Failures in effective process safety leadership/process safety management can be linked to historical Major Accident Hazard (MAH) events such as Piper Alpha, Buncefield and Texas City amongst others. In 2018, HSE flagged concerns about the offshore industry regarding stagnating safety performance and challenged the industry to respond, leading to the adoption of the Principles of Process Safety Leadership (PPSL).
In January 2022, the HSE Energy Division initiated a targeted inspection program across a sample of the UKCS production operators to assess how the industry had responded to the challenge laid out in 2018. 13 operators were inspected by the end of the inspection program in May 2024 with an additional inspection conducted in October 2024. The organizations sampled covered the range of operating models in the UKCS and the different types of installations in use. Inspections were conducted using established HSE guidance on Major Hazard Leadership and carried out by a dedicated core team to ensure consistency of approach and comparison of performance. Benchmarking of Duty Holders against their industry peers was not conducted, and neither were scores assigned.
As a collective, industry demonstrated a strong understanding of the importance of effective process safety leadership and there were examples of good practice observed. There were however several consistent themes from the programme, all of which have room for improvement. The themes were not unique to individual organisations and there is potential for industry collaboration on certain areas to drive improvement.
Strengths
- Senior leaders understand their responsibilities for MAH management and were clear on their expectations, and exhibited the correct behaviors.
- MAH performance is regularly reviewed at leadership meetings.
- The industry has responded positively to the initiative and proactively engaged with HSE and industry peers.
- Significant time and effort have been invested by organisations into assessing their own performance against the principles and identification of any gaps. Improvement plans have been developed and are now being resourced and targeted at the key areas.
- Increased collaboration between organizations with greater sharing of lessons learned from the inspection program, discussion of areas of good practice, and areas for improvement. This is a significant improvement on previous industry interaction and should be built upon by extension into other areas of learning (e.g., incidents and high-potential events.)
- Workforce engagement and utilization of the Elected Safety Representative (ESR) function is a strong positive. Clear two-way communication and messaging to the frontline work force on expected standards of behaviour.
Weaknesses
- The industry has reached the ‘normalization of deviance’ with organizations more willing to accept the degradation of MAH barriers without acting. Knowledge and appreciation of the overall risk profile are improving. Work in areas such as maintenance backlog reviews has helped, but further work is required in order to understand where an organization may be exposed fully.
- Cumulative risk continues to be a challenge. All organizations have developed cumulative risk tools but continue to struggle with demonstrating robust assessment and recording of decisions including where the decision made was to not intervene and cease production.
- Audit and assurance are ineffective and fail to identify areas of weakness. Organizations have not fully implemented industry guidance in this area.
in the audit and assurance systems is preventing senior leaders from being assured of the ongoing effectiveness and suitability of the Safety and Environmental Management System (SEMS) and the Corporate Major Accident Prevention Policy (CMAPP). - Industry headcount has reduced significantly, with many organizations potentially under-resourced in critical areas, which is having a direct impact on MAH
management. There is increasing evidence that competency within the workforce has reduced. - Increase in the number of new recruits in industry (commonly referred to as ‘green hats’) is placing a burden on the offshore workforce. Insufficient time is being spent as part of the contractor on-boarding arrangements to ensure competency of individuals and correct behaviours.
- Contractor engagement remains focused on personal safety with limited consideration of the impact that contracting organizations can have on MAH management.
- Effective process safety leadership is being driven by individuals instead of an ingrained part of the organizational structure or culture.
- There is an absence of a structured MAH competency framework and training for senior leaders.
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