(62a) Main Challenges in the Operational Safety Management of Offshore Oil and Gas Production Platforms in the Design and Commissioning Phase, in the View of the Brazilian Regulator.

Since 2009, ANP (Brazilian National Petroleum and Natural Gas Agency) has consistently carried out audits of offshore oil and gas production platform during the operational phase to verify whether the operators' safety management systems are managing the risks of operations appropriately. These audits are based on the ANP's technical regulation called SGSO (Operational Safety Management System), which is performance-based and risk-oriented. Throughout these operational audits, several serious and critical deviations are identified, sometimes even leading to the shutdown of some platforms by the regulators.

Faced with the identification that several deviations identified in the operational phase of offshore production platforms were related to safety issues that were not adequately managed and resolved in the design and commissioning phase, ANP understood that it should initiate an approach that was capable of previously identifying these weaknesses in management systems in the initial phase of the units’ life cycle. Among the main deviations identified, those related to failures in risk analysis (methodological inconsistencies, lack of implementation of recommendations, lack of systematic risk assessment), undersizing of critical operational safety systems and failure to implement MOCs (management of changes).

Therefore, ANP began carrying out these audits in the design and commissioning phase. Such audits aim to identify and impose conditions for the start of operations, which must be fully met by the operators and submitted for analysis by ANP for subsequent approval. Audits of new units began to take place at shipyards, before the sail away milestone, so that operators would have enough time to implement and meet the conditions imposed by ANP. This type of audit was called “shipyard audit”.

This work aimed to critically analyze the deviations identified in these "shipyard audits", in order to identify the main difficulties in safety management, on the part of operators, that affect the start-up and safety of operations in offshore production units. From a preliminary analysis of 24 "shipyard audit" reports from 2015 to 2023, containing 227 deviations, we arrived at a robust volume of data on safety management at this stage of the units' life cycle.

The main deviations found in “shipyard audits” are then presented, demonstrating in the regulator's view the greatest difficulties and challenges faced by operators in managing operational safety before start-up. The main deviations related to risk analysis, design, commissioning and sizing of critical operational safety systems and management of changes will be detailed.