Carlstien Lutchmedial, international OSH specialist, examines the statements released by both Paria Fuel Trading Company Limited and LMCS Limited last week.
The statements provided by LMCS in absolving themselves from the death of the four workers and injuries sustained by the fifth worker is irresponsible. This was a job being done by LMCS and under their control. To say it is someone else’s fault is a clear reflection of their irresponsibility also in failing to ensure the health and safety of their own workers. If I were an employee of LMCS, I would be ready to quit given a statement like that as it shows a lack of care.
While the facts surrounding the incident is not clear from both Paria and LMCS, one thing is evident; four people died who worked for LMCS. For this to occur, it would mean that proper diving safety protocols were not followed along with industry best practices in the provision of proper safety and emergency response procedures in a high-risk activity.
Regardless of what caused the incident; a valve turned on, a cap removed, a pipe broke, this type of diving incident occurring is well documented and best practices should have been employed. The United Kingdom (UK) has safety regulations for diving operations in the oil and gas industry and is accepted in many countries including Trinidad & Tobago as best practice in managing diving health and safety for the oil and gas industry. In addition, there are many international consensus standards that are available that guide such activities. For LMCS to look at this incident from a reactive perspective lends credibility that they were not focused on the safety of their workers. They should be apologetic and explain what they could have done differently to prevent incidents like this. Incidents like this are a leading indicator of an organisation having many smaller incidents occurring but without major injuries or deaths. Referred to as “near misses”. Usually, the result of “cutting corners”.
There must be an emergency response plan executable immediately
Statistically, for every death that occurs in the industry, there would have been 30 serious injuries and about 600 near misses.
In the safety plans of high risk/dangerous diving operations, there must be a high-level clearance from both the client (Paria) and contractor (LMCS). These clearances range from having a detailed dive plan, methods statement, bridging documents, permit to work (PTW), lockout tag out, an emergency response plan executable immediately.
The UK Health and Safety Executive (HSE) in its Safety Case Regulations (SCR) 2005 & 2015 Regulation 2 defines diving as a ‘major accident hazard’. SCR2015 Regulation 16 (SCR 2005 Regulation 12) requires that all hazards with the potential to cause a major accident be identified and all major accident risks evaluated and measures are taken to control those risks. (Many companies in T&T and internationally follow The UK Offshore Installations (Safety Case) Regulations 2005 & the Offshore Installations.)
Therefore, while the OSH agency may not have specific regulations, companies in the oil and gas industry follow best practices.
Best practices would require that any known underwater or above-water items of plant or machinery under their (LMCS or Paria) control that may cause a hazard to the dive team (for example, a ship’s propellers, corrosion that can cause a pipe to break, water intakes, Delta P situation or turbulence, gas flare mechanisms that may activate without warning or plant likely to start automatically), the diving contractor and workers should be aware of the location and nature of such hazards.
This information should be provided in sufficient time so that it can be taken into account by the diving contractor when preparing the risk assessment before producing the diving project plan.
At the same time Paria was expected to provide the diving contractor with details of any possible substance, situation, event likely to be encountered by the dive team that would be a hazard to their health (for example, vacuum created by a Delta P situation, corroded pipe, residual pressure in piping, radioactive materials). This information should be provided in writing and in a sufficient amout of time to allow the diving contractor to carry out the relevant risk assessment and, if necessary, to take appropriate action.
Paria must take reasonable measures to ensure compliance
If Paria commissioned the diving project then they have a general duty to take reasonable measures to ensure compliance with international Diving Regulations and or best practices in commercial diving. Paria should have clearly defined the scope of the work, including any health and safety specifications for the work. This would include using a remotely operated vehicle (ROV) with cameras to assess the full length of the vertical riser (pipe) to determine its integrity. There is no information on whether this was done or not. The diving contractor generally has overall responsibility for and control of the diving project.
Before this work began, Paria must have been satisfied that the diving contractor was competent to do the work. Paria should have made reasonable enquiries about competence, especially with regard to adequate training, knowledge, experience and resources for the work to be performed. However, Paria would not be expected to evaluate and monitor the actual diving skills of the contractor employees.
According to Paria, there was “no pipe connection mechanism, machinery, or equipment whatsoever connected to the section of pipeline under repair, so nothing could have been switched on or activated by Paria, to change the condition of the pipeline while the project was being undertaken by LMCS.”
Did LMCS break the pipe creating an opening so large that it would suck in five men? Was the pipe corroded and broke on its own? Since this riser (pipe) was not in use, was it blanked and the blank broke causing the pressure differential? Was the pipe head in an open condition within the hyperbaric chamber aka “habitat” and someone in fact turned something on or off to create the vacuum? This still has to be determined.
Bottom line is that an event occurred of such great magnitude that five people were sucked into a 30-inch pipe which must have been caused by the catastrophic failure of safety control barriers or the riser (pipe) itself failed creating an opening.
Contractor’s general responsibilities
The diving contractor’s general responsibilities are to ensure that: (a) the diving project is properly and safely planned, managed and conducted; (b) a diving project plan is prepared, including emergency plans and procedures–the diving project plan should be authorised and dated by a responsible person acting on behalf of the diving contractor; (c) risk assessments are carried out. No work should be carried out if the emergency rescue plan is not rehearsed and can be executed immediately.
In conducting the risk assessment, account must be taken of the general principles of prevention. This risk assessment should have been done jointly by Paria and LMCS. It can be expected that LMCS would not have the details of the riser (piping). Diving should be avoided where the level of risk cannot be determined and controlled to an acceptable level or an emergency rescue response plan cannot be executed the moment an incident occurs.
It is normal that the client is involved in the production of the site-specific risk assessments. The site-specific risk assessment must identify site-specific hazards and their risks. This type of dive requires a dynamic risk assessment. That is one that requires frequent updating by both parties.
The risk assessment control measures must provide contingency procedures for any foreseeable emergency (for example, retrieval of injured and/or unconscious divers from being sucked into the pipe). Again, note that this type of risk assessment requires a competent person with both diving experience and technical safety knowledge of oil and gas risers, lockout tag out, pressure differential, recognition of hazardous conditions such as a corroded pipe that may break. This would also include exposure to deadly hydrogen sulphide gas.
Risk assessment is only as good as the knowledge of the person executing
A risk assessment is only as good as the knowledge and experience of the person/people carrying it out. As such, a team of knowledgeable people in both safety and diving operations from both Paria and LMCS should be engaged in the risk assessment and the application of control measures. Best practices would require frequent and updated risk assessments (referred to as dynamic) by both Paria and LMCS.
Differential pressure situations such as blanked pipelines or void spaces pipes pose a significant hazard when work is being done on them. Where any intakes or discharges are known or suspected, suitable measures, including physical or mechanical isolation (lockout tag out) where practical, should be taken to ensure that these cannot be operated while a diver is in the water. Measures to protect divers should be part of a safe system of work such as a permit-to-work (PTW) system. A PTW would include the risk assessment and control measures to be applied to all hazards identified and the emergency response plan identified. This document then gets signed off and dated by both parties since it’s a high-risk activity.
When looking at fluid dynamics, as fluid flows through a piping system, where pipes rise and fall, changing elevation, the pressure at a particular point in a pipe is also affected by the changes in elevation of the fluid that has occurred.
For example, consider a single vertical riser pipe where the fluid is flowing upwards, gaining elevation height as it goes. The weight of fluid acting ‘on top of the fluid at a point in the pipe reduces as we consider points higher up the pipe since there is less fluid above it.’ Therefore, there is a loss of pressure in the pipe as the fluid rises.
Conversely, at the bottom of the vertical pipe there is the full weight of fluid in the pipe ‘pushing down’ on that point and due to this, the pressure at that point increases (in comparison to the pressure on the fluid at the top of the pipe). Therefore, there is a gain in pressure in the pipe as the fluid falls. If for example, the riser (pipe) was blanked or there was some mechanism or blockage at lower levels of the riser and when work was being done on the riser, the blockage moved, the blank failed or the pipe itself ruptured the weight of the water/fluids will drop quickly to the bottom creating a vacuum which may potentially suck the divers in. Was this the cause of the incident?
LMCS should have activated emergency response before Coast Guard arrived
Safety Case Regulations require that the client commissions the work with responsibilities that include: ensuring that the site is safe to use; identifying known hazards to the diving contractor and supporting the diving contractor in the event of an emergency. The diving contractor should ensure that the diving project is planned, conducted and managed in a safe way. The diving contractor’s responsibilities include: assessing risks, and ensuring that a diving project plan is prepared.
SCR 2005 & 2015 Regulation 2 defines Diving as a ‘major accident hazard’. SCR2015 Regulation 16 (SCR 2005 Regulation 12) requires that all hazards with the potential to cause a major accident have been identified and all major accident risks have been evaluated and measures are taken to control those risks.
Many companies in T&T and internationally follow The UK Offshore Installations (Safety Case) Regulations 2005 & the Offshore Installations (Offshore Safety Directive) (Safety Case etc.) Regulations 2015. SCR 2005 & 2015 Regulation 2 states that: “The owner is the person who contracts with the licensee/field operator to use the installation for oil and gas-related activities and is in direct operational control of that activity, therefore, it is the duty holder (Paria) that has the duty to manage diving operations from their installation.”
LMCS claim that they were prevented from engaging in the rescue of the divers when the Coast Guard and Paria staff arrived, which seems too late as they (LMCS) should have already activated their emergency response plan and rescued the divers way before the arrival of the Coast Guard.
Stop the blame game, a root cause analysis must be done
The decision to place a hold on further rescue into the pipe may have been a prudent decision since there were many unknowns given a depth of over 60 feet of piping and a diameter of about 30 inches. There was no need to risk further loss of life.
In effect, additional diverse lives may have been saved. Paria has not said what condition made the rescue unsafe. Did the Delta P condition still exist after a few hours? This is very unlikely since by then the differential pressure that cause the suction would have equalised.
LMCS is resorting to a reactive approach to an incident gone wrong when they should have been proactive in preventing this incident by providing effective control measures so that if a Delta P situation occurred, the divers would have been protected by tethering, use of the appropriate surface supply diving gear, grids to protect any pipe opening, Delta P current detection, a detailed risk assessment which would have indicated the possibility of a Delta P environment and a well-placed emergency response plan.
It is remiss of LMCS to take such a position in a time when the country, families and workers are grieving. At this time a root cause analysis must be done to determine the facts of the incident and not to place blame for the incident. All evidence needs to be preserved at this time and forensic analysis of all equipment and diving gear must be done.
Both Paria and LMCS had a responsibility to ensure that a safe system of work was in place regardless of what happened or how it happened.
In addition, OSHA needs to place a moratorium on all diving operations in T&T and a start a review of these companies, their dive plans, risk assessments and method statements with respect to future diving operations.
Who is Carlstien Lutchmedial?
Trinidad-born Lutchmedial is the president of OSHE Consultants Corporation and a certified safety trainer and consultant, specialising in the oil and gas sector. He provides Occupational Safety and Health (OSH) training, auditing and consulting to a variety of organisations in the general industry including private companies, industrial, oil and gas companies and government agencies. He is also qualified in emergency response and led New York City’s remediation project for the September 11, 2001 World Trade Center disaster.