Independent Verification of Safety-Critical Elements
Authors: Denney Dennis 
Published: February 2015

This article, written by Senior Technology Editor Dennis Denney, contains highlights of paper SPE 136392, ’Independent Verification of Safety-Critical Elements,’ by Julien Marty, Sophie Theys, SPE, Christian Bucherie, Andy Bolsover, and Philippe Cambos, Bureau Veritas, prepared for the 2010 SPE Russian Oil & Gas Technical Conference and Exhibition, Moscow, 26-28 October. The paper has not been peer reviewed.
The main objectives of independent verification are to help substantiate that current oil and gas best practices are used; to provide assurance that facilities have been designed to operate safely throughout their life-time; and to ensure that all health, safety, and environmental risks have been managed to acceptable and as-low-as-reasonably-practicable (ALARP) levels. Independent verification anticipates the lack of applicable laws or standards, especially in new environments. This approach, initially introduced in the UK after the Piper Alpha disaster in 1988, is becoming an industry standard.
Introduction
A prescriptive approach to safety and environmental management of offshore installations relies on a selection of specific regulatory requirements developed for all phases from design to decommissioning, which are imposed by a regulator. The owners of the offshore installations must follow existing standards, practices, guidelines, and procedures. The same regulator will evaluate the compliance through review, auditing, and inspections of plans, permits, and related documents. Relying on this approach alone has revealed several disadvantages.
The regulator must understand and be capable of keeping up with evolving technologies and practices used in the offshore industry to update the requirements and evaluate compliance. The maintenance of detailed regulatory requirements on how to construct safe installations or operate them properly is resource intensive, and these requirements lag behind best industry practices.
The owner of offshore installations must be completely knowledgeable in the regulations (or lack thereof) of each country in which it operates.
The owner of offshore installations is responsible only for complying with individual regulatory requirements.
Particularities of each offshore installation are not considered and, as such, may not be analyzed as a whole, within the context in which they operate.
Complex working situations occur on offshore installations, possibly creating dangerous conditions that must be examined carefully and organized in the best way possible—the details of which cannot be foreseen in a prescriptive approach.
Goal-Setting Approach
The goal-setting approach was introduced through Lord Cullen’s 1990 report on the Piper Alpha disaster. Instead of imposing rules, the regulator proposed specific quantifiable goals that the offshore installations’ owners must meet. Hence, the owners have flexibility on how they will meet these goals. An important change is that the responsibility for managing safety and environmental aspects rests on the duty holder, which is either the owner or the operator of the offshore installation. The goal-setting approach does not exclude prescriptive regulations. Often, hybrid solutions use elements from both goal-setting and prescriptive approaches.