Those are the rules

1 May 2019

Fire safety should be high on the agenda of any offshore operator. Jim Banks talks to John Pirie and Mark Royle at the UK’s Health and Safety Executive (HSE) about how regulations adapt to new technologies and how the industry approaches its engagement with regulatory bodies.

As the number of offshore oil and gas platforms continues to grow, demand is set to rise for advanced safety systems, including fire and gas detection technology, as well as explosion and fireproof lighting. These are areas in which technology continues to develop incrementally, so regulators and operators alike need to be aware of how the capability of these systems is changing.

The advances in technology are driven partly by regulatory requirements, partly by innovative designs and uses of materials by equipment manufacturers, and partly by enhanced data analysis that changes how technology can be deployed to maximise performance and costefficiency. A key issue here is how the regulatory landscape adapts to the development of new technology or the refinement of existing systems.

Operators will no doubt put great emphasis on safety, but their eye must also be on cost management. For the regulators, performance against clear and specific safety criteria is the only benchmark that they examine, though they recognise the need to work closely with operators and with technology manufacturers to help the industry incorporate advances in design and technology.

“From our point of view, we look at the functional safety piece of safety systems in the offshore industry,” says John Pirie, electrical and control systems principal specialist inspector at the UK’s Health & Safety Executive (HSE). “There have been some changes in the standards, with additional reviews that operators must carry out.”

Pirie’s job is to look after electrical, construction, and instrumentation (EC&I) issues in offshore installations, and is closely involved in planned inspections and investigations of incidents concerning all EC&I systems. The changing standards to which he refers include IEC Standard 61511 – a technical standard that sets out practices in the engineering of systems that ensure the safety of an industrial process through the use of instrumentation.

He also refers to the inspection of equipment that has been classified as safe for use in hazardous areas, known as EX equipment.

“Generally, the industry is good at compliance with regulations and guidance,” Pirie notes. “Some are very advanced in their compliance procedures, most are in the middle of the road, and a small few need to be prompted. Safety has to be a top priority for this industry.”

A lightness of touch

Regulators will not necessarily mandate the use of a new technology such as LED lighting, though they will closely observe how it is used in the industry with a view to formulating new guidance. LED has potential benefits in terms of cost and performance compared with traditional lighting systems, but it is shown to be better suited to specific applications rather than being a direct replacement in every instance.

“When it comes to new lighting systems, it is all about meeting the right performance criteria,” says Pirie. “Offshore installations are reliant on gas and diesel-powered turbines, so the usage of fuel to power electrical systems is a very important consideration. At the HSE, however, we are just looking at the performance of the devices.”

Crucial to this evaluation is IEC 61892, which forms a series of international standards that are intended to enable safety in the design, selection, installation, maintenance and use of electrical equipment for the generation, storage, distribution and utilisation of electrical energy for all purposes in offshore facilities. The lux levels produced by LED lights have raised questions over their suitability for escape lighting, but there are other areas in which they are proving to be highly beneficial from a safety perspective.

“With floodlights, the move to LED has saved a lot of man-hours in maintenance,” says Pirie. “Before, the bulbs failed regularly and were hard to get to. Also, maintaining them at height brings risks. So, LED has certainly reduced the risk. In regular lighting, however, there is less adoption of LED technology compared with fluorescent lighting. The technology needs to develop a bit further in that application.”

“From an explosion protection perspective, you need to open these lighting systems up for inspection,” he adds. “LED lights that have a 10-year closed guarantee may be manufactured to EX standards, but the guarantee does not apply if they need to be opened up.”

Mark Royle, an offshore specialist inspector and leader of the fire and explosion team at the HSE, agrees that the key advantage of LED lighting systems stems from how robust they are.

“LED lighting has reduced the maintenance burden, so there is less need for ropes and scaffolding to reach the lights,” he says. “That improves safety.”

Smart deployment is the future

Another area that is regularly reviewed by regulators, partly because of the potential impact of new technology, is fire safety. Systems for the detection of fire are, for obvious reasons, essential in offshore oil and gas production, as are the processes and procedures for responding to fires or gas leaks.

“Offshore installations are reliant on gas and diesel-powered turbines, so the usage of fuel to power electrical systems is a very important consideration. At the HSE, however, we are just looking at the performance of the devices.”
John Pirie

Royle looks at all passive and active fire protection and gas detection systems, assessing their fitness for purpose and the effectiveness of monitoring and response procedures.

He points out that, in general, the industry’s maintenance regime for safety-critical systems is very advanced. “The regulations are not proscriptive but every five years an operator must look at best practice within the industry and at new technology. Change in the detectors themselves is incremental and does not happen fast.”

“Gas detectors, for instance, have become more reliable in recent years and less likely to give false alarms,” Royle adds. “Now, the focus is on the optimal placement of sensors. Computational fluid dynamics is now easier to perform with the greater computing power that is available, so it is easier to calculate the probability of where gas leaks might occur.”

In the effort to optimise the placement of sensors, the focus has been on the analysis of vast quantities of data to work towards a more intelligent approach to the deployment of detectors. “The result is the operators can save money compared to the previous says Royle. “One area in which the approach to fire suppression is changing is the move away from putting sprinklers in accommodation areas, which means that a very advanced fire detection system must be in place.

“For instance, there is often a smoke alarm in each cabin that is linked to the control room,”he adds. “This initiates a manual response, not an automated deluge system response. For other areas of offshore installations, systems are mature, as they do use the traditional deluge system. We are also seeing the removal of halon systems, which are being replaced by systems that use other nonreactive gases or water mist. Halon systems were replaced by CO2 systems, but then these were replaced by Inergen systems.”

The term halon covers a range of unreactive gaseous compounds of carbon with bromine and other halogens. Extensively used in fire extinguishers at one time, these gases are known to damage the ozone layer, so their use has abated. Inergen fire suppression uses naturally occurring gases – nitrogen, argon and a small amount of CO2.

The cyber dimension

While the fundamentals of safety and security systems have not undergone dramatic change in recent years thanks to a focus on incremental performance improvement, a new issue has taken centre stage for Pirie and his team at the HSE.

“One of the main topics at the moment is cybersecurity, which is relatively new on the agenda,” he explains. “This is certainly pertinent to safety systems, as there is often a lot of connection to vendors' control systems. Generally, the industry is in a good place in terms of security, as it is not easy to break into an offshore installation, but there is wide area network vulnerability. Operators want a connection for information about the installation to go onshore, but there is a cybersecurity risk.”

“The industry has always been advanced in its adoption of IT and business networks have be on the agenda. Nevertheless, in terms of the technology for control systems, operators must recognise the potential for risk,” he adds.

The HSE’s role in the cybersecurity debate is firstly to produce guidance for the protection of control systems. This was first released in 2017 and updated in 2018. Secondly, it is to perform the role of a competent authority in the implementation of the Network & Information Systems (NIS) Regulations that are part of the UK government’s national cybersecurity strategy. NIS, which came into force last year, places legal obligations on providers to protect UK critical services by improving cybersecurity.

The cybersecurity challenge highlights a key issue that the industry and regulators face in all areas, be it safety lighting, fire and gas detection or any other safety system – the need to keep pace with the development of new technology.

“Regulations move more slowly than technology,” says Pirie. “The uptake of technology may be slow or fast, and the pace at which the industry moves is what drives the response of regulators. We handle that through the guidance we produce in collaboration with the industry. Even if the regulations themselves have not caught up with new technology, our inspection guides show the inspection criteria that we will be using.”

Develop a dialogue

Regulatory bodies need to be as forward-looking as the industry and the vendors that supply it with new technology. 

“When there is a new safety case, or a material change to one, it flags up that we need to speak to operators and maybe the manufacturer, too,” says Pirie. “The HSE also brings technology companies into our meetings to introduce new systems. We cannot sign off on new technology, but we do want to be aware of it. There is a very positive attitude from the industry. They engage with us well.”

The dialogue only brings benefits if it includes all relevant stakeholders – industry, regulators and technology developers. The role of the regulator here is not only to establish specific performance criteria for safety systems, but also to bring operators together around new ways of thinking.

“The HSE says that if there is an improvement in industry best practices, then other operators should consider implementing it,” says Royle. “They will always adopt practices and technologies that reduce their costs. We also issue guidance when technology is advancing, and they generally comply, though it can be expensive to put in an entirely new system.”

Operators may not cooperate directly in the area of safety, as they are naturally competitors, so regulators can perform a pivotal role in ensuring best practices, as they develop, are recommended or even mandated across the industry as a whole.

Key document IEC 61892

A series of international standards that are intended to enable safety in the design, selection, installation, maintenance and use of electrical equipment for the generation, storage, distribution and utilisation of electrical energy for all purposes in offshore facilities.

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