Looking ahead to 2022
Preventing major accident events
NOPSEMA’s regulatory work will continue to be carried out in accordance with well-established documented policies and procedures. This includes our assessment, inspection, investigation, enforcement, and promotional and advisory activities. However, this type of work (which is focused on discrete facilities and/or activities) cannot necessarily prevent all risks from escalating into incidents.
Therefore, NOPSEMA will also use its unique access to safety related data and consolidated industry knowledge to push beyond compliance by using a problem-centric approach to managing the risk of issues that may be prevalent across the industry. This will involve focusing on frequently occurring incident types to identify and resolve root cause issues. Specific areas of interest to NOPSEMA will continue to include (but not be limited to):
- Managing human factors, such as mental health and fatigue, that may contribute to major accident events.
- Key safety management systems, including the use of management of change, operational risk assessment, performance standards and other tools. Guidance on implementation of best practice process safety management frameworks and the use of key performance indicators.
- The management of maintenance with a particular focus on corrosion of ageing assets, ensuring that facilities are maintained appropriately until the point at which they are decommissioned.
- Executive oversight and accountability. Collecting and reviewing information relating to the degree to which senior executives and boards have sufficient oversight of, and accountability for, the control of major accident hazards.
Preventing loss of well control
NOPSEMA will continue to lead the International Regulators Forum (IRF) oversight group for the prevention of well control incidents problem statement. The objective of the group is to highlight the significant risk of well control incidents to encourage the global offshore petroleum industry to address the issue collectively.
The group will continue to promote the standardisation of methods for calculating pore pressure/fracture gradients (PPFG) and its application to well design and construction. The group invited the International Association of Oil & Gas Producers (IOGP) and the International Association of Drilling Contractors (IADC) to develop a solution, and in response, the IOGP formed a PPFG taskforce and has started developing a guideline for industry which is expected to be published in 2022.
NOPSEMA will also focus on driving improvements in the titleholder and drilling contractor interface. Industry is encouraged to consider the API Bulletin 97 Well Construction Interface Document (WCID) and the APPEA Self-Audit Checklist for Titleholders. NOPSEMA will publish a discussion paper in 2022 and host a workshop with the Australian industry.
Responsible asset stewardship
NOPSEMA recognises the decommissioning challenge faced by the offshore petroleum industry is substantial given the relatively limited experience in implementing large scale decommissioning projects in Commonwealth waters.
NOPSEMA will continue to implement its decommissioning compliance strategy and plan. This includes ensuring duty holders have appropriate plans for decommissioning and are executing those plans in a timely manner. NOPSEMA will continue to take enforcement and compliance action against duty holders who pose a higher decommissioning compliance risk as outlined in the decommissioning compliance plan.
The first stage of the enhanced decommissioning framework, developed by the Department of Industry, Science, Energy and Resources is set to come into effect in early 2022. This includes the commencement of trailing liability where previous titleholders may be called back to decommission infrastructure and remediate the environment where the current or immediate former titleholder is unable to do so.
Effective oil pollution emergency preparedness arrangements
NOPSEMA has continued to focus on the industry’s ability to effectively respond to major oil spill incidents within Australia. In response to widespread COVID-19 restrictions, NOPSEMA undertook several inspections to evaluate the impact of the pandemic and the mitigation strategies implemented by titleholders and oil spill response organisations to ensure they were still able to effectively respond to a major oil spill. NOPSEMA will undertake further inspections in 2022 focussed on industry’s ability to implement and maintain sufficient capability and effective emergency response arrangements.
NOPSEMA will also continue to work with the APPEA Oil Spill Preparedness and Response Working Group, the APPEA Drilling Industry Steering Committee, AMOSC, OSRL, and other oil spill response service providers to gain better insights into how to implement and maintain effective oil pollution emergency preparedness arrangements.
NOPSEMA will continue to assist DISER to review the offshore petroleum oil pollution risk landscape in Australia to evaluate how the oil spill preparedness and response framework could be simplified and strengthened to enhance resilience to external pressures, protect against variations in performance, and safeguard against the changing industry risk and regulatory landscape.