • Physical ergonomics, • Cognitive ergonomics, • Sociotechnical systems analysis. • Includes design and safety assurance
    5. 5. Lloyd’s Register: Human Engineering Limited Assets are sociotechnical systems The Sociotechnical Approach A system comprises property, processes and people, and the interactions between these three components. Property Technology Equipment People Roles & responsibilities Leadership Competence Culture Processes Procedures Risk assessment Communications The interactions between: • People and people, • People and property, and • People and processes Are crucial to the success of the asset.
    6. 6. Lloyd’s Register: Human Engineering Limited Weak Organisational Integrity multiplies risk • Between 70% and 90% of failures are attributable to human and organisational failure Human & Organisational failures Technical failures Human & Organisational failures Technical failures
    7. 7. Lloyd’s Register: Human Engineering Limited The ND SpaceOptimisingFragileFailure Deviation Normalisation Real Men Don’t Use Procedures!
    8. 8. Lloyd’s Register: Human Engineering Limited Organisational drift - consequences • Technical standards and procedures are missing or inappropriate • Competence and understanding are insufficient • Commitment to technical integrity is lost • Safety management processes degrade • Supervisory decision making is weak • Inability to detect and respond to potential failures
    9. 9. Lloyd’s Register: Human Engineering Limited REGULATORY CONTROL
    10. 10. Lloyd’s Register: Human Engineering Limited DOI 30 day review recommendations II.B. Recommendation 4 & III.A. Recommendation 1 • Increased emphasis on training and competence III.B. Recommendation 2 • Enhanced requirements for organisational and safety management III.C. Recommendation 3 • Increased focus on personal accountability and the control of human error
    11. 11. Lloyd’s Register: Human Engineering Limited Pull through to legislation • Performance based safety case regime • Safety and environmental responsibility placed with the lessee Ensure that all personnel involved in well operations are properly trained and capable of performing their tasks under both normal drilling and emergency well control operations. 30 CR 250 and NTL 2010-N05 IADC’s Health and safety and Environmental case guidelines... will help operators and drilling contractors demonstrate their ability to operate safely and handle the risks associated with drilling on the OCS. DOI safety measures report, 27 May 2010
    12. 12. Lloyd’s Register: Human Engineering Limited Implications for people and organisations • Organisation: There should be clearly defined roles and responsibilities, particularly for decision-making and major accident hazard safety management. • Competence: People should be comprehensively trained and capable. • Processes: Procedures should be fit for purpose and practical. • Usability: Facilities, technology and equipment should be fit for purpose and usable. • Error: The risk of human error should be controlled.
    13. 13. Lloyd’s Register: Human Engineering Limited Safety & Environmental Management Systems • Compliance deadline for mandatory BOEMRE regulation, 15 November 2011 • Focus attention on the influences that human error and poor organization have on accidents • API RP 75 (1998) • 13 elements: to enhance the safety and cleanliness of operations by reducing the frequency and severity of accidents worker safety and pollution control are largely dependent on proper human behavior API RP 75 (1998)
    14. 14. Lloyd’s Register: Human Engineering Limited SEMS 13 elements General Management Program Principles Safety and Environmental Information Hazards Analysis Management of Change Operating Procedures Safe Work Practices Training Quality Assurance/Mechanical Integrity Pre-Startup Review Emergency Response and Control Incident Investigation SEMS Element Audit Documentation and Recordkeeping
    15. 15. Lloyd’s Register: Human Engineering Limited Applicable Phases SEMS applies to all OCS oil and gas operations on new and existing facilities under BOEMRE jurisdiction including • Design • Construction • Start-up • Operation • Inspection • Maintenance
    16. 16. Lloyd’s Register: Human Engineering Limited Job Safety Analysis  Prepare JSA for all OCS activities identified in your SEMS  Must include: • Job steps • Existing or potential hazards • Mitigation Generate task analysis from procedure / observation. Identify the consequences of failure at a sub task level. Are these consequences safety critical? i.e. Could they contribute to a MAH Identify the likelihood of a failure of this sub task occurring (from Table 3) Identify the human failures which would cause this (from Table 2) Identify the performance influencing factors that could contribute (from Table 4) Identify any current processes / mechanisms which reduce risk of failure or enable recovery. Identify any future measures to reduce risk of failure or improve recovery. Task step / task description. Potential consequences of task failure Likelihood of failure occurring. Possible human failures. Performance influencing factors. Existing Risk Management Measures Potential to recover from failure before consequences occur. Additional Risk Management Measures Additional measures to improve recovery NO – consider next step in the task analysis YES – proceed to Step 3 Submit procedure to Procedure Screening Matrix. Is procedure considered safety critical? NO – consider next site procedure YES – proceed to Step 2 Step 1 Site Procedure Screening Step 2 Safety Critical Task Identification Step 3 Human Failure Analysis
    17. 17. Lloyd’s Register: Human Engineering Limited Audit requirements • 2 years after initial implementation • Then every 3 years • Comprehensive audit of 13 elements • Designated and Qualified Personnel (DEP) • 30 day audit plan, API RP 75 section 12.1 thru 12.4 • Deficiencies addressed in Corrective Action Plan (CAP) • Non-compliance can result in sanctions up to and including disqualification as an OCS operator
    18. 18. Lloyd’s Register: Human Engineering Limited ASSET DESIGN
    19. 19. Lloyd’s Register: Human Engineering Limited Objectives for Human Factors Integration To define a feasible role for people • HFI helps to specify the role for people, the manpower requirements, job design and training plans. To specify usable interfaces and equipment • HFI helps to define requirements for the usability of workspaces, equipment and control system interfaces and to support their verification during construction leading to lean commissioning and sustainable performance. To ensure the reliability of human performance • HFI helps to assess the human error potential within the system, its processes and procedures, and to identify workplace hazards for personnel; and so to meet the human factors requirements for regulatory compliance as well as providing operational assurance.
    20. 20. Lloyd’s Register: Human Engineering Limited HFI goals for project phases System lifecycle or maturity stages HFI goals All phases Primary goal for HFI: The optimisation of skilled behaviour. Concept definition Feasibility engineering Main goal 1: To define a feasible role for people. Preliminary engineering Detailed engineering Main goal 2: To specify usable interfaces to workspaces, equipment and technology. Manufacture/fabrication Commissioning Operation Main goal 3: To assure the reliability of human performance.
    21. 21. Lloyd’s Register: Human Engineering Limited HFI Objectives for project phases OperationManuf./CommissionPrelim/detailed designConcept/feasibility • Is the role of people in the system feasible? • Are the human-machine interfaces usable? • Will the required level of human performance be sustainable? • Will the organisation support the business objectives for the system? Key questions:
    22. 22. Lloyd’s Register: Human Engineering Limited HFI questions related to main goals HFI goals Key questions To define a feasible role for people. Is there a concept of operations for the role to be performed by people? Has the target workforce been defined? How many people are needed? What will be their jobs? What are the knowledge and skill requirements? Is there a training plan? How will competence be assured? Stopping rule: The human role is shown to be practicable To specify usable interfaces to workspaces, equipment and technology. Are reference anthropometric data available? What are the requirements for facilities and workspaces? Are the requirements for physical interfaces defined? Is the user population defined? Are the requirements for HCI defined? Is there a plan for testing and acceptance by users? Stopping rule: The facilities and interfaces are fit for purpose. To assure the reliability of human performance. Have occupational hazards been identified? Is there a risk control plan for hazards? Have all safety critical tasks been identified? Have the opportunities for human error in critical tasks been identified? Has the risk from human error been controlled? Have the requirements for a safety culture been defined? Stopping rule: The risks from human error and health hazards are ALARP.
    23. 23. Lloyd’s Register: Human Engineering Limited CONTROLLING ERROR
    24. 24. Lloyd’s Register: Human Engineering Limited Control of human error – the wider view • DOI Safety measures report... ... unsafe offshore drilling operations often result from human error III.C. Recommendation 3. Management and leadership Communications Procedures Knowledge and skills Fatigue and workload Usability of equipment
    25. 25. Lloyd’s Register: Human Engineering Limited Safety Critical Task Review Method Generate task analysis from procedure / observation. Identify the consequences of failure at a sub task level. Are these consequences safety critical? i.e. Could they contribute to a MAH Identify the likelihood of a failure of this sub task occurring (from Table 3) Identify the human failures which would cause this (from Table 2) Identify the performance influencing factors that could contribute (from Table 4) Identify any current processes / mechanisms which reduce risk of failure or enable recovery. Identify any future measures to reduce risk of failure or improve recovery. Task step / task description. Potential consequences of task failure Likelihood of failure occurring. Possible human failures. Performance influencing factors. Existing Risk Management Measures Potential to recover from failure before consequences occur. Additional Risk Management Measures Additional measures to improve recovery NO – consider next step in the task analysis YES – proceed to Step 3 Submit procedure to Procedure Screening Matrix. Is procedure considered safety critical? NO – consider next site procedure YES – proceed to Step 2 Step 1 Site Procedure Screening Step 2 Safety Critical Task Identification Step 3 Human Failure Analysis
    26. 26. Lloyd’s Register: Human Engineering Limited MANAGING COMPETENCE
    27. 27. Lloyd’s Register: Human Engineering Limited Trained isn’t necessarily competent Competence must be measured independently of training... Job Analysis Define Competencies Ability Assessment Competence Assessment Knowledge Assessment Behavioural Assessment Develop assessment methods that assess each critical competency Decompose role in to the competencies required to be successful in the role Identify the most critical competencies
    28. 28. Lloyd’s Register: Human Engineering Limited The assessments Technical Knowledge 1, 2 and 3 Mechanical Comprehension Following Procedures Fault Diagnosis Management Assessment Assessment Interview Work Shadowing/ tours of equipment
    29. 29. Lloyd’s Register: Human Engineering Limited Knowledge assessments
    30. 30. Lloyd’s Register: Human Engineering Limited Ability assessment
    31. 31. Lloyd’s Register: Human Engineering Limited Ability assessments = normalisation
    32. 32. Lloyd’s Register: Human Engineering Limited Behaviourally anchored competencies
    33. 33. Lloyd’s Register: Human Engineering Limited ORGANISATIONAL MANAGEMENT
    34. 34. Lloyd’s Register: Human Engineering Limited Organisational integrity – bringing it all together Circle Of Integrity Critical Tasks Leadership Policy & Procedures Workforce Organisation Ensure competence Usable technology & equipment 2-way Communic -ations Learning & Improving Change Management Leadership Commitment, Decision- Making, trust And common values Define Practicable Practices and COW procedures Optimise Manpower And Responsibilities For safety and performance Tasks critical To the Strategic aims Of the Enterprise Manage the Changes To systems And processes Just Attitude to Blame and Learning culture Build Effective 2-way Communic- ations Define training Needs and Standards of competence Provide facilities, equipment & technology that is fit for purpose
    35. 35. Lloyd’s Register: Human Engineering Limited Measuring Organisational Integrity 0% 20% 40% 60% 80% 100% Critical Task Equipment Design Process & Procedure Leadership Recruitment Training Manpower Fatigue Incident Investigation Change Management Factor Performance Dimension Performance % Approach % Implementation % Outcome % Review % 0% 20% 40% 60% 80% 100% Crtical Task Leadership and Job Design Processes and Procedures Ensure Competence Workload Management Communications Learning & Improving Management of Change Organisational Integrity Dimension Performance
    36. 36. Lloyd’s Register: Human Engineering Limited Summary • New safety regulations demand an increased focus on: • Organisational processes and safety culture • The control of human error • The assurance of competence for key workers • Human factors integration can deliver improved asset design • Organisational integrity offers a framework for the improved management of human factors in offshore operations. • It is a data-based assessment process • Supports error assessment for safety critical tasks • Supports competence assessment for key roles • Improves organisational safety management
    37. 37. Services are provided by members of the Lloyd's Register Group. For further information visit www.lr.org/entities For more information, please contact: W Ian Hamilton & Michael Suerth Lloyd’s Register Americas 1505 Hwy 6 South Suite 250 Houston TX 77077 USA T +1 281 649 2237 E michael.suerth@lr.org or ian.hamilton@lr.org w www.humaneng.co.uk

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