This document discusses how new offshore safety regulations are increasing the focus on controlling human error and assuring worker competence. It introduces Lloyd's Register and their human factors consulting services, which can help organizations meet these new demands through approaches like human factors integration in asset design, safety critical task analysis, and measuring organizational integrity. Organizational integrity provides a framework to improve how human factors are managed in offshore operations through data-based assessments of tasks, competence, and safety management systems.

1. Lloyd’s Register: Human Engineering Limited
Meeting the obligations of the new
offshore safety regulations with
your people
W Ian Hamilton & Michael Suerth
IMAREST
Houston
4th May 2011

2. Lloyd’s Register: Human Engineering Limited
Overview
•
Introducing Lloyd’s Register
•
The importance of skilled behaviour in offshore
operations
•
Stricter regulatory control
•
Improved asset design
•
Meeting the demand for control of human error
•
Meeting the demand for competence assurance
•
A framework for organisational integrity

3. Lloyd’s Register: Human Engineering Limited
Introduction to Lloyd’s
Register
•
Global provider of advisory, technical
& assurance solutions
•
Enhance clients’ quality, safety,
environmental & business
performance
•
Origins dating back to 1760
•
Employs approx 8000 staff, drawn
from over 90 nationalities
•
240 offices
•
80 countries

4. Lloyd’s Register: Human Engineering Limited
Introduction
• Human Engineering is the human factors and
ergonomics consultancy of Lloyd’s Register.
• Our customers operate complex asset
intensive, systems.
• We provide services in:
• Physical ergonomics,
• Cognitive ergonomics,
• Sociotechnical systems analysis.
• Includes design and safety assurance

5. Lloyd’s Register: Human Engineering Limited
Assets are sociotechnical systems
The interactions between:
The Sociotechnical Approach
A system comprises property, processes and people, and the
interactions between these three components.
• People and people,
• People and property, and
• People and processes
Property
Technology
Equipment
Processes
Procedures
Risk assessment
Communications
Are crucial to the success of the asset.
People
Roles &
responsibilities
Leadership
Competence
Culture

6. Lloyd’s Register: Human Engineering Limited
Weak Organisational Integrity multiplies risk
•
Between 70% and 90% of failures are attributable to human and organisational failure
Human & Organisational
failures
Human &
Organisational
failures
Technical
Technical
failures
failures

7. Lloyd’s Register: Human Engineering Limited
Fragile
Optimising
Deviation
Failure
The ND Space
Real Men Don’t Use Procedures!
Normalisation

8. Lloyd’s Register: Human Engineering Limited
Organisational drift - consequences
•
Technical standards and procedures are missing or
inappropriate
•
Competence and understanding are insufficient
•
Commitment to technical integrity is lost
•
Safety management processes degrade
•
Supervisory decision making is weak
•
Inability to detect and respond to potential failures

9. Lloyd’s Register: Human Engineering Limited
REGULATORY CONTROL

10. Lloyd’s Register: Human Engineering Limited
DOI 30 day review recommendations
II.B. Recommendation 4 &
III.A. Recommendation 1
•
Increased emphasis on training and
competence
III.B. Recommendation 2
•
Enhanced requirements for
organisational and safety
management
III.C. Recommendation 3
•
Increased focus on personal
accountability and the control of
human error

11. Lloyd’s Register: Human Engineering Limited
Pull through to legislation
•
Performance based safety case
regime
•
Safety and environmental
responsibility placed with the
lessee
Ensure that all personnel involved
in well operations are properly
trained and capable of
performing their tasks under both
normal drilling and emergency well
control operations.
IADC’s Health and safety and Environmental
case guidelines... will help operators and drilling
contractors demonstrate their ability to operate
safely and handle the risks associated with
drilling on the OCS.
DOI safety measures report, 27 May 2010
30 CR 250 and NTL 2010-N05

12. Lloyd’s Register: Human Engineering Limited
Implications for people and organisations
•
Organisation: There should be clearly
defined roles and
responsibilities, particularly for decisionmaking and major accident hazard safety
management.
•
Competence: People should be
comprehensively trained and capable.
•
Processes: Procedures should be fit for
purpose and practical.
•
Usability: Facilities, technology and
equipment should be fit for purpose and
usable.
•
Error: The risk of human error should be
controlled.

13. Lloyd’s Register: Human Engineering Limited
Safety & Environmental Management
Systems
•
Compliance deadline for mandatory
BOEMRE regulation,
15 November 2011
•
Focus attention on the influences that human
error and poor organization have on
accidents
worker safety and pollution control
are largely dependent on proper
human behavior
API RP 75 (1998)
•
API RP 75 (1998)
•
13 elements: to enhance the safety and
cleanliness of operations by reducing the
frequency and severity of accidents

14. Lloyd’s Register: Human Engineering Limited
SEMS 13 elements
General Management Program Principles
Safety and Environmental Information
Hazards Analysis
Management of Change
Operating Procedures
Safe Work Practices
Training
Quality Assurance/Mechanical Integrity
Pre-Startup Review
Emergency Response and Control
Incident Investigation
SEMS Element Audit
Documentation and Recordkeeping

15. Lloyd’s Register: Human Engineering Limited
Applicable Phases
SEMS applies to all OCS oil and gas operations on new and existing
facilities under BOEMRE jurisdiction including
• Design
•
Construction
•
Start-up
•
Operation
•
Inspection
•
Maintenance

16. Lloyd’s Register: Human Engineering Limited
Job Safety Analysis

Prepare JSA for all OCS activities identified in your
SEMS
Step 1
Site Procedure
Screening

Must include:
NO – consider next site
procedure
Submit procedure to Procedure
Screening Matrix. Is procedure
considered safety critical?
YES – proceed to
Step 2
•
Job steps
•
Existing or potential hazards
•
Step 2
Safety Critical
Task Identification
Are these
consequences
safety critical? i.e.
Could they
contribute to a
MAH
Identify the
consequences of
failure at a sub
task level.
Task step / task
description.
Mitigation
Generate task
analysis from
procedure /
observation.
Potential
consequences of task
failure
YES – proceed to
Step 3
Step 3
Human Failure
Analysis
NO – consider next step
in the task analysis
Identify the human
failures which
would cause this
(from Table 2)
Identify the
likelihood of a
failure of this sub
task occurring
(from Table 3)
Identify the
performance
influencing factors
that could
contribute
(from Table 4)
Possible human
failures.
Likelihood of failure
occurring.
Performance
influencing factors.
Identify any
current
processes /
mechanisms
which reduce risk
of failure or enable
recovery.
Existing Risk
Management
Measures
Potential to recover
from failure before
consequences occur.
Identify any future
measures to
reduce risk of
failure or improve
recovery.
Additional Risk
Management
Measures
Additional measures
to improve recovery

17. Lloyd’s Register: Human Engineering Limited
Audit requirements
•
2 years after initial implementation
•
Then every 3 years
•
Comprehensive audit of 13 elements
•
Designated and Qualified Personnel (DEP)
•
30 day audit plan, API RP 75 section 12.1 thru 12.4
•
Deficiencies addressed in Corrective Action Plan (CAP)
•
Non-compliance can result in sanctions up to and including
disqualification as an OCS operator

18. Lloyd’s Register: Human Engineering Limited
ASSET DESIGN

19. Lloyd’s Register: Human Engineering Limited
Objectives for Human Factors Integration
To define a feasible role for people
• HFI helps to specify the role for people, the manpower requirements, job design and training
plans.
To specify usable interfaces and equipment
• HFI helps to define requirements for the usability of workspaces, equipment and control system
interfaces and to support their verification during construction leading to lean commissioning and
sustainable performance.
To ensure the reliability of human performance
• HFI helps to assess the human error potential within the system, its processes and
procedures, and to identify workplace hazards for personnel; and so to meet the human factors
requirements for regulatory compliance as well as providing operational assurance.

20. Lloyd’s Register: Human Engineering Limited
HFI goals for project phases
System lifecycle or maturity stages
HFI goals
All phases
Primary goal for HFI: The optimisation of skilled
behaviour.
Concept definition
Main goal 1: To define a feasible role for people.
Feasibility engineering
Preliminary engineering
Detailed engineering
Manufacture/fabrication
Commissioning
Operation
Main goal 2: To specify usable interfaces to workspaces,
equipment and technology.
Main goal 3: To assure the reliability of human
performance.

21. Lloyd’s Register: Human Engineering Limited
HFI Objectives for project phases
Key questions:
•
Is the role of people in the system feasible?
•
Are the human-machine interfaces usable?
•
Will the required level of human performance be sustainable?
•
Will the organisation support the business objectives for the system?
Concept/feasibility
Prelim/detailed design
Manuf./Commission
Operation

22. Lloyd’s Register: Human Engineering Limited
HFI questions related to main goals
HFI goals
Key questions
To define a feasible role for people.
Is there a concept of operations for the role to be performed by
people?
Has the target workforce been defined?
How many people are needed?
What will be their jobs?
What are the knowledge and skill requirements?
Is there a training plan?
How will competence be assured?
Stopping rule: The human role is shown to be practicable
To specify usable interfaces to workspaces,
equipment and technology.
Are reference anthropometric data available?
What are the requirements for facilities and workspaces?
Are the requirements for physical interfaces defined?
Is the user population defined?
Are the requirements for HCI defined?
Is there a plan for testing and acceptance by users?
Stopping rule: The facilities and interfaces are fit for purpose.
To assure the reliability of human performance.
Have occupational hazards been identified?
Is there a risk control plan for hazards?
Have all safety critical tasks been identified?
Have the opportunities for human error in critical tasks been
identified?
Has the risk from human error been controlled?
Have the requirements for a safety culture been defined?
Stopping rule: The risks from human error and health hazards
are ALARP.

23. Lloyd’s Register: Human Engineering Limited
CONTROLLING ERROR

24. Lloyd’s Register: Human Engineering Limited
Control of human error – the wider view
•
DOI Safety measures report...
Management and
leadership
Communications
Procedures
Knowledge and
skills
Fatigue and
workload
Usability of
equipment
... unsafe offshore
drilling operations
often result from
human error
III.C. Recommendation 3.

25. Lloyd’s Register: Human Engineering Limited
Safety Critical Task Review Method
Step 1
Site Procedure
Screening
NO – consider next site
procedure
Submit procedure to Procedure
Screening Matrix. Is procedure
considered safety critical?
YES – proceed to
Step 2
Step 2
Safety Critical
Task Identification
Are these
consequences
safety critical? i.e.
Could they
contribute to a
MAH
Generate task
analysis from
procedure /
observation.
Identify the
consequences of
failure at a sub
task level.
Task step / task
description.
Potential
consequences of task
failure
YES – proceed to
Step 3
Step 3
Human Failure
Analysis
NO – consider next step
in the task analysis
Identify the human
failures which
would cause this
(from Table 2)
Identify the
likelihood of a
failure of this sub
task occurring
(from Table 3)
Identify the
performance
influencing factors
that could
contribute
(from Table 4)
Possible human
failures.
Likelihood of failure
occurring.
Performance
influencing factors.
Identify any
current
processes /
mechanisms
which reduce risk
of failure or enable
recovery.
Existing Risk
Management
Measures
Potential to recover
from failure before
consequences occur.
Identify any future
measures to
reduce risk of
failure or improve
recovery.
Additional Risk
Management
Measures
Additional measures
to improve recovery

26. Lloyd’s Register: Human Engineering Limited
MANAGING COMPETENCE

27. Lloyd’s Register: Human Engineering Limited
Trained isn’t necessarily competent
Job Analysis
Competence must be
measured independently of
training...
Define
Competencies
Competence
Assessment
Ability
Assessment
Knowledge
Assessment
Decompose role in to the
competencies required to be
successful in the role
Identify the most critical competencies
Develop assessment methods that
assess each critical competency
Behavioural
Assessment

28. Lloyd’s Register: Human Engineering Limited
The assessments
Technical Knowledge 1, 2 and 3
Mechanical Comprehension
Following Procedures
Fault Diagnosis
Management Assessment
Assessment Interview
Work Shadowing/ tours of equipment

29. Lloyd’s Register: Human Engineering Limited
Knowledge assessments

30. Lloyd’s Register: Human Engineering Limited
Ability assessment

31. Lloyd’s Register: Human Engineering Limited
Ability assessments = normalisation

32. Lloyd’s Register: Human Engineering Limited
Behaviourally anchored competencies

33. Lloyd’s Register: Human Engineering Limited
ORGANISATIONAL
MANAGEMENT

34. Lloyd’s Register: Human Engineering Limited
Organisational integrity – bringing it all
together
Tasks critical
To the
Strategic aims
Leadership
Of the
Critical
Tasks
Manage the
Commitment,
Enterprise
DecisionMaking, trust
Changes
To systems
And
Change
Management
Leadership
And common
values
processes
Define
Just
Attitude to
Circle
Learning &
Improving
Practicable
Policy &
Procedures
Practices and
Of
Blame and
procedures
Learning
culture
Integrity
2-way
Communic
Build -ations
Workforce
Organisation
Optimise
Effective
Manpower
2-way
And
Communic-
Responsibilities
ations
Usable
technology &
equipment
COW
Ensure
competence
Provide facilities,
Define
equipment &
training
technology
Needs and
that is fit
Standards of
for purpose
competence
For safety and
performance

35. Lloyd’s Register: Human Engineering Limited
Measuring Organisational Integrity
Organisational Integrity Dimension
Performance
Crtical Task
100%
Management of
Change
80%
60%
40%
Change
Management
20%
Learning &
Improving
0%
Factor Performance
Leadership and
Job Design
Processes and
Procedures
Ensure
Competence
Workload
Management
80%
Equipment
Design
60%
Incident
Investigation
Communications
Critical Task
100%
40%
Process &
Procedure
20%
0%
Fatigue
Leadership
Manpower
Recruitment
Training
Dimension Performance %
Approach %
Implementation %
Outcome %
Review %

36. Lloyd’s Register: Human Engineering Limited
Summary
•
New safety regulations demand an increased focus on:
•
Organisational processes and safety culture
•
The control of human error
•
The assurance of competence for key workers
•
Human factors integration can deliver improved asset design
•
Organisational integrity offers a framework for the improved
management of human factors in offshore operations.
•
It is a data-based assessment process
•
Supports error assessment for safety critical tasks
•
Supports competence assessment for key roles
•
Improves organisational safety management

37. For more information, please contact:
W Ian Hamilton & Michael Suerth
Lloyd’s Register Americas
1505 Hwy 6 South Suite 250
Houston
TX 77077
USA
T +1 281 649 2237
E michael.suerth@lr.org or ian.hamilton@lr.org
w www.humaneng.co.uk
Services are provided by members of the Lloyd's Register Group.
For further information visit www.lr.org/entities