2020 - absinfo.eagle.org...FEED Front End Engineering and Design HAZID Hazard Identification HC Hydrocarbon HSE Health Safety and Environment ISO International Organization for Standardization

ADVISORY ON BARRIER MANAGEMENT2020

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SECTION 1 - INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Objective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Scope and Limitations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.3 Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.4 Terminology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

SECTION 2 - BARRIER MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

2.1 What is a Barrier? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

2.2 What is Barrier Management? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

2.3 Barrier Management in Design Phases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

2.3.1 Identify Hazards and Barrier Functions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

2.3.2 Barrier Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2.3.3 Performance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.3.4 Performance Influencing Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

2.4 Barrier Management in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

2.4.1 Monitoring and Verification of Barrier Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.4.2 Risk Evaluation and Compensatory Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

SECTION 3 - BARRIER MANAGEMENT IN DIFFERENT REGULATORY REGIMES . . . . . . . . . . . . . . . . . . . . . . . . . . 13

3.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

3.2 Norway . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

3.3 United Kingdom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

3.4 Australia . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

3.5 United States / Gulf of Mexico . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

3.6 Comparing the Regulatory Regimes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

SECTION 4 - IMPLEMENTATION – LESSONS LEARNED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4.1 Design Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4.1.1 Challenges Related to Establishing Performance Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4.1.2 Approaches to Monitoring Barrier Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

4.2 Operational Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

4.2.1 Integration with Work Processes and Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

4.2.2 Utilizing Barrier Status as Decision Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

SECTION 5 - BARRIER MANAGEMENT WITHIN THE ABS CLASS REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . 18

5.1 Class Rules and Barrier Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

5.2 Barrier Management in Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

5.3 Barrier Management in Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

SECTION 6 - REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

——TABLE OF CONTENTS

While ABS uses reasonable efforts to accurately describe and update the information in this Advisory, ABS makes no warranties or representations as to its accuracy, currency or completeness. ABS assumes no liability or responsibility for any errors or omissions in the content of this Advisory. To the extent permitted by applicable law, everything in this Advisory is provided “as is” without warranty of any kind, either expressed or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose, or noninfringement. In no event will ABS be liable for any damages whatsoever, including special, indirect, consequential or incidental damages or damages for loss of profits, revenue or use, whether brought in contract or tort, arising out of or connected with this Advisory or the use or reliance upon any of the content or any information contained herein.

LIST OF FIGURES

Figure 2 1: Principle of barrier protecting people/environment/assets against a hazard ....................................................................................................... 8

Figure 2 2: Relationship between barrier function, barrier element, performance requirements, and performance influencing factors. ..........................................................................................................................................................................................................................................................................................................9

Figure 2 3: Barrier Management process from design to operations .............................................................................................................................................................. 10

Figure 2 4: Example illustration of relationship between MAHs and barrier function in a certain area ........................................................ 11

Figure 2 5: Example illustration of hierarchical breakdown of a barrier function to barrier elements ............................................................ 12

Figure 2 6: Example of process for performing a safety critical task analysis ..................................................................................................................................... 13

Figure 2 7: Example illustration of link between barrier elements and performance requirements/standards .................................... 13

Figure 2 8: Illustration of relationship between barriers and performance influencing factors ................................................................................ 15

Figure 2 9: Barrier management activities to promote safe operation ......................................................................................................................................................... 16

Figure 5 1: The Class role in the barrier management process ............................................................................................................................................................................. 25

1 | ADVISORY ON BARRIER MANAGEMENT | ABS

——SECTION 1 – INTRODUCTIONAll oil and gas activities have associated risk. This risk should be managed by way of safe and robust design solutions combined with principles for safe operation. Some of this risk relates to major accidents, such as blowouts, fires or collision, which are considered “low likelihood – high consequence” events. However, experience shows that despite having established safe and robust solutions for design and operations, “low likelihood – high consequence” hazards and accidents will still arise. To manage this type of risk, it is important to have barriers aimed at preventing and mitigating failure, hazard and accident situations to maintain the necessary level of safety. Single failures can and will occur; however, having multiple barriers in place may prevent single failures from resulting in major catastrophes. The coordinated activities for establishing and maintaining these barriers so that they always fulfill their functions at all times is referred to as barrier management.

1 .1 OBJECTIVE

This Advisory provides operators and owners with insight related to barrier management. The application of such techniques can help strengthen a company’s risk control and potentially reduce the likelihood and impact of major accident hazards.

1 .2 SCOPE AND LIMITATIONS

This Advisory covers barrier management for the lifetime of facility. The principles and best practices outlined in this document could apply to any activity where consequences of failure are unacceptable to the public at large, regulators or stakeholders. However, the approach and chosen solutions must be adapted to fit each facility.

1 .3 ABBREVIATIONS

API American Petroleum Institute

BE Barrier Element

BF Barrier Function

BOP Blow Out Preventer

BM Barrier Management

BSEE Bureau of Safety and Environmental Enforcement

CCR Central Control Room

CFR Code of Federal Regulation

DOI Department of Interior

DPO Dynamic Positioning System Operator

DSHA Defined Situations of Hazards and Accidents

EPA Emergency Preparedness Analysis

ESD Emergency Shut Down

FEED Front End Engineering and Design

HAZID Hazard Identification

HC Hydrocarbon

HSE Health Safety and Environment

ISO International Organization for Standardization

MAH Major Accident Hazard

MATI Manufacturing, Assembly, Testing and Installation

MoC Management of Change

NCS Norwegian Continental Shelf

NOPSEMA National Offshore Petroleum Safety and Environmental Management Authority

OCS Outer Continental Shelf

OCSLA Outer Continental Shelf Lands Act

PIF Performance Influencing Factor

PS Performance Standard

PSA Petroleum Safety Authority

ABS | ADVISORY ON BARRIER MANAGEMENT | 2

PSF Performance Shaping Factor

QRA Quantitative Risk Assessment

RIF Risk Influencing Factor

SCE Safety Critical Element

SCR The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations

SCT Safety Critical Task

SCW Safety Critical Worker

SECE Safety and Environmental-Critical Elements

SEMS Safety and Environmental Management System

SIL Safety Integrity Level

USCG United States Coast Guard

1 .4 TERMINOLOGY

Concept Description Analogous concepts

Barrier

A measure intended to identify conditions that may lead to failure, hazard and accident situations, prevent an actual sequence of events occurring or developing, influence a sequence of events in a deliberate way, or limit damage and/or loss.

Safety Barrier Measure

Barrier Function

The task or purpose of a barrier.

Example: Limit size of hydrocarbon leak

Safety Function

Barrier Element

Technical, operational and organizational measures or solutions involved in the realization of a barrier function.

-

Technical Barrier Element

Equipment and systems involved in the realization of a barrier function.

Example: Gas Detector

Safety Critical Element (SCE)

Operational Barrier Element

Actions or activities which personnel must perform in order to realize a barrier function.

Example: Initiation of deluge

Safety Critical Task (SCT)

Organizational Barrier Element

Personnel with defined roles or functions and specific competence involved in the realization of a barrier function.

Example: Control room operator

Safety Critical Worker (SCW)


Concept Description Analogous concepts

Barrier Management (BM)

The coordinated activities for establishing and maintaining barriers so that they fulfill their functions at all times.

Safety Management

Barrier StrategyPlan for how barrier functions, on the basis of the risk picture, are implemented in order to reduce risk.

Barrier System

A system of several technical barrier elements that has been designed and implemented to perform one or more barrier functions.

Example: Emergency Shutdown system

Safety System

Hazard

Any agent that can cause harm or damage to humans, the environment or assets.

Example: gas under pressure

-

Major Accident Hazard (MAH)

An acute incident which immediately or subsequently causes several serious injuries and/or loss of human life, serious harm to the environment and/or loss of substantial material assets.

Example: Blowout

Defined Situation of Hazard and Accident (DSHA) (with major accident potential)

Performance Influencing Factor (PIF)

Factors identified as having significance for barrier functions and the ability of barrier elements to function as intended.

Performance Shaping Factor (PSF)

Risk Influencing Factor (RIF)

Performance Requirements

Verifiable requirement for the properties of the barrier elements in order to ensure that the barrier is effective.

Example: Valve closing time

-

Performance Standard

A collection of performance requirements to a certain barrier system or barrier function.

Example: ESD performance standard

-


——SECTION 2 – BARRIER MANAGEMENT

2 .1 WHAT IS A BARRIER?

A barrier is a measure intended to identify conditions that may lead to failures, hazard and accident situations, prevent a sequence of events from occurring, influence a sequence of events in a deliberate way, and limit damage and/or loss. Figure 2-1 illustrates the concept of barrier management.

Figure 2-1: Principle of barrier protecting people/environment/assets against a hazard

A barrier function is often provided by several barrier elements that may be either technical, operational or organizational.

A technical barrier element is equipment performing a barrier function. There are two types of technical barrier elements: active or passive. An example of a passive technical barrier element is a firewall, while an active element could be a gas detector or an emergency shutdown valve. Operational barrier elements are planned actions or activities which personnel must perform to stop an undesired sequence of events, or directly reduce the consequences of an undesired event. Organizational barrier elements are referred to as to personnel (roles) dedicated to executing a predefined action on demand. Figure 2 2 shows the relationship between barrier function and barrier elements, the performance requirements and performance influencing factors for different type of barrier elements.

The following simplified example illustrates the management of barriers: A dynamically positioned (DP) floating rig experiences a drift-off during drilling operations with the bit downhole. A yellow alarm is triggered, the rig continues to move off station. The DP operator alerts the driller to initiate the Emergency Disconnect Sequence (EDS) – effectively cutting the drill-string and thus avoiding damage to the wellhead due to exceeding forces.

The hazard in drift-off situations when drilling is a potential loss of well control, introduction of hydrocarbons, and possible escalation into a well blowout. If not adequately controlled, it may lead to a major accident causing severe damage to the environment and/or assets, and injury or death.


Figure 2-2: Relationship between barrier function, barrier element, performance requirements, and performance influencing factors.

The goal of the first barrier function is to prevent loss of position and the goal of the second barrier function is to prevent well control problems. The first barrier fails, while the second retains its function. The DP operator and the driller represent organizational barrier elements. The monitoring of the situation, detection of drift-off, alerting the driller, and activation of the EDS represents operational barrier elements. The alarm system and the EDS represent technical barrier elements.

The term barrier is well established in the offshore drilling industry, with reference to the widely adopted rules to always maintain two qualified and tested well barriers towards a reservoir (API RP 90, 2006, NORSOK D-010, 2013, ISO 16530, 2014).

2 .2 WHAT IS BARRIER MANAGEMENT?

Barrier Management (BM) is the coordinated effort of establishing and maintaining barriers so that they can fulfill their functions throughout the lifetime of a facility. This includes confirming through a systematic and continuous process that necessary barriers are implemented and function as intended in order to protect against major accident hazards identified in the risk analysis of the facility.

Figure 2-3 shows the general process of Barrier Management throughout all design phases, including the operations phase. The figure shows how various safety studies and other studies serve as input to develop the Barrier Management system through its different phases.

BARRIER FUNCTION

Technical Barrier Element


Performance Influencing Factors

Organizational Barrier Element



Operational Barrier Element



• Active (e.g., gas detector)

• Passive (e.g., blast wall)

• Requirements that apple to equipment and systems (e.g., valve closing time)

• Factors that influence the performance of technical barrier elements

• Human (e.g., control room operator)

• Requirements for human (e.g., expertise, training, etc.)

• Factors that influence human performance

• Actions or activities (e.g., initiation of deluge)

• Requirements for task (e.g., human response time)

• Factors that influence the ability to carry out tasks


Figure 2-3: Barrier Management process from design to operations

The following sections 2.3 and 2.4 describe in further detail the principles for Barrier Management in design and operations.

2 .3 BARRIER MANAGEMENT IN DESIGN PHASES

The Barrier Management process should be initiated in an early phase of the design of a facility and take into consideration the following main principles:

1. A facility-specific barrier strategy should be established, preferably during the FEED phase and further developed throughout the detailed engineering and construction of the facility. A concept of the Barrier Management may be included in the feasibility/concept selection stage.

2. The barrier strategy should be based on the specific major accident risks identified for the facility.

3. The barrier strategy should, where applicable, be presented per area and overall facility. Division into areas should be based on appropriateness for the specific facility.

4. The barrier strategy should specify which barrier functions are to be present in order to prevent and/or mitigate major accident risks throughout the entire facility.

5. All barrier functions should be described down to barrier element level.

6. Performance requirements for all technical, operational and organizational barrier elements should be established, and it should be possible to verify performance requirements through the lifetime of the facility.

7. Verification activities and intervals should be determined based on the properties and criticality of each barrier element.

8. The barrier strategy should always be kept updated and available.

2 .3 .1 IDENTIFY HAZARDS AND BARRIER FUNCTIONS

The barrier strategy should demonstrate the relationship between the Major Accident Hazards (MAH) identified for the facility and the barrier functions established to mitigate those risks. These hazards and associated barrier functions should be identified, verified and maintained through the lifetime of the facility. Identification of major accident hazards should be based on safety studies, e.g. HAZID, HAZOP, QRA etc. When the barrier strategy is presented by area, the area division should be conducted at an early stage of the barrier strategy process. Example is given in Table 2 1 on the following page:

BARRIER MANAGEMENT IN DESIGNBARRIER

MANAGEMENT IN OPERATION

• Evaluate context

• Identify hazards with major accident potential

• Identify barrier functions

Perform barrier analysis and identify:

• Barrier sub-functions

• Barrier elements

• Performance influencing factors

• Monitor and verify barrier performance

• Barrier status evaluation and compensating measures

• Management of change risk assessment

Concept/FEED

HAZID, QRA, EPA

Early design barrier strategy and performance standards

Detailed design barrier strategy and performance standards

In-service barrier management

system

Detailed design

HAZID, QRA, EPA

As-built QRA, EPA, SIL

compliance report

Concept Selection

Detailed DesignFEED MATI &

Commissioning OperationPHASES

ACTIVITIES

DELIVERABLES


Barrier Function

Area

A0 Rig in General

A1 Living Quarter ( . . .)

A3 Drilling Area incl . Moonpool

( . . .) A7 Well Test Area

BF1: Prevent Well Control Problems x

BF2: Prevent Blowout x x

(...)

BF8: Prevent Dropped Objects x x x

(...)

BF17: Prevent Loss of, and Re-establish,

Positionx

Table 2-1: Example of Barrier Function Representing Area

A barrier function refers to the role or purpose of a set of barrier elements designed to prevent, detect, control and/or mitigate risk associated with a MAH identified in a certain area. Thus, barrier functions should be described per area and reflect differences in MAHs, design properties and risks within the given area. The relationship between MAHs and the barrier functions in an area can be illustrated as a sequence; see Figure 2-4.

Figure 2-4: Example illustration of relationship between MAHs and barrier function in a certain area

Initiating event/operational error

Leak/undesired event

Prevent ignition

Fire/ explosion Escalation Evacuation/

handling

BF 01: Prevent

well control problem

DSHA 01:Well

control problems

BF 02:Prevent blowout

BF 06: Prevent fatalities during escape,

evacuation, and rescue

DSHA 05:Toxic gas release from well (H25)

DSHA 02:Platform blowout

DSHA 19:Fire or explosion in shaker room (upper/lower)

BF 05: Prevent escalation due

to fire or explosionBF 08:

Prevent dropped objects

DSHA 23:Dropped objects

BF 09:Prevent damage

to subsea equipment

and pipelines BF 07:

Prevent and limit damage to external

environment

DSHA 15: Acute pollution

DSHA 03:Subsea blowout

DSHA 04:Fire or explosion

in well test equipment

BF 04: Prevent leak and ignition

BF 03: Prevent ignition


Some MAHs may be global i.e. relevant for the entire facility while others are specific for one or more areas. An example of a barrier function for a specific area is “prevent process leaks”, whereas an example of a global barrier function is “prevent loss of structural integrity”. Every MAH should at least be linked to one dedicated barrier function.

2 .3 .2 BARRIER ELEMENTS

A barrier function may be divided into several hierarchical sub-functions to increase understanding of the various tasks covered by a given barrier function, and the various barrier elements that fulfill that function. Division into sub-functions makes it possible to follow a logic sequence from the risk identified in safety studies such as the QRA, through barrier sub-functions to be fulfilled to control this risk, and further to the barrier elements required to fulfill each sub-function. Arranging information with the use of sub-functions also provides sufficient visual overview of all barrier elements included in a barrier function.

See Figure 2-5 for an example of a barrier function with its sub-functions and barrier elements denoted.

Figure 2-5: Example illustration of hierarchical breakdown of a barrier function to barrier elements

The identification of barrier elements is based on several information sources and processes, e.g.:

• Regulations, such as the PSA Norway Facilities regulations

• Industry standards, such as NORSOK S-001 and ISO 13702

• Company standards

• Design and risk studies, e.g. HAZID, QRA, EPA

• Best practices

Technical barrier elements will typically be based on industry standards and design studies, whereas the assignment of operational and organisational barrier elements will be based on experience, document reviews and interviews with operating personnel. It may also be convenient to use “safety critical task analysis” to identify operational and organisational barrier elements; see example in Figure 2-6.

Evacuation/ handling

Barrier sub-function 2nd level

Barrier sub-function 3rd level Barrier element

Limit size of HC-Leak

Detect gas Detect gas automatically

Detect logic

ESD pushbutton

Isolate segment

Automatic isolation of segment

Infrared detectors

CCR operator

Manually activate isolation

ESD system

Manually activate isolations


Figure 2-6: Example of process for performing a safety critical task analysis

2 .3 .3 PERFORMANCE REQUIREMENTS

All barrier elements should be assigned a set of performance requirements. All performance requirements should be possible to verify through various verification activities, e.g. testing, inspection, drills, audits, etc. The performance requirements could be grouped into performance standards, at the appropriate hierarchical level (e.g. system, sub-function, barrier function); see example in Figure 2-7.

Figure 2-7: Example illustration of link between barrier elements and performance requirements/standards

Performance requirements for technical barrier elements are generally grouped into the following main categories:

• Functionality: Efficiency and capacity to work towards fulfilling the barrier function.

• Integrity: Availability/reliability: ability to be present and in a functional state upon demand.

• Survivability: Ability to withstand and function during and after exposure to the relevant accidental loads.

Performance requirements for operational and organisational barrier elements could for instance be set to task performance (e.g. sequence, time, etc.) and competency (e.g. training, drills, etc.) It may be practicable to verify these barrier elements together, as these often are closely linked. Performance requirements might also be set to the Performance Influencing Factors (PIFs) that influence the performance of the safety critical tasks (operational barrier elements) and the personnel (organisational barrier elements) to execute them, as illustrated in Figure 2 8. Then, barrier performance is verified indirectly through the condition of a set of performance influencing factors. Typical verification methods for such PIFs could be questionnaire, interviews with key personnel, observation, and document review.

Identify Main Hazards

Identify Barrier Functions

Identify safety critical task for each barrier function

Perform task analysis for each SCT, identifying

diagnostic and action elements

Determine performance influencing factors (PSFs)

for each SCT

Identify potential human errors (HEI) and recovery

potential for each SCT

Set performance requirements to PIFs based

on importance of barrier and recovery potential

Safety critical task analysis for operational barrier elements

Evacuation/ handling

Barrier sub-function 2nd level

Barrier sub-function 3rd level Barrier element Performance

standard

Limit size of HC-Leak

Detect gas Detect gas automatically

Detect logic

PS no. 3

PS no. 7

ESD pushbutton

Isolate segment

Automatic isolation of segment

Infrared detectors

CCR operator

Manually activate isolation

ESD system

Manually activate isolations


In general, for all barrier elements, the goal is to choose a limited but appropriate set of performance requirements. ‘Limited’ to avoid comprehensive and complex systems, both which may prove difficult to understand and resource-demanding to maintain. ‘Appropriate’ meaning that the requirements must reflect the risk that should be controlled.

In the introduced example with a DP floating rig that experienced a drift-off during drilling operations, the barrier elements involved may include the following performance requirements:

• Alarm system response given specified DP offset limits, which reflects the tension limit on the drilling riser and possible risk for damage to well head, drilling riser or attached equipment if not controlled.

• Response time from when a yellow offset limit is detected until control is restored (position is retained) or response time from when red offset limit is detected until EDS is activated. (The last offset limit is the physical offset limit, which represents the likely maximum tolerable load for the drilling riser and well head).

• Efficiency and integrity of the EDS. The EDS typically consist of an operation of 15-20 functions and takes 30-90 seconds to complete.

• Survivability of the wellhead, including the BOP.

2 .3 .4 PERFORMANCE INFLUENCING FACTORS

A Performance Influencing Factor (PIF) is a factor having significance for barrier functions and the ability of barrier elements to work as intended. Thus, a PIF affects the performance of one or several barriers but will not directly prevent or mitigate a major accident scenario; see illustration in Figure 2-8.

Figure 2-8: Illustration of relationship between barriers and performance influencing factors

The relatively broad category of performance influencing factors covers everything from integrity management (inspection, maintenance and testing program) to management of competency, procedures and documents, physical working environment and human-machine interface.

The potential PIFs are many and can be very detailed. However, it is recommended to keep their number and level of detail at a reasonable level and to focus on the factors with the most apparent relationship to the barrier functions or elements.In the introduced example with a DP floating rig that experienced a drift-off during drilling, the performance influencing factors may include:

– Weather conditions, i.e. the combination of wind, current and wave, influencing available response time between offset limits.

– Organisational climate which influences the cooperation and communication between the DP operator and the driller. The DP operator gives the command to execute the EDS and the driller activated the EDS.

– Human resource management, e.g. if personnel is trained and well-experienced for such situations.

– Human factors, e.g. availability, situation awareness, perception of information, motivation.

– Physical environment, e.g. human machine interface.


Barriers

Human Machine Interface Competence

Technical

Initial Events (Escalating) Events

Operational

Organizational

Procedures and Documentation

Integrity Management Others


2 .4 BARRIER MANAGEMENT IN OPERATIONS

Barrier Management in operations includes all activities carried out to ensure the functionality and integrity of barriers during all operational modes, and is based on the following principles:

1. Proper performance of all barriers should be verified on a regular basis. This verification should, if possible and appropriate, take place at a barrier element or tag level. For safety instrumented functions, verification should also be performed at a function level.

2. Verification of barriers should be evaluated against the performance requirements set in the design phase.

3. The output from the verification activities should be monitored and addressed systematically through adequate barrier monitoring and verification tools which denote the status of all barriers implemented, to mitigate risk at the facility.

4. Barrier performance data should be presented and communicated in a way that provides all relevant parties with adequate information about barrier conditions.

5. Information from the barrier monitoring and verification tools should be used actively in operational risk management and decision-making.

6. All significant barrier performance nonconformities should be risk evaluated.

7. For permanent technical, operational and organizational modifications, as well as external factors that may significantly influence the performance of the identified barrier functions, the need for updating of the barrier strategy and/or performance requirements should be evaluated.

Figure 2-9 shows the main Barrier Management activities to ensure safe operation.

Figure 2-9: Barrier management activities to ensure safe operation

The activities and the relationship between them are further described in Section 2.4.1 and 2.4.2.

2 .4 .1 MONITORING AND VERIFICATION OF BARRIER PERFORMANCE

Monitoring and verification activities consist of all activities that monitor the performance of the barriers and verifies that performance against established performance requirements. The verification of barrier performance should be systematic and performed on a regular schedule.

Monitoring and verification of technical barrier elements are typically covered through the facility’s integrity management programs (e.g. maintenance, testing and inspection). Barrier performance should also be monitored per system and performance standards (PS). If considered appropriate, other verification activities, such as multi-annual audit programs and examination of follow up trends could be applied.

Monitoring and verification of operational and organisational barriers could be verified by means of key performance indicators considered appropriate for the purpose. These data could be collected from a wide range of information sources with different updating intervals, such as competence matrices, document reviews, surveys, and audits.

Data from the monitoring and verification process should be gathered and presented using facility-specific monitoring and verification tools, e.g. Barrier Panel, SIL in operation, etc. The information should be presented at an adequate level of detail and be adapted to different user groups and areas of application.

2 .4 .2 RISK EVALUATION AND COMPENSATORY MEASURES

The performance of all barriers should be continuously evaluated. Impaired barrier performance may indicate a need for implementing improvements, compensatory measures and/or modification of a barrier element. Barrier impairments can either be foreseen or unforeseen.

Barrier Panels

Implement measures Safe Operation Monitoring and

verification

Evaluate and decide measures


A foreseen impairment of a technical barrier element normally refers to the overriding of a barrier due to operational requirements (such as maintenance), while an unforeseen impairment could be a malfunction found through testing, an inspection finding, a condition monitoring alarm, or even delayed/overdue preventive maintenance (which increases the likelihood of failure). For operational and organisational barrier elements, an impairment could be lack of personnel (e.g. due to illness), lack of competence, or lack of update of a critical document (e.g. P&ID).

In case of impairment, the barrier’s function should be restored as soon as practicably possible. Different means to improve the condition of a technical barrier can be chosen, such as corrective maintenance, or replacement of required personnel (organizational barrier element). For more permanent deficiencies, it should be considered to perform a modification to the barrier element itself (e.g. replacement by another solution). A modification may also improve the functioning of the current barrier element.

A risk assessment should be performed on all barrier impairments. Where a barrier element is impaired in a way that affects the performance of its barrier function, compensatory measures should be implemented to restore the barrier function. In cases where no adequate measures can be implemented, alternative solutions (such as a decrease in activity level) should be evaluated in order to avoid an increase in risk. All active compensating measures should be monitored and followed up to ensure that they continue to maintain the barrier function as intended.

In case of repeating barrier failures and/or negative trends, a system improvement or modification should be considered. In case of a modification, it should be confirmed the modification of the barrier is significant enough to require an update of the facility’s barrier strategy. Significance in terms of HSE risk can be difficult to estimate. Thus, this evaluation process may be supplemented by assessing the extent of changes in barrier elements and performance requirements for a given barrier function.


——SECTION 3 – BARRIER MANAGEMENT IN DIFFERENT REGULATORY REGIMES

3 .1 INTRODUCTION

Some countries (e.g., Norway, United Kingdom (UK), Australia and United States (US)) have implemented the Barrier Management philosophy into their offshore oil and gas regulations. Although the concept of Barrier Management is not explicitly stated in all regulations, the outcome of the different regulatory regimes is effectively the same: an extensive array of risk control and barrier systems whose design performance is adequate to mitigate the risk down to an appropriate safety level.

Regulations for offshore oil and gas activities may be situated on a spectrum between prescriptive requirements and performance-based regulation, and many regulatory regimes include elements of both approaches. Prescriptive regulation sets specific technical or procedural requirements with which regulated entities must comply. Performance-based or goal-based regulation identifies functions or outcomes for regulated entities but allows them considerable flexibility to determine how they will undertake the functions and achieve the outcomes (Dagg, et al. 2011).

3 .2 NORWAY

The Petroleum Safety Authority (PSA) is the safety regulatory body for oil and gas activities on the Norwegian Continental Shelf (NCS). Barrier Management has its legal foundation in the Management Regulations. Section 5 of these regulations concerns barriers, and states:

Barriers shall be established that at all times can

a. identify conditions that can lead to failures, hazard and accident situations,

b. reduce the possibility of failures, hazard and accident situations occurring and developing,

c. limit possible harm and inconveniences.

The above provision emphasizes the need for independence between barriers and strategies for design, use and maintenance. It also states that personnel should be aware of function, performance requirements, and status, and that necessary measures are implemented to compensate for impaired barriers. The regulations also differ between technical, operational and organisational barriers. Although the regulations do not explicitly refer to major accidents, in practice this is mainly where Barrier Management principles are applied.

The Petroleum Safety Authority developed a barrier memorandum in 2011, updated in 2013 and in 2017 (PSA 2017), to provide fundamental meaning and information on the basis for Barrier Management in the regulations. Their intention is to highlight how the interaction between technical, operational and organisational elements included in barrier functions can be planned for and monitored over time.

3 .3 UNITED KINGDOM

The Health and Safety Executive (HSE) regulates through a goal-setting approach, leaving the detail to individual operators to be worked out in the context of a Safety Case. The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015 (SCR 2015) came into force on July 19, 2015. The primary aim of SCR 2015 is to reduce the risks from major accident hazards to the health and safety of the workforce employed on offshore installations or connected activities. Furthermore, the above regulations also aim to protect the marine environment and coastal economies against pollution and ensure improved response mechanisms in the event of such an incident. Barriers are part of the Safety Case and are referred to as Safety and Environmental-Critical Elements (SECE).

SCR 2015 defines “safety and environmental-critical elements” as “parts of an installation and such of its plant (including computer programmes), or any part of those –

a. the failure of which could cause or contribute substantially to a major accident; or

b. a purpose of which is to prevent, or limit the effect of, a major accident.”

The Safety Case should confirm that SECEs are suitable measures to prevent/mitigate major accidents. SECEs are important in a verification scheme, however, the concept only focuses on technical aspects of a barrier.

3 .4 AUSTRALIA

Similar to the UK, Australia has adopted a goal-setting regulatory regime, managed by the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA). The Offshore Petroleum and Greenhouse Gas Storage


(Safety) Regulations 2009 (OPGGS) introduced the Safety Case, and the requirements for the content of the Safety Case. Overall, the Safety Case is a document developed by the operator which (Ref. 20):

• Identifies hazards and risks

• Describes how the risks are controlled

• Describes the safety management system in place to ensure the controls are effectively

• Is consistently applied.

Appropriate performance standards should be defined for the operation of the safety critical aspects, i.e. the performance required of a system, item of equipment, or person or procedure which is used as a basis for managing the risk of a major accident.

3 .5 UNITED STATES / GULF OF MEXICO

The Outer Continental Shelf Lands Act (OCSLA) represents the legal foundation for oil and gas activity on the United States Outer Continental Shelf. The law authorizes the federal Department of Interior (DOI) and its Bureau of Safety and Environmental Enforcement (BSEE) and the United States Coast Guard (USCG) to carry out a regulatory program to ensure that the activities are safely conducted. Many of the regulations are based on standards and recommended practices developed by the American Petroleum Institute (API) and other standards organizations. The focus for OCSLA is compliance with prescriptive regulations.

The requirements for exploration and production activities are established by BSEE and published as regulations in the Code of Federal Regulations (30 CFR Part 250 – Oil and Gas and Sulphur Operations in the Outer Continental Shelf). A known example of use of preventive barriers from these regulations is the requirement for two independent barriers on subsea BOP stacks.

The Safety and Environmental Management Systems (SEMS) as described in 30 CFR Part 250, Subpart S is a non-traditional, performance-focused tool for integrating and managing offshore operations. The purpose of SEMS is to enhance the safety of operations by reducing the frequency and severity of accidents. A part of SEMS is the identification of hazards and addressing control technologies applicable to manage hazards, measures to prevent or mitigate uncontrolled release of hydrocarbons and other materials with environmental or safety consequences, and emergency response and control plans.

3 .6 COMPARING THE REGULATORY REGIMES

The regulatory regime barrier requirement is summarized in table below.

Jurisdiction Regulatory Approach(Dagg et al . 2011)

Main Regulatory Body for

Safety Issues

Barrier Concept

NorwayPerformance-based approach with non-binding guidelines and recommended standards

PSA

Application of barrier functions and technical, operational and organisational barrier elements

United Kingdom

Performance-based approach that requires companies to continually demonstrate that they are taking measures to minimize hazards and risks to “as low as reasonably practicable.”

HSEApplication of Safety and environmental-critical elements (SECEs)

Australia

Performance-based approach that requires companies to continually demonstrate that they are taking measures to minimize hazards and risks to “as low as reasonably practicable.”

NOPSEMA

Focus on identification of critical tasks and appropriate control measures to eliminate, prevent, reduce and mitigate hazards

United States (GoM)

Mainly prescriptive regulations, often requiring industry standards through regulatory incorporation

BSEEUSCG

Use of well control technology to prevent, mitigate and remove hazards. Emergency response.


——SECTION 4 – IMPLEMENTATION – LESSONS LEARNED

4 .1 DESIGN PHASE

In the design phase, the focus is on identifying the need for barrier functions based on the given risk profile, as well as designing and defining their performance requirements. When establishing the Barrier Management approach, a vast majority of the requirements and systems are in accordance to industry standards and regulations. A challenge is to determine what should be considered beyond common industry practices, i.e. what is special for the concept and its context. Use of tailor-made solutions may prove valuable where such use is appropriate, however, the sole use of tailor-made solutions is strongly counter-productive. On the other hand, to use a solution from another upstream oil and gas unit, without giving thought and consideration to changes in concept and context may result in an inadequate solution (Vinnem 2014). A balance between the use of existing and tailor-made solutions must be achieved to obtain appropriate Barrier Management for a unit.

4 .1 .1 CHALLENGES RELATED TO ESTABLISHING PERFORMANCE REQUIREMENTS

If the performance standard requirements are not stated explicitly in regulations and standards, there exist a significant amount of possibilities for how these may be established, monitored and verified. The advantage is that the operator may adapt and evolve the requirements to a specific upstream oil and gas unit, in addition to utilizing company-specific standards based on best practices and lessons learned. The disadvantage is that the design and implementation process may be resource demanding.

Establishing verifiable performance requirements is also more challenging for operational and organisational barriers as opposed to technical barrier elements. A common approach is verification of competence requirements; however, competence consists of several elements (including knowledge, skills and abilities) which may be addressed in several ways. Completion of training and courses does not necessarily lead to fulfillment of competence requirements, as knowledge is not the same as behaviour. A solution has been to develop or utilize existing guidelines/methodologies, based on available knowledge (retrieved from academia/industry/regulations) on what are considered established and measurable requirements. An example of such a methodology is the Petro-HRA (Ref. 8).

Investigations of major accidents reveal that simple technical failures or human errors are typically not the sole reasons for catastrophic sequence of events and barrier failures. Organisational weaknesses that affect several barriers are often identified as contributing factors. As an example, an organisational barrier element included in several barrier functions requires a specific competence that is gained by providing training to personnel. If the training is flawed in one of its elements, it could affect several barrier functions. Normally, dependence and common cause failures are evaluated for technical system elements to ensure sufficient independence between barrier functions, however, such evaluation should be extended to operational and organisational barrier elements.

4 .1 .2 APPROACHES TO MONITORING BARRIER PERFORMANCE

One method of visualizing barrier performance is the use of a barrier status dashboard, which has increasingly developed into the preferred solution for short-term monitoring of barriers. The status indicators that may be automatically collected and visualized on the barrier status panel are (Ref. 19) :

• Monitoring alarms triggered by specified conditions and criticalities

• Fault alarms from the safety system

• Information/optic signal on manually disabled elements

• Information/optic signal on overdue priority corrective maintenance

• Information/optic signal on delayed preventive maintenance or testing

Currently, the industry is mainly focused on monitoring and verification of technical barriers, but the complexity of a Barrier Management system should be reflected by a corresponding approach for operational and organisational barriers. As the focus on operational and organisational barriers is increasing, the option for visualizing these barriers should be considered in the project/design phase – and not postponed to the operations phase.


An issue is that the Barrier Management system may be developed into a very detailed and complex tool that is difficult to monitor and use as a basis for decision-making. The goal should be to make it an intuitive tool in managing hazards. Digitalization is an emerging factor providing beneficial opportunities for monitoring and verifying barrier status. A difference between new and old installations is the amount of manual inputs made into the system. Newer installations possess a greater number of sensors, decreasing the need for manual verification of technical elements. Digitalization accompanied by visualization allows for both in visualizing a holistic barrier picture and retrieving information on causes to downgraded barriers – e.g. fail in self-test verification of alarm systems, disengaged local safety systems due to maintenance, use of compensating measures, unavailable personnel, etc.

4 .2 OPERATIONAL PHASE

The full benefit of Barrier Management is realized by integrating it into day-to-day operations, and as support for decision-making. The status of barrier functions is based on real-time information alongside short- and long-term indicators and helps to obtain a risk level picture of an offshore unit. The information provided by Barrier Management monitoring is applied when planning and prioritizing maintenance work, in support of risk assessment of barrier impairments, in evaluating adequate compensating measures, and in monitoring barrier status trends over time.

4 .2 .1 INTEGRATION WITH WORK PROCESSES AND TRAINING

Barrier Management is an integrated part of the risk management system. All work towards establishing and maintaining a facility-specific barrier strategy should be subject to a commitment from top to bottom in the organisation. This implies that personnel from all relevant functions and levels in the organisation should be involved in the process to ensure ownership and confidence in the system.

Roles and responsibilities related to Barrier Management in operations should be described in relevant work processes. Key users of barrier related information should be identified, and the information adapted to each user-group. Understanding of the role of a barrier and the relationship between different barriers is crucial to ensure sound risk awareness in the operation and maintenance of a facility. In addition to monitoring, the role of the various technical, operational and organisational barriers requires extensive communication and training. Training should not only be in the form of one-way information but should also include participative use of barrier-related information in practical exercises, such as case-based training and/or tabletop exercises and review to further learning and reinforce ownership.

Offshore personnel may lack experience with barrier functions and their management. In addition, barrier functions are not easily taught to offshore personnel, and common classroom and presentation methods are oftentimes insufficient. An effective approach is on-the-job training methods which are adapted to their high workload. The training should incorporate the use of reflection-based learning methods.

Situations should be taken into account wherein technical barrier elements are impaired. Incidents reveal that personnel are not always prepared to manage the event, especially if there are no procedures in place for situations wherein the technical barrier elements fail. An example is having a new drilling crew using a new drilling method aboard an existing installation. If the installation and drilling crews do not communicate sufficiently and do not possess experience working as a team, a well incident might escalate due to miscommunication. In hindsight, the solution may be to perform pre-emptive walkthroughs of scenarios, communication procedures and practices, and proper response to readings.

4 .2 .2 UTILIZING BARRIER STATUS AS DECISION SUPPORT

The visualized output of barrier panels or similar visual interfaces is highly dependent on the input, and poor quality of or missing data input may provide a wrong picture of the situation. In particular, the relation between barrier function and barrier elements may constitute a challenge. For example, if several barrier elements are impaired, their impact on a single barrier function is not necessarily reflected in digital solutions. Blind trust in the system is dangerous; hence, human evaluation of the barrier status is crucial.

In most risk assessments, it is assumed that all important barriers are functioning as intended. However, a recurring issue in operations is what seems to be lack of systematic registration, communication on and follow-up of deviations and barrier impairments. This does not necessarily increase risk above some acceptance criteria, but it does signal that the situation needs to be monitored and evaluated – and if risk increases, this has to be acted upon. This highlights the importance on increasing awareness to barrier and barrier impairments in different decision arenas –for example, using the barrier panels as an aid to discuss and prioritize approaches.


While monitoring and verification of technical barrier elements may be performed rather frequently, this constitutes a greater challenge for operational and organisational barrier elements. An example to this challenge is the dependency on personnel availability, as staff might move around on the unit and it may be challenging to track their whereabouts at any time. Another example is the frequency and quality of data retrieval, which may be particularly challenging for operational and organisational barrier elements because the information is retrieved from several sources and not necessarily frequently or simultaneously.

The paragraphs above represent examples of uncertainty that should be considered. It is important that the decision-makers are aware of and take account of the uncertainties in the information on which they base their decisions. In general, the barrier status

• May be based on erroneous assumptions (e.g. estimated vs actual time to detect abnormal situations or believing that the system tolerates more than it currently does).

• May be based on poor knowledge (e.g. “blind spots” in barrier panels, or critical information not passed on during handover meetings).

• May not reflect key phenomena of the world (e.g. too simple models originating from the use of crude risk aggregation rules).

• May not cover relevant events (e.g. decision-makers/assessors having lack of competence on relevant hazard scenarios).

A related challenge is that major modifications during operations phase makes it difficult to keep the barrier status panel up to date (Hauge & Øien 2016). Although barrier panels are a recommended approach in obtaining barrier status, they reflect only a part of the real situation. The overall message is that in operations, the context is ever changing, implying that a more thorough approach is needed to obtain a more realistic risk picture. A common approach in the industry is to frequently perform a more thorough health check on the barrier system, reviewing information from inspections, deviations or incidents and take appropriate corrective measures.


——SECTION 5 – BARRIER MANAGEMENT WITHIN THE ABS CLASS REQUIREMENTS

5 .1 CLASS RULES AND BARRIER MANAGEMENT

ABS publishes various Rules and Guides which strive to protect life, property and the environment. Class Rules are mostly prescriptive, outlining safety requirements to prevent major accidental hazards. Although not expressly stated, barriers are inherently included in those class Rules. During the design review phase, ABS engineering verifies that all safety requirements specified in the Rules are included in the design. During construction, the ABS surveyor verifies that those safety measures are installed. Periodically during operation, the ABS surveyor verifies that those safety measures are tested, maintained and perform as designed.

The successful implementation of a Barrier Management program requires proper execution in the field as well as the review and evaluation of the data. Barriers should be maintained so they continue to function to a required integrity level and should be periodically tested to demonstrate they continue to satisfy the specific performance requirements. The Owner/Operator is responsible for preparing and executing the Barrier Management program. ABS verifies that the proposed safety feature satisfies the requirements prescribed in Class Rules and periodically verifies that the safety features are functional or in compliance with the Rules.

A Barrier Management program can help owners show compliance to class Rules. Additional benefits of proper Barrier Management are that it brings a structured approach to design, manage, maintain and monitor performance of barriers. Overall, the class role relationship to the Barrier Management process is shown in Figure 5-1.

Figure 5-1: The Class role in the barrier management process

BARRIER MANAGEMENT IN DESIGNBARRIER

MANAGEMENT IN OPERATION

Early design safety/ barrier strategy and

performance standards

• Review the early design safety/barrier elements/features

• Assist operator with Flag and other regulatory body approval

• Review the detailed design safety/barrier elements/features

• Pre-review of plan for monitoring and verification

• Conduct implementation survey

• Periodic review of

• Safety features

• Maintenance records

Detailed design safety/ barrier strategy and

performance standards

In-service barrier management system

Concept Selection

Detailed DesignFEED MATI &

Commissioning OperationPHASES

CLASS ROLE

DELIVERABLES

Note: BM are to include as a minimum all prescriptive safety equipment as defined in class rules and applicable regulation.


5 .2 BARRIER MANAGEMENT IN DESIGN

This stage includes various steps for developing an asset-specific Barrier Management program similar to designing safety measures specified in Class Rules, except for risk studies and development of the Barrier Management plan. During this stage, ABS can participate in the following activities to verify that client’s barrier strategy, performance requirements of barrier elements and performance influence factors for the asset meet safety requirements as defined in Class Rules and regulations. ABS multidisciplinary teams will work with the client during their Barrier Management development activity by:

• Participation in the risk assessment workshops

• Reviewing the Barrier Management Plan to confirm that the proposed barrier elements/features comply with the class Rules and regulations.

• Reviewing Owner/Operator’s plan of verification and validation of the performance requirements and the performance-influencing factors for the barrier elements/features.

• Reviewing the Barrier Management maintenance program, including preventive maintenance, inspection and monitoring activities including scope, method, and frequency for compliance to class requirements.

• Reviewing a Management of Change (MoC) program so any deviations to the initial program will not impact the integrity of safety critical barrier elements. For example, any thresholds or triggers should be identified that would initiate activities such as engineering assessments or risk assessment to update the Barrier Management program.

5 .3 BARRIER MANAGEMENT IN OPERATION

ABS will perform periodic surveys to verify that the facility has been maintained in compliance with Class Rules and all safety systems are performing as designed. With the Barrier Management concept, the program requires proper execution in the field as well as the review and evaluation of data. The Owner/Operator is responsible for preparing and executing the Barrier program, so that they provide the required integrity level and should be tested to demonstrate compliance with the specific performance requirement, while ABS reviews and verifies the requirements are satisfied through periodic surveys.

Barrier-based management focuses resources on major accident hazards and associated barrier elements and provides a methodology for determining the optimum combination of inspection and monitoring activities. Barrier-based maintenance directs inspections, monitoring and maintenance towards the barrier, thus maintaining the highest level of integrity for barrier elements. The priority is usually determined based on the risk associated with failure of the barrier elements.

To maintain class, an offshore unit with a barrier-based management program will require the annual program survey to be conducted by an ABS Surveyor. To verify an asset with a Barrier Management program is managed adequately, the following will be confirmed during survey and audit:

• The Barrier elements/features as outlined in the ABS Rules are implemented according to the approval documentation.

• All the tests for verifying barrier condition and compliance with established performance requirements (such as the closure time for a BOP ram) have been performed.

• Verification that required inspection and monitoring activities are conducted, recorded and maintained. The inspection and monitoring data should be stored either electronically or in hardcopy to be easily retrieved for reference.

• Verification that the barrier elements/features are operated according to the initial assumptions (e.g., operation environments, manning levels, response times, etc.). If there are significant variations between the assumed and actual conditions, adjustments with proper MoC are required.

• Identify anomalies that are potentially significant to the integrity of safety critical barrier elements, and whether any action is required to address them. Verification that all anomalies are addressed in a timely manner and there are no overdue repairs.

• Verify and validate any change/modifications to the barrier elements/features (e.g., change/modification of technical barrier elements, change/modification of operating procedures, change in manning level, change of Barrier Management tool, etc.). Change/modifications to barrier elements/features are subject to the approval of the appropriate ABS Engineering Office and verification by the attending ABS Surveyor.

• Verify that change/modification been justified using proper risk analysis as required.

• As stated above, Barrier Management inherently helps Owner/Operators to show compliance with Class Rules and to satisfy class requirements for maintaining asset integrity.


——SECTION 6 – REFERENCES

1. API RP90 (2006). Annular casing pressure management for offshore wells. American Petroleum Institute, Washington, DC.

2. NORSOK Standard D-010 (2013). Well integrity in drilling and well operations, rev. 4. https://www.standard.no/en/sectors/energi-og-klima/petroleum/norsok-standard-categories/d-drilling/d-0104/. Accessed 14 Feb 2019.

3. ISO Standard 16530 (2017). Petroleum and natural gas industries -- Well integrity. https://www.iso.org/standard/63192.html. Accessed 14 Feb 2019.

4. PSA Norway (2017). Regulations relating to design and outfitting of facilities, etc. in the petroleum activities (the facilities regulations). http://www.ptil.no/facilities/category400.html. Accessed 14 Feb 2019.

5. NORSOK Standard S-001 (2008). S-001 Technical safety, rev. 3. https://www.standard.no/nettbutikk/produktkatalogen/produktpresentasjon/?ProductID=132387. Accessed 14 Feb 2019.

6. ISO Standard 13702 (2015). Petroleum and natural gas industries -- Control and mitigation of fires and explosions on offshore production installations - Requirements and guidelines. https://www.iso.org/standard/57416.html. Accessed 14 Feb 2019.

7. Dagg, J., Holroyd, P., Lemphers, N., Lucas, R., & Thibault, B. (2011). Comparing the offshore drilling regulatory regimes of the Canadian Arctic, the US, the UK, Greenland and Norway. The Pembina Institute. https://web.law.columbia.edu/sites/default/files/microsites/climate-change/files/Arctic-Resources/Oil-and-Gas/comparing-offshore-drilling%20regs%20full%20report.pdf. Accessed 14 Feb 2019.

8. PSA Norway (2017). Regulations relating to management and the duty to provide information in the petroleum activities and at certain onshore facilities (the management regulations). http://www.ptil.no/management/category401.html. Accessed 15 Feb 2019.

9. PSA Norway (2017). Barrier memorandum. http://www.ptil.no/news/barrier-memorandum-new-version-2017-article12697-878.html. Accessed 15 Feb 2019.

10. UK Legislation (2015). The Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015. http://www.legislation.gov.uk/uksi/2015/398/contents/made. Accessed 15 Feb 2019.

11. UK HSE (2015). The Offshore Installations (Offshore Safety Directive)(Safety Case etc) Regulations 2015. Guidance on Regulations. http://www.hse.gov.uk/pubns/books/l154.htm. Accessed 15 Feb 2019.

12. Federal Register of Legislation (2009). Offshore Petroleum and Greenhouse Gas Storage (Safety) Regulations 2009. https://www.legislation.gov.au/Details/F2010C00422. Accessed 15 Feb 2019.

13. US Code of Federal Regulations. Outer Continental Shelf Lands Act. https://legcounsel.house.gov/Comps/Outer%20Continental%20Shelf%20Lands%20Act.pdf. Accessed 15 Feb 2019.

14. US Code of Federal Regulations. 30 CFR 250 – Oil and gas and sulphur operations in the outer continental shelf. https://www.govinfo.gov/app/details/CFR-2011-title30-vol2/CFR-2011-title30-vol2-part250. Accessed 15 Feb 2019.

15. Vinnem, J. E. (2014). Offshore Risk Assessment. Springer.

16. Bye, A., Laumann, K., Taylor, C., Rasmussen, M., Øie, S., van de Merwe, K., ... & Massaiu, S. (2017). The Petro-HRA Guideline. https://brage.bibsys.no/xmlui/handle/11250/2441536. Accessed 15 Feb 2019.

17. Hauge, S., & Øien, K. (2016). Guidance for barrier management in the petroleum industry. https://www.sintef.no/globalassets/project/pds/reports/pds-report---guidance-for-barrier-management-in-the-petroleum-industry.pdf. Accessed 15 Feb 2019.

18. “Analysis of human actions as barriers in major accidents in the petroleum industry, applicability of human reliability analysis methods”, Project no. 220824/E30.

19. https://sintef.brage.unit.no/sintef-xmlui/handle/11250/2567437 – Petro-HRA Guideline.

20. National Offshore Petroleum Safety and Environmental Management Authority(NOPSEMA) https://www.nopsema.gov.au/safety/safety-case/what-is-a-safety-case/

TX 11/19 19359

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