19
Health and safety of offshore wind farms
Abstract
As renewable energy installations increase in size/complexity and are positioned further offshore; the work hazards encountered increase substantially. It is the employers' responsibility to identify those hazards and put in place mitigation measures to reduce risk to a level assessed as being as low as reasonably practical. As a new industry there is little statutory guidance. Accordingly, this requires a systematic approach to identify and manage risk. Specialists normally conduct such an assessment. This chapter explains the basics to enable informed decision-making during the commissioning of such work and guides readers to where further information on offshore renewable health and safety may be found.
Keywords
Hazard identification; Health and safety; Offshore; Renewable; Risk mitigation; Safety case; Scope of activity; Wind farmsThe marine environment is inherently dangerous and very unforgiving. What would be a minor inconvenience on shore can become a major incident off shore.
19.1. Limits of this chapter
Health and Safety at Work is a substantial topic and a chapter within a book can only briefly touch on the subject. To put this into perspective; a general managers' guide to health and safety at work can stretch to over 300 pages, the RenewableUK guidance on Offshore Wind and Marine Energy Health and Safety Guidance is 268 pages and the Trade Industry Organization, G9, guidance on one specific aspect, Working at Height in the Offshore Wind Industry extends to 143 pages. Accordingly, this chapter does not attempt to be a reference document on Offshore Health and Safety, but will explain the process and procedures that have to be followed and provide guidance on where up-to-date and more detailed information may be found. It is written for non-health and safety professionals and is not a substitute for seeking specialist advice on this topic; however, it should help identify the questions that should be asked of such individuals.
Documents are not referenced, as change is so rapid in the industry that versions become obsolete very rapidly. All documents referred to are open source and the most recent version may be found by searching the Organization's Name and the Document Title, which are highlighted within the chapter in Italic.
19.2. Introduction
A wind turbine generator (WTG) only becomes a reality once it is constructed offshore. The construction process encompasses: survey work, cable laying, subsea structure construction in the form of mono-piles or jacket construction, tower build, nacelle lifting, hub and blade attachment and finally commissioning. Hazards within these activities include: heavy lifting, cables under tension, electricity and chemical handling. Wind turbine components have been dropped during vessel loading and lifting mechanisms have failed, dropping blades. Injuries have occurred. Although original equipment manufacturers (OEM) plan to minimise visits to wind turbines, regular servicing and rectification visits are needed. Servicing of wind turbines is a planned and coordinated process usually taking a week to complete. Similarly to automobile servicing, oil and fluid levels are checked, as are other key components. Outside the servicing regime additional visits can be undertaken to carry out retrofit or warranty work as well as fault-finding and component changes. Fires have occurred whilst turbines have been manned and on very rare occasions have resulted in fatalities. Rectification can involve major component exchange, necessitating the use of jack-up vessels.
The requirement to reach and transfer to a turbine offshore introduces logistic issues, be it marine or aviation risk. Vessels range from small agile crew transfer vessels (CTV) carrying 12–24 technicians, service/construction operation vessels with around 60 on board, to hotel ships with hundreds on board. Marine incidents have included vessel fires leading to abandonment and striking an object under power leading to lifeboat and search and rescue helicopter call out. Although offshore helicopter accidents are extremely rare, the consequences tend to be catastrophic.
Inherent in turbine design is a requirement to work at height. This includes climbing the ladders on a turbine foundation following a marine transfer from a CTV, to climbing the full height of a turbine using the internal ladder system when the lift is unavailable. This physical exertion has led to heart attacks. Working at height also introduces risk from dropped objects and falling from height.
In addition, there are risks to offshore structures from collision of passing vessels or planes which could lead to structural collapse and finally the offshore environment can throw extremes in temperature, wind, wave and tidal forces.
Such complexity requires a methodical approach to risk management. Fifteen pages can only skim the subject and only attempt to describe the task that has to be completed.
19.3. Legal framework
All employers have a duty of care for those in their employment. The Health and Safety Executive (HSE), the Maritime and Coastguard Agency (MCA) and the Marine Accident Investigation Branch (MAIB) are responsible for different aspects of the law applied to offshore activities. For example, WTG must meet statutory requirements for machines. All marine activity will come under the authority of the MCA. It can help clarify the requirement by thinking of what would happen if an accident were to occur. The HSE would investigate if the accident was to occur on an Offshore Renewable Energy Installation (OREI) and either the MCA or the MAIB would investigate a marine accident. There is memorandum of understanding between the organizations to determine who would have precedence if the accident occurred at the boundary of responsibility, for example whilst transferring from a vessel to an OREI.
The health, safety and welfare of personnel are protected by law. The UK Health and Safety Laws follow a goal-setting approach. Instead of a prescribed checklist of things to do, which may not be right in all circumstances, goal-setting law sets out the objectives to be achieved. Those that are responsible for creating the risks in the workplace are responsible for controlling them and must as a minimum:
• systematically identify hazards;
• assess the risks and the consequences of those hazards being realized; and
• put in place suitable procedures and measures to control the risks.
The offshore wind industry is still in its infancy and the ‘pushing of boundaries’ in terms of turbine size and distances from shore continue to produce additional health and safety challenges. The Health and Safety Executive document Reducing Risk and Protecting People (2001) advises if the level of risk is unclear due to new technology or processes then a ‘precautionary principle’ should be adopted. If there is a plausible and credible risk that serious harm can occur then that risk should be mitigated regardless of lack of frequency information or data.
In simple terms, employees should have the expectation of going to work and at the end of the work day returning home without any deterioration in their physical or mental health.
19.4. Safety management system
How can an employer meet such a requirement? Experience has shown that an organization must have a safety management system (SMS) in place to control risk. There are various models of SMS available; however, British Standard Occupational Health and Safety Management (BS OHSAS) 18001 and BS EN ISO 9001 on safety and quality respectively, are seen as international standards adopted by the major players in the offshore renewable energy industry. Employers use compliance with these standards as a recognized short hand that they have safety and quality under control. Some companies refuse to work with other businesses that do not carry such recognition. There is therefore a need for businesses to obtain independent certification that they meet these standards; this service is provided by international certification bodies such as Det Norske Veritas – Germanischer Lloyd (DNV-GL). The process of certification can in itself be a challenging, time-consuming though very beneficial process. However, there is a danger that certification becomes the companies' aim and not protecting the safety of its employees.
Regulators do not only police health and safety law but also provide guidance on what is expected from employers and employees. The UK HSE portal is an excellent place to start – http://www.hse.gov.uk with HSG65 Managing Health and Safety providing a foundation of what is expected of an organization's management system. The key to effectively managing for health and safety are:
• Leadership and management (including appropriate business processes);
• A trained/skilled workforce;
• An environment where people are trusted and involved.
HSG65 does not prescribe what exactly has to be put in place, but uses the Plan, Do, Check, Act cycle of goal-setting.
19.5. Plan, do, check, act
The Plan, Do, Check, Act approach, Fig. 19.1, should be seen as a circular process and may need to be completed more than once as a project is developed and implemented.
Figure 19.1 Plan, Do, Check, Act. http://www.hse.gov.uk/managing/plan-do-check-act.htm.
19.6. The offshore renewable energy industry
The first ever commercial offshore windfarm was installed in Vindeby, Denmark in 1991. The wind farm consisted of 11 450-kW turbines located approximately 2 km from the coastline. The first offshore windfarm in the UK was a near-shore installation in Blyth harbour, north-east England in 2000. For comparison, the total Vindeby output was around 5 MW, a single turbine in 2015 is capable of producing 7 MW and larger turbines are in development. As turbine size has increased they are also being located further offshore, The Bard offshore wind farm in Germany became the first to be located 100 km offshore, connecting to the power grid in September 2013. This mixture of size, complexity and distance to shore, combines to produce a complex working environment with many and varied hazards that could cause injury and loss of life. Nevertheless, the renewable industry is not assessed as a Hazardous Industry and as such is not currently subject to the UK's Control of Major Accident Hazards Regulations (COMAH), as is the case with oil and gas for example.
The Plan, Do, Check, Act cycle will be used as a framework to look at the Offshore Renewable Energy Industry.
19.7. Plan
Policy – Leadership and management need to provide strong guidance on what is expected within the organization. This is more than just a glib statement; it has to be followed by actions and resources. A clear and succinct policy will be felt and followed throughout the organization. Many of the companies working in the offshore renewable sector have a background in the petrochemical industry and bring their zero tolerance of harm culture to the renewable industry.
Think about where you are now and where you need to be – An analysis of the organization's current capability at managing health and safety is a prerequisite to assessing the risks as projects proceed offshore. New competences may be required, which may have to be sourced from outside the organization and from other industries. As a relatively new industry; health and safety rules, regulations and procedures are constantly evolving and the option of controlling risk through the perspective of compliance in isolation, will not work.
Say what you want to achieve and who will be responsible – Objectives and targets must be achievable and there has to be an understanding of who is responsible for meeting such targets. Organizations that have a long track record of managing complex and high hazard activity, for example aviation, realise that risk is managed by the owners of the risk and not the prerogative of health and safety professionals. Clarity in accountability and responsibility will ensure correct resources are applied and that those that have to implement policy have the training and competence to complete their actions. Accountability can best be described as the owner of the risk, who is ultimately responsible should anything go wrong and has the budget to implement change. The responsible individual implements the process and procedures put in place to manage risk and should have received the appropriate training and equipment to undertake his duties.
Decide how to measure performance – Performance can be measured in many ways. The easiest is to look at historical data – how often an event occurs per 100,000 h worked. Such historic data showed that there was a correlation between the number of major injury (accidents), minor injury (incidents) and non-injury accidents (near-misses).
Fig. 19.2 shows the ratios found by Heinrich in 1931.
This led to the belief that in pursuing the non-injury events, this would also eliminate major injury accidents. This activity tended to concentrate on the causes of the minor events and not the precursors of the major events. Recent work is looking at concentrating on the precursors of major injury events. A popular statistic is the number of days worked without a lost time incident (time-off following an incident). Where an organization rewards such milestones, the pressure on an individual not to report an accident on the 499th day out of a 500-day target is immense.
Such historic information is known as lagging indicators. They are the bottom-line numbers of safety performance within a project. They tell you how many incidents occurred and how many people were hurt. They do not say how well an organization is at preventing accidents. Conversely, low reporting may give a false impression that safety is under control. A leading indicator is a measure preceding or indicating a future event used to drive and measure activities carried out to prevent and control injury. Examples include: safety training, employee perception surveys and safety audits. An example that has worked well in the renewable industry is the recording of the number of management safety walks, these demonstrate leadership's commitment to safety and provide an interaction with the work force.
Consider hazards and cooperate with those that share those risks. Wind farm projects are a complex interaction of risk owners. A WTG is a complex piece of equipment that introduces risk from rotating equipment, combustible materials, electricity and stored energy. Design risk assessments (DRA) are completed by the OEM and where possible these risks are eliminated in initial design. Not all risks can be eliminated and process and procedures are introduced to control and mitigate these risks. Such processes and procedures need to be clearly transferred between the OEM and the customer. Most projects involve numerous subcontractors, from marine heavy lift down to a specialist inspection team of one. In identifying risks, those that are exposed to, or could be affected by it, should be involved in the deliberation. This also applies to adjoining risk producers, for example colocated oil and gas installations.
Plan for change and identify any legal requirements that have to be met – Changes in circumstances can alter the risk profile. If we consider the different phases of a wind farm development
• Preconsenting survey
• Construction phase
• Under water
• Cable laying
• Foundations
• Turbine construction
• Operation and Maintenance (O&M)
• Planned maintenance
• Rectification
• Repowering
• Decommissioning
The number of personnel exposed to hazards and the type of hazards can vary significantly. A construction site can have 10 times the number of vessels and personnel offshore compared to the O&M phase. Emergency procedures and first aid provision may be well found during construction, but may reduce dramatically as the project moves to Operation and Maintenance. Weather changes can alter marine risk and night operations may complicate working procedures and delay rescue procedures. Change has to be monitored and its impact has to be anticipated to ensure risk remains under control.
19.8. Do
Identify your risk profile – With such a new industry, identifying the risk is the foundation of any safety management system relating to offshore renewable energy and will be covered in depth. As with similar industries, such as oil and gas, it is the hazard that has failed to be identified and treated that causes the accident.
It is worth starting with some clarification:
• A hazard is anything that may cause harm, such as electricity, working at height or rotating equipment.
• The risk is the chance, high or low, that someone could be harmed by these and other hazards, together with an indication of how serious the harm could be, for example whether an event could cause a single or multiple fatalities.
In simple terms the risk assessment process consists of:
• Identifying the hazards;
• Deciding on who might be harmed and how;
• Evaluating the risk and deciding on precautions.
There is also a requirement to record significant findings and to put in a process to review the assessment on a regular basis and following an incident or a major change in what has being assessed.
Turning to the systematic identification of hazards. There are currently no guidelines of what constitutes a renewable energy hazard list. However, there are industries with similar profiles. For example, ISO 17776 has been developed to aid the oil and gas industry. Although offshore renewables occupy a similar geographical footprint it does not have the petrochemical risk and personnel tend to be dispersed and work in smaller groupings. The following gives an outline of the likely hazard areas:
The risk associated with the product:
• Wind turbine
• Transformer platforms.
• In both cases, these can be further divided into control of hazardous energy:
- Fire
- Electrical
- Mechanical
- Hydraulics and pneumatics.
The geographical and environmental impact of placing the product offshore:
• Vessel and aircraft collision
• Structural failure.
The human interaction with the product:
• Working at height
• Lifting
• Marine and aviation access
• Occupational activity.
Activities to mitigate risk or to respond to incidents:
• Offshore medical fitness
• Offshore first aid training
• Offshore emergency response
• Onshore integrated emergency response planning.
Trade bodies provide industry guidance and customer groupings also work together to establish best working practices. The RenewableUK portal www.renewableuk.com provides access to health and safety documents. Their document, Offshore Wind and Marine Energy Health and Safety Guidelines, gives a structured approach to identifying the possible risks that could be expected and are split into 24 major categories from Access and Egress to Work at Height.
The offshore renewable industry is primarily a danger to its own employees; interaction with the public is limited. Nevertheless, consideration has to be given to the unplanned visitor to a WTG. Here there is a conflict between the requirement to provide refuge for a mariner in distress and the physical control of access to a WTG.
Turning to risk assessments. The HSE Information Sheet – Guidance on Risk Assessments for Offshore Installations, outlines the procedures that may be followed. Although specifically developed with the oil and gas industry in mind, the key principles apply equally well to the renewable energy industry.
In evaluating risk, it states, the risk assessment methodology applied should be efficient (cost-effective) and of sufficient detail to enable the ranking of risks in order, for subsequent consideration of risk reduction. The rigour of assessment should be proportionate to the complexity of the problem and the magnitude of risk.
Risk assessments can progress through the following different tiers of assessment:
• Qualitative (Q), in which frequency and severity are determined purely qualitatively.
• Semiquantitative (SQ), in which frequency and severity are approximately quantified within ranges.
• Quantified risk assessment (QRA), in which quantification occurs.
This approach ensures that time and effort are expended in appropriate areas.
In the renewable industry, Q assessment is the norm as most hazards are understood and there is considerable experience in how to control these risks from other industries. Examples include heavy lifting, working at height, electricity and rotating machinery. Such an assessment would be conducted in-house and would form the vast majority of assessments undertaken. The risk can be plotted on a risk assessment matrix, which can be superimposed by the risk tolerance of the organization.
For example, in the Risk Assessment Matrix in Fig. 19.3, any risk within the red area would be unacceptable and the activity would not be contemplated until mitigation measures were applied that either reduced the severity or probability of the event occurring. Areas in green would be deemed as under control and no further actions would be required. The yellow area would be the subjective area, sometimes referred to as the As Low as Reasonably Practical (ALARP) region. Here the residual risk is acceptable to the organization as any further activity to reduce risk would be deemed as requiring excessive effort measured in time and money. This recognizes that there will always be pressure on resources and by comparing residual risk against other risks, attention is placed on where best value for money can be achieved. Nevertheless, this heightened risk remains and business takes the responsibility that the level of risk is within the business' tolerability. As this is a very subjective decision it is essential that this decision is made by the risk owner. In some organizations the limit of authority to accept such risk varies within the company, with the highest risk being approved at the highest level, for example the Chief Executive Officer.
There are some areas where the consequence of a hazard may be more severe and with historic information from such a new industry lacking, an SQ assessment may be appropriate. The risk from fire being an example, where the consequences to an individual are understood but the probability of these occurring is not clear. In such a situation detailed computer modelling may be considered to populate an SQ assessment. These may be conducted in-house, but may also require specialist support.
At the top end where consequences may be very severe, possibly involving multiple fatalities and the hazard could affect the general public, then a QRA conducted by a specialist organization will be undertaken. An example would be the risk associated with the loss of a blade from a WTG.
Once the risk is identified, quantified and prioritized it should be treated to bring the residual risk down to an acceptable level. The following is a recommended hierarchical approach to risk reduction:
• Elimination and minimization of hazards by design (also known as safer by design);
• Prevention (reduction of likelihood occurring);
• Detection (raising the warning);
• Control (limitation of scale, intensity and duration);
• Mitigation of consequence (protection from effects); and
• Escape, evacuation and rescue (EER).
Advice on risk mitigation may be found from many organizations. The following are examples of organizations that provide specific advice on key hazards; the list if far from exhaustive.
19.8.1. WTG hazards
• HSE – Safe Use of Work Equipment – Provision and Use of Work Equipment 1998 (commonly known as PUWER 1998). Approved Code of Practice and Guidance
• HSE – Memorandum of guidance on the Electricity at Work Regulations 1989 – Guidance on regulations Guidance on regulations
19.8.2. Marine hazards
• IMCA – Guidance on the Transfer to and from Offshore Vessels and Structures
• IMCA – Guidelines for Lifting Operations
• MCA and NWA – The Workboat Code – International Working Group Technical Standard
19.8.3. Occupational hazards
• HSE – Manual handling assessment charts (the MAC Tool) Guidance on regulations
• HSE – Safe Use of Lifting Equipment – Lifting Operations and Lifting Equipment Regulations 1998 (commonly known as LOLER 1998) Approved Code of Practice and Guidance
• G9 – Good Practice Guideline – Working at Height in the Offshore Wind Industry
• G9 – Good Practice Guideline – The Safe Management of Small Service Vessels used in the Offshore Wind Industry
19.8.4. Emergency preparation and response
• RenewableUK-Incident Response: Offshore Wind and Marine Projects∗
• MCA – MGN371 – Offshore Renewable Energy Installations (OREIs) – Guidance on UK Navigational Practice, Safety and Emergency Response Issue∗
• MCA – Offshore Renewable Energy Installations. Emergency Response Co-operation Plans (ERCoP) for Construction and Operations Phase, and Requirements for Emergency Response and SAR Helicopter Operations∗
• ∗These documents are to be replaced by Integrated Emergency Response – Renewables (IOER-R) in late 2015.
Nevertheless, the above is only advice and the final decision on how risk is to be treated rests with the management responsible for putting individuals in harm's way.
Organise activities to deliver the plan. In the process of determining how the risk is to be controlled it is important to involve workers and communicate, so that everyone is clear on what is needed and can openly discuss issues. This assists in developing positive attitudes and behaviours. Management must provide adequate resources to deliver the plan, including specialist advice where needed.
Implement the plan. In implementing the plan management must:
• Decide the preventative and protective measures needed and put them in place. Such information should be clearly published to enable a safe system of work to be established. The RenewableUK – Wind Turbine Safety Rules are a good example of such procedures.
• Provide the right tools and equipment to do the job and keep them maintained.
• Train and instruct, to ensure that everyone is competent to carry out their work. As the renewable energy workforce tends to move from project to project, the main industry leaders have standardized the minimum safety training required to work within the industry. Information can be found through the Global Wind Organization portal at http://www.globalwindsafety.org/.
• Supervise to make sure that arrangements are followed.
Within the offshore renewable industry, managing contractors is a special cause for concern. Contractors have a higher accident rate than core employees. The reason for this can be many-faceted and each situation must be assessed on its own merit and special procedures will need to be developed to monitor and control the situation. This may require external specialist support where in-house experience is lacking.
A key component of any plan is to have contingency measures in place should any incident occur. Within the renewable wind industry events can occur organically from within the wind farm's activity or a wind farm can also collect events from passing or adjoining general marine activity.
The United Kingdom's emergency services operate a three-level escalatory response to any incident, see Fig. 19.4. The activity related to dealing with the incident at its source is deemed to be at the operational level. Where the incident requires the coordination of a number of responding assets, this level of response is defined as the tactical level. Where an incident is likely to exceed predefined contingencies, then it can be escalated to the strategic level (sometimes also known as a crisis response) so that all the organization's assets may respond. These three levels are also referred to as Bronze, Silver and Gold.
Figure 19.4 Strategic, Tactical and Operational levels of Command and Control – https://www.app.college.police.uk/app-content/operations/command-and-control/definitions-and-procedures/.
The regulatory authorities expect windfarms to have the ability to immediately respond to foreseeable events. Historic evidence shows that individuals suffer life-threatening medical emergencies, eg heart attack, industrial accidents affecting limbs and ergonomic events leading to strains and dislocations. Multiple casualties are rare, although marine-related events have seen personnel forced to enter life rafts, with a risk of an unintended water entry, exposure and drowning. All offshore incidents eventually reach shore and recovery to the mainland should be factored into all response plans. This may require the creation of reception centres, next of kin notification and survivor support. Liaison officers and communication specialists are most likely to be also required.
How a windfarm principal duty holder prepares to respond to an incident will be determined by the likely magnitude of the incident and assets that are available to respond. This will change as the windfarm evolves through the lifecycle of the project. Accordingly, any assessment and response plans will require updating as risk and responding assets change.
Activity at the operational level is detailed within the principle duty holders' Emergency Response Plan. This should cover all activity and all personnel, including subcontractors, within a defined windfarm. This clarity of command cannot be overemphasized and is one of the key lessons identified from the oil and gas industry. Should the incident require a complex response or external assistance, it should be escalated to the tactical level. This would be in the first instance to the MCA Maritime Rescue Coordination Centre (MRCC) and would be in accordance to the predetermined Emergency Response Cooperation Plan (ERCoP). It is mandatory for ERCoPs to be established before wind farm construction commences and for them to be updated as the wind farm progresses into Operation and Maintenance. The full requirement for ERCoPs can be found at MCA – Offshore Renewable Energy Installations. Emergency Response Co-operation Plans (ERCoP). ERCoPs are documents jointly prepared by the principal duty holder and the MCA, they cannot be created in isolation and therefore ensure face-to-face dialogue.
Where there is a risk to life or where there is a risk to the quality of life, the incident should be immediately escalated to the MCA in accordance with the ERCoP. The MCA will then take responsibility for the coordination of the incident and determine whether national search and rescue assets should be deployed. In a medical incident the MCA will seek telemedicine advice on the urgency and efficacy of an immediate SAR helicopter transfer. On occasions the windfarm assets may still be the preferred means of transportation; however, coordination with other emergency services, eg the ambulance authority, will remain the responsibility of the MCA.
Where an incident is greater than the capability of the windfarm and normal standby national emergency response, then the incident may be escalated to a strategic/crisis incident. It is difficult to imagine a windfarm originating an incident that would require such an escalation. It is more likely to arise from a marine incident occurring within or near the windfarm. All mariners are obliged to respond to personnel in distress at sea. As windfarms progress further offshore and into oil and gas territory, geographical integrated response procedures will be established, detailing how the different stakeholders will provide mutual support.
Any incident that causes loss of life will also be investigated by the police. This can require the interviewing of witnesses and fact-finding visits to OREI.
19.9. Check
Measure your performance. A safety management system is only as good as the feedback it generates. Monitoring can be broken into ‘active’ or ‘reactive’. Active include routine inspections, health surveillance and safety equipment checks. Reactive methods include investigating accidents and incidents and monitoring causes of ill health and sickness absence records. Active monitoring is difficult in the offshore renewable industry. Work teams are small and work independently from senior supervision. In addition, no-notice visits are difficult to conduct as marine logistics require prior notification. Accordingly, self-supervision with remote monitoring of activity is becoming commonplace.
Investigate the causes of accidents, incidents or near misses. The key to reactive monitoring is to choose the correct level of investigation. There is little to be gained in completing a full-blown investigation when the injured party and supervisor are fully aware of the cause and the corrective actions required. Investigating a near miss that could have had severe consequences may be more beneficial. Accident investigation requires a book on its own. However, care has to be taken to identify what went wrong and not who did wrong. A hunt for a culprit is a sure way of ensuring that incidents and near misses are never reported. Such a culture is known as a hanging culture and can be very corrosive. The opposite approach is the non-blameworthy culture, where any event is forgiven, as long as it is reported. This also has its issues, with wilful breaches of procedures seen as having no repercussions, thereby encouraging unsafe actions. A middle ground has been christened a Just Culture, where honest mistakes are recognized as more of a systems failure than a personal failure. However, wilful breach of safety procedures will not be tolerated and will be subject to disciplinary action. On occasions management may perceive wilful breach, but the individual may claim a mistake. On these occasions it might be useful to look at the incident from the eye of work colleagues, who may have also experienced a similar situation, albeit without the unfortunate consequences. For a Just Culture to succeed it must be seen to be fair by the work force.
There are a number of tools and methodologies available to assist in investigating an accident, incident or near-miss. They help in identifying the root cause of any incident. Management oversight is often credited as a root cause or at least a contributory factor. After all, not many individuals come to work to harm themselves. An in-depth investigation can identify many shortcomings within an organization; however, they can be time-consuming and costly. It is therefore imperative that any lessons are acted upon and that the information gained is shared with the workforce in an open and honest manner, however uncomfortable the findings may be to management.
19.10. Act
Review performance. All employees should have the means to report accidents, incidents and near-misses. These can be as simple as verbally reporting to line management, to IT solutions that record, distribute and process all information into user-friendly categories that support trend analysis. The larger the organization the stronger the requirement for such IT systems. In addition, trade organizations, such as IMCA, G9 and RenewableUK, run industry-specific reporting systems, that attempt to collate information across the whole industry so that collective improvement can be instigated.
Regulatory authorities also require the mandatory reporting of accidents and incidents above a certain threshold. Where they believe that action is required they can raise an improvement notice and where the authorities believe there could be a risk of serious personal injury then an enforcement notice requiring the cessation of the activity can be raised.
Take action on lessons learned, including from audit and inspection reports. Lessons identified must be converted into lessons learned. Following the systematic identification of the root cause, a corrective action (an attempt to prevent reoccurrence) or a preventative action (to stop the event occurring) should be applied. Collectively these actions are known as Corrective Actions Preventative Actions (CAPA) and organizations have systems in place to ensure that CAPA owners are identified and those actions are monitored and closed.
19.11. For the future
With wind farms becoming larger and further offshore, personnel are being employed permanently offshore for long periods, either within vessels (hotel ships and service operation vessels) or fixed offshore transformer platforms. The oil and gas industry has been in a similar situation for decades. However, the current renewable industry approach to risk management may not stand up to the demands of planned activity. History has shown that incidents occur at the interaction and boundaries between risks and risk owners. This can be well-illustrated by the tragic Piper Alpha Platform accident in 1988, which led to the death of 167 workers. Lord Cullen led a review into causes of the disaster and to recommendations for the changes to the safety regime. The cause was identified as a hydrocarbon leak following the removal, blanking of a pump and then recharging of the pipe. It is believed that the consequence of pump removal was not fully understood by those responsible for the restart. Lord Cullen's report resulted in the oil and gas industry adopting a Safety Case approach to managing risk. The safety case is required to provide full details of the arrangements for managing health and safety and controlling major accidents on an installation. This umbrella approach is intended to ensure that risks are not missed, especially where activities and risk owners meet. Safety Cases were mandated by law for the oil and gas industry; however, they are currently not a requirement for the offshore renewable industry. However, it may become very difficult to justify that a principal duty holder has risk controlled without adopting such a process.
19.12. Conclusion
If you want to be 100% risk-free; then avoid offshore activity. However, large WTG work well in the stable and strong wind environment that exists offshore. Those that manage the risk well will have a commercial advantage. Risk management is built on detailed hazard identification. This activity must commence at the beginning of a project and requires a systematic approach; it is not an afterthought. Only with an early understanding of the risk exposure can those accountable for the activity put control measures in place at the design phase; the only time where elimination of a risk is a possibility. Although a young industry, it has made tremendous progress through adopting and adapting process and procedures from similar industries.
With strong leadership, management and a well-trained and dedicated workforce, it is possible to go to work offshore and return home safely, but it requires everyone involved, from designers, supply chain managers, lifting supervisors, marine coordinators, operational managers and engineers to all play their part. Safety is a team game, even more so when played offshore.
Abbreviations
| ALARP | As low as reasonably practical |
| CAPA | Corrective actions preventative actions |
| CTV | Crew transfer vessels |
| DRA | Design risk assessments |
| EER | Escape, evacuation and rescue |
| ERCoP | Emergency response cooperation plan |
| HSE | Health and safety executive |
| MAIB | The marine accident investigation branch |
| MCA | The maritime and coastguard agency |
| MRCC | Maritime rescue coordination centre |
| O&M | Operation and maintenance |
| OEM | Original equipment manufacturers |
| OREI | Offshore renewable energy installation |
| Q | Qualitative |
| QRA | Quantified risk assessment |
| SMS | Safety management system |
| SQ | Semiquantitative |
| WTG | Wind turbine generator |
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