Robert W. Miles
Offshore Safety Division HSE
This paper discusses the case for the offshoreenergy industry moving
towards more performance based standards for human and organi-
sational factors such as safety management systems, permit to work
and fatigue risk management.
Introduction the importance of standardisation
Standards influence many things that we interact with in the course of our normal
working lives. We take them for granted to such an extent that we are quite con-
founded when they are in conflict. Standards evolved to provide an assurance of a
predictable and repeatable level of performance; the drivers were interoperability
and mass production. In the offshore oil and gas industry, while we see ourselves
as individuals the reality is that in a globalised industry we need to transfer staff
from one jurisdiction to another, from one installation or contract to another.
Some important lessons
This drive for “human interoperability” has led to a number of attempts to intro-
duce a standard Permit to Work (PTW) system across the North Sea. Many staff
transferring from one installation to another or changing clients will be faced with
a different PTW and require additional training. Why attempts to standardise PTW
have failed provides an important lesson.
Each multi-national wantedtheir PTW system to be the newstandard, no one wanted
to have to change their system and face all the on-costs.
PTW systems tend to evolve to become fit for purpose. A drill rig with a crew of
(say) 100 can function very effectively with a paper PTW system whereas a 250
POB production platform will require a fully integrated computerised PTW and
work control system.
Does this mean that there is no future in pursuing standardisation in PTWs? Far
from it, the lesson that emerges is that standardisation of PTW systems is not the
right objective. We should instead look to standardise two key elements:
1. The user interface/experience so that each system can be navigated based upon
common training and users will “recognise” where they are.
134 R.W. Miles
2. The system performance – so that regardless of the design of the PTW there are
assured standards for key PTW objectives such as error prevention.
A performance standard; yes, a standard system; no. The same lessons can be trans-
ferred to safety management systems. As with PTW there is already comprehensive
guidance that describes these systems but as with PTW, SMS are personal to indi-
vidual organisations. No current SMS guidance sets standards for performance or
user interface.
A regulatory perspective
Enforcers of regulation like standards. The assurance of performance is their goal
and inspecting against standards is simple once there is consensus that the standard
is effective. However, we need goal setting to raise performance and address the
unpredictable with one caveat: goal setting works when founded on standards that
serve to benchmark goals, goal setting without standards becomes ungrounded.
The regulation of working time is a case in point. The EU took the prescriptive route
in theWorkingTime Directive. By and largethis has failedto regulate working hours
in relation to safety. The American Petroleum Institute recently introduced API
Standard 755 for human fatigue risk management. This sets performance standards
for risk management and as such provides a model for how to take human and
organisational standards forward.
The way forward
My conclusion is that the time is right to revisit a range of human and organizational
factors currently covered by industry guidance, and with the lessons from past
failures and successes, draft a range of standards based on assured performance.
RP 755 Fatigue Prevention Guidelines for the Refining and Petrochemical
Industries – American Petroleum Institute 2010

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