A Review of the Safety Case Guidelines for Oil and Gas Facilities in Nigeria

This paper reviews the Nigerian Upstream Petroleum Regulatory Commission's Safety Case Guidelines for Oil and Gas Facilities with a view to unearthing its content in the light of risk governance in the petroleum sector.

Source: Alliance Law Firm

The oil and gas industry is not only capital intensive but very delicate and complex. Operations that pose a high risk are carried out in the onshore and offshore sectors. It is associated with innate risks, hazards, incidents and accidents that are capable of eroding safety and environmental protection.

Safety risks lurk across all levels of the industry, including exploration, production projects (petroleum and gas installations), facility operations, maintenance, construction, processing, transport, storage, and during the application of the oil-derived products. Furthermore, the huge volumes of materials that are processed, handled and used make accidents highly likely in the industry.

Public apprehension is further heightened by the numerous experiences of oil spillages, pipeline explosions, and environmental degradation in the Niger Delta Region of Nigeria, where the reverberations of risk-related accidents are humongous. As such, concern is often expressed about the availability of the requisite expertise and technology in the industry and the adequacy of the regulatory regime to manage the oil resources in a safe and environmentally friendly manner. In particular, the continuous accidents in the industry, and pollution of the environment by industry, question the effectiveness of the regulation and regulator in this context.

Although several regulations exist globally that obligate operators to conduct their operations in a safe manner to prevent risk-related accidents, petroleum producing countries continue to experience them. Thus, the goal of the Safety Case Guideline is injury prevention and reduction in the oil and gas industry. Thus, it compels operators to have adequate safety systems in place, rather than prescribe the particular management systems they should adopt.

The safety case was borne out of the conclusion that a prescriptive method of regulation cannot keep up with the risks associated with a fast-changing and high-risk environment. Thus, there was a strong imperative for a flexible system responsive to the fast-changing associated with the petroleum sector.

There are up to 500 oil fields within the Niger Delta Region, with more than 55% located offshore. Therefore, hazards or threats, if not managed, can cause fatalities or serious injury to personnel and the public, damage to property assets, and a negative impact on the environment and community. Because of the volatile nature of the industry and the inherent risks associated with same, the Nigerian Upstream Petroleum Regulatory Commission (NUPRC), as part of its continuous efforts toward maintaining safety, formulated the Safety Case Guideline 2020 to statutorily obligate operators to have in place adequate mitigation and control measures to reduce the occurrence of accidents and hazards as low as reasonably practicable.

The guidelines provide guidance to operators on issues to be addressed in respect of safety cases in different operations in the sector. In addition, it contains the definition, purpose, and content of a safety case; submission and approval procedures; review and approval procedures; revisions; and sanctions. However, this paper reviews the NUPRC Safety Case Guidelines for Oil and Gas Facilities with a view to unearthing its content in the light of risk governance in the petroleum sector.

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