Strategic approach to managing safety and environmental critical elements (SECEs)

Working together
for a safer world
Strategic approach to managing Safety & Environmentally Critical
Elements (SECEs)
Ian Thomas, September 2015

©Lloyd’s Register Consulting
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)

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.

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.

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

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
species and natural
habitats.
b) water damage, which is any damage
that significantly adversely affects
the ecological, chemical & amenity /
commercial status.
c) land damage, is any land
contamination that creates a
significant risk to human health
Damage means a measurable adverse change relative to
baseline condition

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

Considerations for quantification when setting thresholds
Oil spill scenarios & response Times < 25 miles from
beach
Oil Quantity
(Estimate)
Oil
Type
Aerial
Surveillance
Capability
Block Specific Vulnerability (JNCC 1999)
1 (very high vulnerability) All other categories
(high, moderate and low
vulnerability
0 to 25 tonnes 1 Within 4
hours
Monitor and
natural dispersion –
(dispersant requirement
assessed on case by case
basis)
Monitor and natural dispersion -
No dispersant requirement
2; 3 and 4 Monitor and dispersant within
1 hour
Monitor and dispersant available
but no “within 1 hour
requirement”
25 to 100 tonnes 1 Monitor and
basis)
2, 3 and 4 Monitor and dispersant within
2 hours
Monitor and dispersant available
but no “within 2 hour
requirement”
100 to 500
tonnes
1 Monitor and
basis)
6 hours
Monitor and dispersant within 6
hours
>500 tonnes 1 Monitor and
basis)
18 hours
Monitor and dispersant within 18
hours
Type of hydrocarbon inventory and
proximity to shoreline
ITOPF classification / Oil type
1. Group I SG < 0.8 e.g. Kerosenes / Gasolines
2. Group II SG 0.8-0.85 e.g. light crude, gas oils
3. Group III SG 0.85-0.95 e.g. medium crude
4. Group IV SG> 0.95 or Pour Point > 30 degree
International Tanker Owners Pollution Federation
Limited (ITOPF)

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).

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

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
Guidance available, but there are no prescriptive thresholds.

Stage 1: Identification of SECEs with safety function
Identify Major Accident Hazards using safety case
Identify system (structure, plant & IT) which can cause, prevent,
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)
Stage 1
Use existing guidance to
Identify structures, plant,
equipment and IT as safety
critical.

Identify MAHs
Identify Major Accident
Hazards
• HAZID
• Safety Case
Major Accident Hazards
HC.001 Loss of containment from Production Riser/ Turret System
HC.002 Loss of containment from Crude Separation/ Stabilisation System
HC.003 Loss of containment from Gas Compression System
HC.004 Loss of containment from Gas Dehydration System
HC.005 Loss of containment from Fuel Gas System
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

Identify systems with safety role in MAH
Apply objective method to
identify those systems which
have a safety role in Major
Accidents
• Bow tie
Identify threats &
assign preventive controls
Control
Assess consequences / impacts &
assign recovery controls
Recover

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

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

Stage 2: identify SECEs with environmental role
Establish criteria/ thresholds for a major environmental incident
Identify Major Environmental Incident from list of MAHs
(consider scenarios a, b & d)
Identify systems (plant, equipment, IT ) that interact with the hazard or condition
(cause, contribute to or prevent or recover from a major environmental incident)
Evaluate the consequence of system failure and whether consequence
constitutes and environmental incident
Confirm SECE has an environmental role
Establish an assurance and verification scheme to manage SECEs
Stage 2
Second review
cycle to identify
those SECEs that
have an
environmental role.
Bow-Tie Analysis to
confirm SECE with an
environmental role
Confirm scenarios with
potential for significant
environmental
consequence
Use EIA, Aspects register
and OPEP to evaluate
significant & lasting
impact
Generate list of SECEs
Performance standards,
compliance routines link
to maintenance system
Fire, explosion, loss of
well control or release of
a dangerous substance

MAH with environmental impact
Major Accident Hazards
HC.001 Loss of containment from Production Riser/ Turret System
HC.002 Loss of containment from Crude Separation/ Stabilisation System
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
Identify MAHs with potential
environmental impact
• ENVID
• Primary focus – loss of
hydrocarbon inventory

Stage 1. Example Bow Tie output
(only those systems which have a safety role in Major Accidents)

Stage 2: Example Bow Tie Output
SECEs with a role in an environmental incident.

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

Summary
• Simple 2 stage process
• Existing operators – need to review MAHs
& SECEs for environmental implication
using existing information and
transparent procedure.
• New entrants will need to run process
from start, as described.
• Collaborative effort required.
Identify Major Accident events
using safety case
Identify system (structure, plant &
IT) which can cause, prevent,
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
Establish criteria/ thresholds for a major
environmental incident
Identify Major Environmental Incident
from list of MAHs
(consider scenarios a, b & d)
Identify systems (plant, equipment, IT )
that interact with the hazard or
condition
Evaluate the consequence of system
failure and whether consequence
constitutes and environmental incident
Confirm SECE has an environmental role
Establish an assurance and verification
scheme to manage SECEsSECE (safety)
SECE (Environment)
HAZID

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.

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

Lloyd’s Register and variants of it are trading names of Lloyd’s Register Group Limited, its subsidiaries and affiliates.
Copyright © Lloyd’s Register Consulting. 2013. A member of the Lloyd’s Register group.
Working together
for a safer world
Ian Thomas
Department Manager
Aberdeen
T + 44 1224 267 485 / Mobile +44 7785 515 403 E
ian.thomas@lr.org
Lloyd’s Register Consulting
www.lr.org/consulting
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