India
has one of the densest oil and gas installation network in the world, both
upstream and downstream. Managing safety of these installations is no mean
task. As safety is of paramount importance, there is a move within the
government to give more teeth to the Oil Industry Safety Directorate (OISD)
by converting it into a statutory body. OISD’s Executive Director, Hirak
Dutta talks to Neeraj Dhankher on what needs to be done to make
installations safe and reliable. Excerpts:
What is the status of talks over granting statutory status to OISD?
Talks are going on to provide statutory
power to OISD, particularly for the downstream sector, by transferring part
powers of the Petroleum and Explosives Safety Organisation (PESO) related to the
petroleum sector. Currently, we have statutory power in upstream offshore as per
petroleum rules, but we don’t enjoy a similar power in the downstream sector,
although there are a total of 111 safety standards of OISD (of which 11 are
mandatory) which are part of petroleum rules and are to be followed in the
entire hydrocarbon value chain.
OISD is a technical wing of the
ministry and is managed by people deputed from oil companies. We don’t have a
regular cadre of OISD. Our infrastructure is not spread out across the country.
Once we have the statutory power in the downstream sector as enjoyed by PESO, we
need to have adequate infrastructure and manpower. Therefore, the entire aspect
needs to be studied by a consultant to firm up requirements for manpower,
infrastructure and other areas. We have broadly finalized the terms of reference
and by November 2012 we will be able to line up the consultant. Thereafter, the
findings of the study upon submission of consultant’s report have to be
discussed with Petroleum Ministry, DIPP and PESO. The consultant will not look
at the legal aspects.
Once OISD is made a statutory body, what will be its implications on the oil and gas sector?
Even today we have the technical competence
in monitoring safety practices in the petroleum industry. Therefore, since we
make standards, once we have statutory authority, the overall objective of
enhancing safety in oil installations can be achieved.
At the moment, out of 111 OISD
standards, 11 standards are mandatory in nature. These have to be followed by
oil companies in the hydrocarbon sector. Even in case of other standards, there
is a broad acceptance and oil companies do follow them strictly.
To make standards mandatory, we have
to take the approval by the Safety Council which is headed by Secretary,
Ministry of P&NG and its members include heads of private and public companies
and other statutory bodies these are to be included in petroleum rules.
Are OISD standards applicable to private companies as well?
Earlier these standards were not applicable to private companies. But now
both public and private companies come under the gambit of OISD’s safety audit.
For example, we have audited RIL’s Jamnagar refinery complex and HMEL’s refinery
at Bhatinda for precommissioning checks. Similarly we have carried out audits of
private sector companies in oil exploration & production.
We carry out External Safety Audits, Surprise audits and Precommissioning
audits for both private and public sector. The aim of these audits is not to
find faults but to actually bring out some of the weaknesses in the system which
might have escaped the attention of the company and thus improve upon it so as
to fulfill the goal of energy security. So these audits are focused to help the
oil companies. These audits are conducted under a favourable environment where
the oil companies are receptive to our suggestions and whatever observations are
made by us are adhered to.
Once statutory status is granted to OISD, do you think there will be any overlap in functioning with PESO?
I don’t think so. As once petroleum functions of PESO are given to OISD, I don’t think there will be much of a problem. But process of transfer will take some time after detailed deliberations at appropriate levels.
How does OISD reward top performers? Do you also have any mechanism to deter companies from violating safety guidelines?
We have both. We present oil industry
safety awards every year to companies that meet and qualify our safety
performance parameters. All companies submit the data to us. We have a
committee, which examines the various safety parameters in great detail. Based
on that, companies are rewarded, both public and private. We are also
encouraging individuals. For the last two years we are giving awards to
individuals who have made significant contribution for enhancing safety in their
installations.
Similarly, about deterrence, when we
find some installations are violating or not meeting OISD standards, we take up
the issue with respective oil companies. There have been instances where oil
installations have actually been stopped at the site, relocated or taken
appropriate measures immediately to correct the situation.
Does OISD have a role in monitoring safety practices before the actual project execution takes place?
Safety is inbuilt in design. When a new
refinery is coming up, the process licensor in the design incorporates various
safety features. Various safety considerations pertaining to process,
instrumentation, process safety interlocks based on HAZOP and HAZARD study are
incorporated in the design. The mechanical standards following API, ASEM
standards are followed. In case inbuilt safety features in design fail, there is
secondary system like fire fighting which helps in mitigating the unsafe
situation. Therefore, the important part is safety during design stage. Oil
companies in India have a very robust system. Now days, we have a 3D model
review of P&I diagrams by multi-disciplinary group, along with process licensors
and consultants.
Please explain how safety audits are conducted by OISD?
We have three kinds of audits- the External
Safety Audit, Surprise audit and Precommissioning audit. The external audits are
carried out once in three years, while in case of surprise audits, we don’t tell
the installations about the audit. We go randomly to check whether they are
following OISD standards. Precommissioning audits are conducted at the request
of the oil company when its plant is ready for commissioning. The ESA team is
also highly experienced team of 5-6 people. Each year, we have Safety Council
meeting where we discuss the number of audits to be conducted every year.
Along with OISD audits, oil companies
also carry out their respective internal audits to correct deficiencies, if any.
There have been cases when the oil companies have found to have violated OISD’s recommendations. Why is it so?
It is not willfully they do not do it. If
you look at the history of many installations, some have come up two to three
decades back. The technology is constantly being upgraded. Design has changed a
lot over the years. When we go and audit old and aging installations, we make
some recommendations which were not incorporated in design at that point of
time. Therefore those changes have to be incorporated now. It is not that oil
companies do not do it, just that it takes time. Refining, Exploration &
Production operation is highly complex and any technology up-gradation is a time
consuming process.
Do you think that in India we attach the same importance to safety as in developed countries like USA?
I can tell you that safety standards in
India are robust. But one shouldn’t compare India with that of other country as
environment and work culture are different. We take inputs from other
international standards, technological developments taking place and we have
principal panellists from various public and private companies who sit over a
period of time before a safety standard is made. So there is an elaborate
process of formulating a standard. Standards in India are quite good and they
are also followed religiously to the extent possible. There will always be some
gaps in any system, be it in the East or West. There has been lot of improvement
in safety culture in India. Managers are looking at operational integrity, asset
management integrity and hardware and software issues.
Don’t you think that OISD’s decision to make standards 116 and 117 mandatory was a controversial one as oil companies were asked to replace existing fire fighting systems with new ones leading to unnecessary expenditure? Please elaborate.
With technological developments you have to
undertake modifications, put new systems. In today’s era of technological
developments you can’t look back at what has been done earlier. As and when
technology improves we have to bring in new features. That’s what happens
universally. As per me there was no controversy. In some areas there were some
deliberations and debate and we have included their feedback based on
discussions in Safety Council. Sometimes someone creates some noise which is
blown out of proportion. The Safety Council approves the standards only after
building a consensus with oil companies and statutory bodies. We are not saying
that perfectly functioning equipment should be replaced with the one mandated by
the standards. Infact, the oil companies themselves are more sensitive than OISD
as their stakes are very high. Hence whatever technological advancements we
suggest, or otherwise also, the oil companies incorporate changes in their
process. Acquiring state-of-the-art technology is a must for improving
production, profitability and safety. And as per me, there are no differences of
opinion on this. Safety is not expensive, it is priceless.
There are enough suppliers in the
market to procure the equipment recommended by us. Amendments are done from time
to time. This world is a changing world; only thing which is constant is change.
Developments in science and technology move at a rapid pace, and we have to
catch up and incorporate those.
With the MB Lal committee coming out with its own set of safety recommendations for oil and gas industry, how has it impacted OISD’s owns set of guidelines?
The MB Lal Committee was set up in the
aftermath of a fire incident at IOC’s Jaipur POL terminal in October 2009. The
committee had recommended various safety measures. Around 70% of its
recommendations have been implemented so far and the balance is under various
stages of implementation. Based on these recommendations, OISD has also modified
its standards to incorporate some of the measures which were not included
previously.
What, according to you, are the key challenges in the functioning of OISD today?
Managing rapid changes in technology up
gradation, dealing with old and aging assets and thick population growth around
installations are some of the major challenges faced by oil & gas industry.
Upgrading skill is another important issue, along with assimilation of
technology. After all it is the people who manage the technology. Employee
engagement is a must.
(InfralineEnergy thanks Hirak Dutta, Executive Director, Oil Industry Safety
Directorate (OISD) for sharing his valuable insights with our
readers. The column 'In-Conversation', is a platform to engage
experts from various sectors to share their views on the different
transformations happening in the Indian energy sector.)