The US Bureau of Safety and Environmental Enforcement (BSEE) has issued a safety alert regarding gas release hazards, following a compliance and incident data review that turned up 31 incidents by 14 operators in the Gulf of Mexico.
|Photo from BSEE.|
During the same time frame, 36 gas release incidents of non-compliance were issued by BSEE. To battle future incidents and compliance issues, the agency developed a protocol to conduct targeted gas release performance-based risk inspections on 26 production platforms and 10 well operations in the GoM region over a two-day period.
The inspection showed that 17% of facilities involved had documented oil or gas accumulation. Eight of 36 facilities (22%) had a non-operable gas detector, no process implemented for calibrating devices, failed a bump test or had no documentation on the frequency and/or results of inspection.
The good news, BSEE found, that the facilities inspected had no issues identified by BSEE's staff on excessive temperatures. Most observed that high temperature areas were well insulated and out of human reach.
However, one facility had an outdated electrical classification drawing, and very few facilities had warning signs to address area classification. Most signs focused on person protective equipment, BSEE staff observed.
BSEE said that the inspections suggest that operators’ safe work practices do not fully cover pressurized welding enclosures, and are not readily available to offshore personnel. Bridging documents with contractors need to be evaluated to ensure personnel fulfill obligations.
Additionally, BSEE said job safety analyses overall met the intent of Subpart S; however, multiple job safety analyses had potential noncompliance with 30 CFR 250.1911 or 250.1928. BSEE identified multiple facilities that lacked evidence of personnel training in gas detection.
“With the data we are capturing, it makes sense for us to analyze the information and look for opportunities to improve safety,” explained Lars Herbst, BSEE Gulf of Mexico Region Director. “Because gas releases can be significant safety risks, BSEE selected those incidents, developed a protocol for those inspections and conducted those targeted inspections during the pilot.”
BSEE recommends that operators develop and implement daily and weekly inspection protocol to check for common gas releases based on incident data (float cells, thief hatches, produced water treatment units, etc.). BSEE advises that operators work with original equipment manufacturers for gas detectors to develop and implement monthly, quarterly, and annual inspection protocol for handheld detectors on facilities. In particular, BSEE suggests the inspection include documenting dates of inspection, name and position of the person conducting the inspection, the signature of who performed the test, the serial number or other identifying information of the equipment and a description of the test performed.
Additionally, BSEE suggests operators review all safe work practices associated with gas detection and verify that they are available to all employees involved in the operations and reflect current practices. Operators should also meet with gas detector original equipment manufacturers, production contractors, and drilling contractors to develop minimal training requirements for day-to-day operations.
Finally, operators must verify that all responsible company personnel and contractors are trained in the work practices necessary to understand and perform their jobs in a safe and environmentally sound manner.
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