Case Study in Successful Risk Management – The Oil and Gas Industry in Norway Some critical reflections Terje Aven University of Stavanger, Norway Regulatory development – a thorny path or a freeway What regulative approach should we choose? Command and control Self regulation The regulations give general requirements related to • Risk assessments • Risk acceptance criteria • Risk reduction processes o ALARP: Risk shall be reduced to a level that is As Low As Reasonably Practicable Challenge Industry risk perspective is rather narrow and compliance oriented The regulator has a broader perspective ”Optimal decision” Risk analysis Cost-benefit analyses Risk acceptance criteria Tolerability limits Science Management Decision Ethics, politics ”The formula ” risk analysis Risk description • ------ P =1 x 10-4 What is acceptable risk This approach should be used with care ! Risk acceptance criteria • ---------------- P < 0.1% • ---------------- P < 0.01% Balance Development and protection Take risk Weight given to E E[NPV], cost-benefit analyses Reduce the risks and uncertainties Cautionary-precautionary Risk acceptance criteria E: Expected value • RISK is more than computed probabilities Challenge Industry risk perspective is rather narrow and compliance oriented The regulator has a broader perspective Risk perspective Probability-based Historical data Industry practice + Knowledge dimension + Surprises Kahneman asserts that we have a basic lack of ability to treat small risks: we either ignore them completely or give them too much weight. The main thesis put forward is that we grossly over-estimate small risks. Kahneman’s book «Thinking fast and slow» For Kahneman the risk was acceptable I knew that the risk was truly negligible, and that any effect at all on my actions would assign an inordinately high “decision weight” to a minuscule probability. In fact, I was more likely to be injured in a driving accident than by stopping near a bus. But my avoidance of buses was not motivated by a rational concern for survival. Risk perspective + + Petroleum Safety Authority Norway Main problems with the probability based approach John offers you a game: throwing a die • ”1,2,3,4,5”: • ”6”: 6 -24 What is your risk? (C,P): • 6 5/6 • -24 1/6 Is based on an important assumption – the die is fair “Background knowledge” Assumption 1: … Assumption 2: … Assumption 3: … Assumption 4: … … Assumption 50: The platform jacket structure will withstand a ship collision energy of 14 MJ Assumption 51: There will be no hot work on the platform Assumption 52: The work permit system is adhered to Assumption 53: The reliability of the blowdown system is p Assumption 54: There will be N crane lifts per year … Assumption 100: … … Model: A very crude gas dispersion model is applied Risk perspective + + Black Swan A surprising, extreme event relative to the present knowledge/beliefs Aven (2013) On the meaning of a black swan in a risk context. Safety Science, 57, 44-51 Black swans a) Unknown unknowns b) Unknown knowns c) Known but not believed to occur because of low judged probability Extreme consequences Aven (2014) Risk, surprises and black swans Routledge Challenge Industry risk perspective is rather narrow and compliance oriented The regulator has a broader perspective Implications for the implementation of the ALARP principle ALARP • Risk shall be reduced to a level that is As Low As Reasonably Practicable (ALARP) Costs Benefits The burden of proof is reversed. A risk reducing measure should be implemented provided it cannot be demonstrated that the costs are grossly disproportionate relative to the gains obtained Balance Development and protection Take risk Weight given to E E[NPV], cost-benefit analyses Reduce the risks and uncertainties ALARP Cautionary-precautionary Risk acceptance criteria E: Expected value Regulatory development – a thorny path or a freeway What regulative approach should we choose? Command and control Self regulation Challenge Industry risk perspective is rather narrow and compliance oriented The regulator has a broader perspective Project Norwegian Oil and Gas Association: Preventing Major Accidents Transfer of experience, building knowledge and expertise A new perspective on how to understand, assess and manage risk and the unforeseen 35 • Extra Hansson and Aven (2014) Risk description Q (A,C,U) (C,U) K C’ Q: Measure of uncertainty (e.g. P) K: Background knowledge C’: Specific consequences Probability Consequence, impact Poor background knowledge Medium strong background knowledge Strong background knowledge Cautionary principle Faced with risks and uncertainties caution shall be a ruling principle Not execute an activity Robustness Defence in depth Redundancy ALARP Precaution … Precautionary principle If there is scientific uncertainty related to the consequences … All agree Acceptable risk Risk analysis Risk picture Unacceptable risk A surprise for some Unknown knowns Not a surprise for others The Deepwater Horizon accident Erroneous assessments of pressure test results Failure to identify formation fluid penetrating the well despite log data showing that this was happening The diverter system was unable to divert gas The cutting valve (blind shear ram – BSR) in the BOP failed to seal the well http://www.ptil.no/nyheter/deepwater-horizon-ulykken-vurderingerog-anbefalinger-for-norsk-petroleumsvirksomhet-article788924.html Disasters • We experience combinations of conditions and events which collectively result in a major accident A B C D • We do not normally identify such combinations of conditions and events in risk assessments – and, if we did, they would typically be disregarded because of negligible probability 45 How to confront the black swans Knowledge Risk assessments Modified procedure for using RAC • If risk is found acceptable according to probability with large margins, the risk is judged as acceptable unless the strength of knowledge is weak (in this case the probability-based approach should not be given much weight). • If risk is found acceptable according to probability, and the strength of knowledge is strong, the risk is judged as acceptable. • If risk is found acceptable according to probability with moderate or small margins, and the strength of knowledge is not strong, the risk is judged as unacceptable and measures are required to reduce risk. • If risk is found unacceptable according to probability, the risk is judged as unacceptable and measures are required to reduce risk.