PIPELINE EHS AWARENESS

So with all the pipelines being laid across the world in response to the new found energy savior, natural gas, what is the do's and don't in safety?

The best approach to this topic is my favorite response to any EHS topic and that is to utilize a risk-based Health and Safety Management approach that is systematic and focuses on the realities of that location's particular situation.

Senior level managers of Oil & Gas companies typically have the mindset that falls into two groups; duplication of past documentation, and generating new documents.  This mindset is based upon whether the company finances or obtains financing for the project, and on the location. 

Here is how it typically works.

Oil & Gas companies that finance their own international projects are not financially bound by external standards and guidelines, and typically feel immune from immune from most of these standards.  The established pipeline operators, with extensive experience, most likely have management staff with many years of on-site construction experience in all aspects of pipeline construction.  These companies will have a Construction EHS Operations Manual (perhaps with dust in the back corner of the project manager’s office), which will be referenced within the contract, and so be contractually binding.  All parties, Contractors included, will be obligated to comply with the established construction practices in this manual. Because they have been doing these sorts of projects for several years they have a corporate way of doing it; we’ve always done it this way syndrome.

The EHS MS documentation for those companies that are successful will have been integrated into the process so that it is streamlined, and the work will be executed quickly and safely.  

In instances where a Company has financed an international project, the lenders will have many expectations outlined in an Environmental Impact Assessment (EIA) that will require the development of numerous, predominantly Environmental and Social documents within the EHS MS.  Oil & Gas Companies with experience managing international pipeline construction projects generally have knowledgeable staff and an established Company Construction EHS MS (the same dusty one). 

Companies lacking an experienced construction team, often start a project with a severe handicap; lack of documentation.  Such companies may utilize an existing (plagiarize) company Operations EHS MS to show the lenders (regulators) that they are complying with the intent to control the risks associated with the construction process, not recognizing that operational risks and construction risks are as different as night and day, and must be managed using different methods.  Additionally, a construction and EHS management team with little or no practical knowledge of pipeline construction may be recruited for the project, drawn from the company & offshore exploration or refinery sectors.  

International Oil &Gas companies, that are accustomed to working under International Financial Institution (IFI) standards, with operations originating in those regions, with well established standards, often have a library of  EHS Management documents.  The problem is that the EHS document library of some of these companies is so extensive that without a systematic EMS management system in place much of the paperwork and processes serve no real purpose in identifying hazards, evaluating risks, or preventing accidents.  

Contracted construction management staff that have worked for these Oil & Gas companies on other projects, often wrongly assume that the way they operated in their last project is the way they proceed on all projects.

An EHS library comprised of many volumes of documents does not deliver a safer project; when was the last time you saw a project manager with a EHS document open?

A real EHS Management Systems has to be tailored to the requirements of the project, the safety culture of the national workforce and other variables, and may be different from project to project.   

A lack of a comprehensive knowledge of pipeline construction hazards and risks during the engineering phase, when documents and contracts are drawn up, is the single most frequent cause of the failure of an EHS management system, that can cause a project to be less profitable.  This is when the EHS program is blamed for the reduced profit, and any related issues that may occur.

A mistaken belief is that the EHS manager must be experienced with pipeline construction and possess a detailed knowledge of pipeline construction methods.  This comes usually from consultants, or people who want to sound like the sky is falling.  The truth is that a truly well rounded EHS manager is trained in how to facilitate the development of the EHS management system.  It is the operations people who are the experienced professionals.

Be wary of construction and QA management who may claim on their CVs to be experts in risk management, especially if they proclaim that they can do it all.  This also is not true.  

What is needed is a good corporate EHS manager that understands the systematic approach.  But in order to be a good corporate EHS Manager requires the backing of the corporate office, and cooperation from the operations team.  Otherwise the EHS management plan becomes a document that is drafted in a vacuum that is not based on reality, and is destined to fail.

A good corporate EHS manager that is integrated into the operation will be able to correlate lessons learned during the construction phase to be collated for future projects. This critical knowledge can then develop a EHS management system that is based on reality, and is supported by operations.

There is a perception that Health and Safety management is more difficult to assess than Environmental management because environmental issues for the most part are quantifiable and HS issues are perceived as not quantifiable.  This perception is incorrect.

A properly completed project risk assessment undertaken by a trained EHS professional will identify Physical, biological, social, and archeological baselines.  By the way these types of risk assessments are also called Environmental Impact Analysis (EIA).

Due to a universal lack of knowledge of historic pipeline specific lessons learned and to a fear of assuming liability, best-practice baselines in EHS are limited to compliance with work place regulations and codes of practice of the location, neither of which are aimed to manage risks specifically during pipeline construction.  Once again a good EHS manager will be able to build a program from the knowledge of the professionals, the people who do the job day in and day out.  This is there EHS management program.

Over the last 40 years two factors have a come into play which impact EHS management:

The workforce has aged and now it is not unusual to see septuagenarians as site supervision, welding pipe or operating side booms. During the 60s and 90’s, Construction Managers worked their way up through the trades during which time they learned the work inside out.

As the population has aged, the younger generation, brought up in the age of digital electronic devices, is not interested in this type of work, which includes arduous conditions, long hours, often poor accommodation, and isolation from family and friends.  This lack of interest, as the older generation has retired, has resulted in a loss of the accumulated knowledge of the previous generation and the widespread entry of management-engineers with little or no practical knowledge of the work process.  It is not uncommon to find workers in their 60’s working on international projects, and in some locations, which they have no business. 

So now it is not unusual to find foreign workers taking the positions, which adds another complication to the mix--Communication

Work Phase Risks are known by Pipeline Industry EHS experts. The Pipeline Construction Industry is more than 60 years old.  The equipment and methodology have not changed a great deal over time.  Many lessons have been learned.  Application of these lessons learned through seamless on site supervision will deliver project target EHS goals. If your project team does not have access to a database of these lessons learned, you would be well advised to bring in an external advisor to establish a usable EHS Management System that is duplicable and to provide mentoring for your EHS staff.

Most all countries have highly developed national EHS legislation, including stringent due diligence legislation, which assigns accountability and culpability following accidents.  As a large company, perceived to have deep pockets the application of those regulations can be more sever for you than a similar in-country company.

On all projects, locking the Contractor into written detailed EHS commitments, identified in a contractually binding commitments register, EHS plans, procedures, and other EHS documents, is one effective method of delivering an accident free project.  

Contractually binding documents which identify specific project EHS standards, objectives, expectations, penalties for non-compliance and rewards for exceptional performance, provide the assurance that all EHS hazards and risks will be identified and controlled and the work performed in a manner that will not pollute the environment, nor expose the workers and general public to risks.  

Without penalties for non-compliance, the Contractor management will not follow the established plan as closely as they will with monetary penalties attached to non-compliance.  These financial incentives ensure that your Contractors allocate sufficient resources to ensure their front line supervision, the right of way foreman, embrace the requirements in your EHS plans and procedures.  The success of your EHS management system hinges almost entirely on these foremen, many of whom will be, if not illiterate, be unable to digest a complicated EHS plan.  If the Contractor foremen do not buy into the EHS MS, accidents and losses will occur.  It is critical that during the planning and preparation of documents, to ensure that the Contract foreman is part of that process, so they are owners of the procedure and process.

Additionally, during the engineering phase of the project, early EHS input into the tender offering,  and contractually binding project documents such as the project execution plan, pipeline specifications and other critical project execution documents is essential to ensure that risks will be managed during execution.

Client project management staff, including EHS management, may have limited knowledge of the actual work methodology and less knowledge of the pipeline construction industry historic and reoccurring accidents and their causes.  If management staff does not have the accrued experience and knowledge of lessons learned, and is not familiar with how the work is executed, they will be a non-factor or worse in your management team, and will require external support.  Often this lack of experience in pipeline construction is a consequence of project HR recruitment policies. Industry specific experience takes second place to academic and engineering credentials on recruiting agency internet sites and job application forms, when sourcing EHS management staff for international projects.

There is a belief among EHS consultants and others that the corporate EHS manager must be trained in specifics of the industry.  This is a false belief, due to the fact that the corporate manager is a facilitator, while the operations’ staff are the experts.  No one knows the job, or should know it better than the operations people.  This is why the utilization of the LEAN process along with a risk assessment is critical in the development of the EHS MS.  The team comprised of operations and EHS devises together the EHS MS protocols, which are then formatted into workable documents that are usable by the operations group.  Otherwise if the EHS MS is authored by the EHS professional it may or may not be based on reality, and thus be one of those crazy EHS documents that are scoffed at by most operations’ staff.

EHS cannot be managed on a computer screen from a distance.  It must be managed primarily onsite, at ground level, through the use of those who are actually doing the work.

3rd World Country and International Law

We have discussed several times that international environmental law is not such a complicated matter.  The laws are all pretty much the same, it is the application that is different.  So it is more a matter of your corporate conscious on whether your company will abide by or go around these laws.  Small business has a tough time in navigating through the laws, business or environmental, of any 3rd world country because they simply do not have the horsepower to break through the consultants, in-country agents, and others who talk about helping but only see a easy meal ticket.  The more you do not understand, and admit that truth, the more they take advantage of you. 

Here is a little write up I did on another blog.  Sorry, it is a bit of a civics lesson, but one that is important in refreshing what we already know.



Life is a game, and we all play for keeps in this game.  The Constitution is the guiding document for the that outlines the rules of the game for the people of the country. It is the rulebook of game.  The only job of the government is to administer and enforce that document (rulebook). The government acts as the referee. It is the job of the people (players) to ensure that their government does their job.  When a government fails to do the job they were elected to do then it is the right and obligations of the people to change those who are in paid to be in charge of the rulebook.  In a democracy that involves voting out the government elected officials, which is the same as being fired.  This requires the players to be motivated, and educated in order to have a clear understanding that when the referees are doing their best to enforce the rules or are arbitrarily applying the rules based on personal preferences.

Imagine what would happen if fans found out that the referees at the final game of the World Cup ignored violations of rules by one side, and enforced the rules against the other side.  Most likely the referees would have to be flown out of the stadium to an undisclosed location in fear of reprisals from those fans.  Those people are passionate, motivated, and educated about their game.

Passion is the emotional fire required to motivate (move) people to do something.  Education is what is needed to know the difference between right and wrong, to understand that the rules and whether the referees are being honest.  Remove any one of the points of the triangle and results in whining and complaining, but no change. 

Passion can be removed through the use of many different distractions; outside threats, intoxicants, mass entertainment, to name a few.  In Djibouti there is no mass entertainment, outside threats are not ever mentioned, and the Islamic populace generally frowns upon intoxicants such as alcohol.  So the Djiboutia use khat to calm and control the masses.  Khat is a narcotic that calms the user, and gives a sense of euphoria.  The use of khat by the general population is encouraged by the government, and according to a document secured from the US military, the XXXXXX manages the khat trade.  Khat dulls the passion, dulls the senses to the point that educated people lack the motivation to do anything about the wrongs of a government that they talk about everyday.

Djibouti is a small country of less than 800,000 citizens, with an unemployment rate of over 50%.  There is nill manufacturing, or any real economic drivers other than having a deep sea port, and leasing of land for foreign military bases.  Service industry is the primary driver for the masses.  Education of the people is not a real priority.  Without a strong education program the people did not know the difference between democracy, dictatorship, communism, or any other method of governance.

Little passion, little education, and even less motivation results in a government with no oversight by the people, in a government that can do as it pleases.  Results in a government that arbitrarily administers the procedures and laws of the country.  The referees can rule on the game that meets their own personal needs.

Contracts in the 3rd World

Contracts and Environmental Law may not seem to be related, but as a is a written or spoken agreement, esp. one concerning employment, sales, or tenancy, that is intended to be enforceable by law it is a topic relevant to this discussion.

Contractual agreements that are funded by the International Finance Commission (IFC - World Bank), with the EU or USA, all require Environmental compliance as a prerequisite.  Actually the contracts will require environmental, safety, and health.  The IFC has a complete standard that must be complied.  Sounds daunting.  But it is not.  Just do the right things and you will be in compliance, and still make money doing so.  Not hard, really.  What is hard is dealing with the local contractors in these developing localities.

The level of business sophistication is just a hair above kindergarden.  A contract is not a bidding agreement to many of these businesses.  It is just suggestions, that can be ignore.  The bad part is that these businesses will ignore whole provisions of the contract, and yet expect to be paid as if they complied with the contract in full detail.  What to do then?

Normally we think the first step is to work it out with the contractor.  He'll understand that he has obligations under the contract.  It is a simple matter of communication, and working it out.  Yes that is one approach that can take months, which may or may not pay off.  What to do if that fails?  Go to court is the normal next step.

In the 3rd world the country government is formed by the extended family; ie the 'Tribe'.  This means the judges and those in position to make decisions are all related to the contractor in some method or form.  

In other words do not hold your breath that you have more than a 50% chance of winning a contract case that is clearly in your favor.  This extends beyond environmental (HS) into any contractual dispute.  There is a reason the country is labeled "3rd World".  

The rules of law, and in this situation contract law, is what separates a developed country from an undeveloped one.  The same issues face both countries such as bridery, favortism, etc.  The difference is that in a developed country the rules are enforced so that everyone has a semblance of a equal playing field without regard to family.

How does this apply to environmental (H&S)?  It applies because if your contract is funded with IFC $ then you are obligated to comply with their rules, even if you don't know any better.  No slack for people coming from the modern societies.   This is where people get into trouble.  Because these 'family' members will want to side with their family there is the option to buy back their neutrality or vote.  They will typically present the option in a coy and secretive manner that would not implicate them, nor yourself.  Slight of hand, a nod in reference to some discussion about money about some other topic there are all sorts of tactics used.  

A lot of foreign companies simply do not want t deal with the EHS requirements of these contracts.  The sad part is that it isn't that difficult.  Instead of ignoring the issue, why not face up to it directly and working a system to comply.  A system that includes sub-contractors that will or will not comply.

You do have the option of sticking your head in the sand.  Hope you can get in do the job and then get out.  But why?  

Renewable Energy in Under-developed or Developing Countries

Electricity as we all know is the driving force for economic development, there is just no disputing that fact.  That does not make it right or wrong, good or bad, it is what it is.  There are people who say that it is not right to introduce, or push, economic development onto the developing nations.  Perhaps they do not want it, or it will not benefit them.  We can't push our lifestyle on others, etc. is how the story goes.  Although I see that Coke Cola has done an outstanding job of placing itself into every corner of the planet.

What is missing from those arguments is that democracy is part of economic development.  Even in China, as that economy has grown certain elements of democracy has crept into their political system.  My apology, I am deviating from the point.

Many of the developing countries do not have the infrastructure for generating, transmitting, or
distributing electricity.  Whatever they do have is typically rudimentary.  Now this in my opinion is a good thing all around.  Why?  Well we all know that it is easier to write on a clean blackboard (dating myself), and so it is in establishing a power infrastructure when it is being built from scratch.  Also, the pricing of electricity in these places is very high compared with the developed world.  This scenario has been identified by other much smarter people than myself, so it is not a new concept.

So what is the connection between a weak infrastructure, high energy prices, and the environment?  Ah, now that is the puzzle to be solved, because this triangle makes for the perfect market driven environment for the development of a renewable energy based economy.  No need for the government welfare feed-in tariffs that artificially create a market for renewable energy, but can not be sustained in economies such as the ones I am talking about.  In these economies the market makes for the perfect incubator.



So I say---

However, it is constrained by a limited pipeline of bankable projects, leading experts to complain about “too much money chasing too few bankable projects” and a lack of resources to prepare projects and develop a robust project pipeline.  Increased efforts are therefore taking place to mobilize human and financial resources and partner with countries experienced at private‐public partnerships (PPPs) to create facilities that either offer extensive and specialized technical assistance or combine such help with financial resources.

  Quality and reliability of infrastructure services is another challenge in developing countries. Power outages and water suspensions still frequently occur, hampering productive and efficient economic and social activities. Frequent interruptions in infrastructure services are significant constraints on businesses in developing countries.

Infrastructure services often are public goods or natural monopolies, or both. As such they are either run or are regulated by public entities and thus suffer from common inefficiencies of public services.

In response to the clear infrastructure deficiencies of most developing countries, and a broad consensus in the literature that infrastructure is important for growth, a number of authors have attempted to provide estimates of infrastructure “needs”. A useful starting point of course is to determine the level of demand. Demand for infrastructure increases with income. For instance we know from empirical studies that electricity use, telephone use and automobiles increase with disposable income. Countries also tend to increase their investments in environmental amenities as they become wealthier.

First establishing the level and type of demand that is welfare-improving and, second, in order to find out whether a project is worth undertaking, relying on a mechanism that tests whether the benefits of a project or service exceed its costs. For most types of infrastructure, cost- covering prices provide such a test. Relying fully on user fees to fund infrastructure services makes sense for all sectors. Cost-covering prices provide the strongest protection against wasteful investments. Relying on prices to reveal demand implies that policymakers instruct potential providers to proceed on the assumption that they will not receive any fiscal transfers or subsidies and that regulation will allow them to set prices at cost-covering levels in the aggregate. 

Providers, whether publicly or privately- owned, will then estimate demand and calibrate it against costs just as any private investors in a normal market would do. The infrastructure provider will then invest and provide the service. He/she can only make money if customers are actually willing to pay the required price. Thus it is assured that investments are welfare improving. Financing happens as in any other market and is again fundamentally the same for private or public enterprises. Firms seek to obtain bank or capital market financing based on the cash flow expected from cost-covering prices. Risks for creditors are limited by the equity of the provider. Proceeding in this way also means that policymakers themselves need not take a view on “need” or demand. They can delegate this to the service provider. 

Without adequate cash flow investment is not possible, and no amount of financial engineering or PPP structuring can change this basic fact. Once prices are allowed to cover costs, the financial constraints on infrastructure investment become significantly less binding. Focus can then move to the optimal market structure, which is what we turn to next.

Maintain the stability and enforceability of laws and contracts. A clear and enforceable legal framework is also among the top priorities for investors. They want the “rules of the game” to remain credible and enforceable—not altered at the government’s convenience once they have made investment decisions based on those rules. A government’s willingness and ability to honor its commitments are key.

• Improve responsiveness to the needs of investors. Investors identified government unresponsiveness to their needs and time frames as the most important factor in the failure of investments. And they considered the administrative efficiency of a host government one of the top factors in their decisions to invest in a country. Completing better preparation of trans- actions before inviting investors to participate can help reduce processing delays and the related opportunity costs for investors. 

Minimize government interference. Investors are most satisfied with investment experiences when they are free to realize returns from their investments with- out government interference. Where investment experiences were successful, investors pointed to their ability to exercise effective operational and management control of their investments as a key factor. And when investors consider investing in a country, they give much weight to the independence of regulatory processes from government interference. 

Economies also depend on electricity supplies that are free from interruptions and shortages
so that businesses and factories can work unimpeded.  

Africa faces a huge energy deficit: the 48 countries of sub-Saharan Africa, with a combined population
of 800 million, are estimated to generate roughly the same power output as Spain, a country of 45 million.  This energy deficit is the result of the region’s limited generation capacity—the result, in turn, of a lack of long-term planning on the part of each of those countries.  The lack of large-scale investment is a consequence of the limited participation of private players and the difficulties in mobilizing long-term financing from African financial systems to fund big-ticket items such as infrastructure, in places that historically have not followed a strict financial regime that encourages long term investment.  

The monthly, daily, or hourly change in government, or policy, along with little internal investment makes for high risk for low returns on investment.

In addition, aging infrastructure and rising demand have led to intermittent blackouts across all regions of Africa, undermining competitiveness. The blackouts largely started in the 1990s in East and West Africa, in 2007, once again due to lack of planning or any formalized plan that was strictly followed. 

Energy facilities across Africa are in urgent need of new and innovative sources of investment, particularly for generation, transmission lines, and distribution. This much-needed investment
is held back because across Africa—especially sub- Saharan Africa—even though tariffs are very high, they do not reflect actual cost because they account for only about 50 percent of the historical production costs.  The thought process within most of these areas is that they deserve to have the lowest priced electricity on the planet, and the developed countries are obligated to provide it.

Even beyond the much-needed physical investment, there is an urgent need to invest in the diversification of the energy mix so as to make the infrastructure sustainable. In East and Southern Africa, over-reliance on hydropower energy makes the economies vulnerable to hydrological conditions. The major drought in the mid-2000s caused substantial economic losses—as high as 4 percent of GDP in Tanzania—and increased the demand for expensive emergency diesel power generation. In Northern and Western African countries, the energy mix depends largely on gas and oil reserves (thermal energy), which is more reliable than hydropower but more costly.  

In Djibouti a country with no conventional resources that has placed its short/mid-term economic and political life on the back of Ethiopian hydropower have suffered considerable set backs with the up and down availability of electricity.  The price of electricity has not dropped since the power started coming from a 200km interconnection line as no more than 35MW is available at anyone time.  The Djiboutian negotiators were out maneuvered by their Ethiopian big brothers as the metering cost is at the point of generation so that the 20% plus line loses are absorbed by the people of Djibouti.  This keeps the cost of electricity at above $400/MW, with continued brown and black outs.  The Ethiopian government is also able to keep their little brothers in line by a flip of a switch, which is not uncommon.

All these situations come back to the same point of lack of planning, and serious focus on long term economic development on the part of each of the countries' private and public leadership.

Hazardous Chemicals Transferred from Developed Nation to Third World Locals

Washing hands with Trichloroethylene

I start off this month's blog with this image as it symbolizes a major international issue that is spoken about infrequently yet should be one of the main topics of discussion in all international commercial discussions.

An example of this issue is a local 'recycling facility', aka junkyard, that has provided the French military with an exclusive location to dispose of all of it unwanted material (trash).  This material includes jeeps, generators, furniture, ammunition boxes (empty), ammunition clips, washers, refrigerators, trucks, tires, barrels, and drums.

There does not seem to be any controls placed on the 'waste' material that is given (or sold) to this local recycler.  I was told this man has been in business for over 30 years and been exclusive with the French military for all of that time.
As you see in the above photograph of drums of 'acid' it does not appear that the containers have been properly drained and cleaned prior to be 'transferred'.  There were a number of drums that were full, of what I don't know, but I would not be interested in doing any taste test.

I watched a laborer who was painting a drum wash his hands using Trichloroethyene (TCE).  I tried to explain to him that this was not a good idea, but I was not able to properly communicate this to him=French does not translate well to English or versa.  Which is just as difficult when we are speaking with people in our own country.  

TCE has been used for years as a solvent by both private and government industrial sectors that includes the military.  It has been used as an anesthetic, in food processing, dry cleaning solvent, industrial cleaner, and in refrigerant manufacturing.

When talking with long time TCE users, who usually look like long time TCE users, it was always difficult to explain to them the hazards associated with the improper use and disposal of this solvent.  It is not uncommon to hear statements such as; "I've been using this stuff for years and nothing has happened to me", "It is great, so what do you have that will replace it", "You environmental people are all nancy boys", etc.  

So trying to speak with someone in a third world country is that much more difficult as they have the same opinion.  This is a parts cleaner product that comes from France so it has to be good, never mind being safe or not.  The man actually did say to me "no problem, good".  

Something as simple as a parts cleaner that is dangerous at best when used properly, is associated (according to the CDC) with depressed brain function, kidney/liver toxicity, associated with the development of Parkinson's Disease, reproductive toxin, and of course cancer whose impacts are magnified when used improperly; i.e. hand washing.

The improper use of hazardous chemicals is a norm in third world countries where a combination of a high illiteracy rate, and general understanding of health is common.  If someone can't read a label how can they understand the dangers or how to protect themselves?  If that same person has no basic health science back ground how can they understand the risks?  Answer to both questions is they can't.  


This is not an isolated incident.  As I have seen large US firms supporting the same type of activity, especially when operating in these third world countries.  One temporary energy firm I worked for had a plant in Ecuador.  The diesel engine mechanics had a local deaf/mute janitor wash parts using gasoline.  When I told them to immediately stop they complained to 'senior' management that I was impacting the operation.  They had used gasoline for parts washing for years, and there is no other alternative.  Of course I identified an alternative within a few days, that was cost effective and safe.  Old ways of doing things are always hard to change.

According to UNESCO the majority of illiterate people in the world are located in the sub-sahara, arabic countries, and south Asia.  The sub-sahara of Africa is where hazardous waste/chemicals has been disposed of or stored legally (as in the case of the French military mentioned about) and illegally.  

The Basel Convention agreement was designed to stop the illegal transboundary movement of these substances.  In the case of the US military it has caused an increase in the price that is paid to dispose of hazardous wastes.  This increased price can put pressure on other country governments to identify other means of disposal as was identified at this one location, either intentional or inadvertent.