IOGP R690

This week we are delighted to share an interview with Tony Cramp, Chairman of IOGP’s Aviation Committee and Vice President of Shell Aircraft about the recently issued IOGP Report 690 on Offshore Helicopter Recommended Practices.

Tony, thank you for taking the time to speak with us. Can you describe the role of the IOGP in offshore aviation and how it differs to other stakeholders in this matter, for example regulators such as EASA, FAA, CAA etc?

The role of the IOGP (in particular the Aviation Subcommittee - ASC) is to really set the bar for the industry in terms of aviation safety. It’s a forum for collaboration on safety and the idea is to pull together the collective expertise in the industry to move it forward. That collaboration includes not only the oil and gas companies, but other members such as the aircraft operators through HeliOffshore and HSAC and also other regional aviation bodies that are responsible for aviation exposure in their respective areas.

The mission for the ASC is to eradicate aviation fatalities in the oil and gas industry. Offshore is our area of highest exposure and the one where we have historically had a lot of accidents, albeit it is not considered the ‘riskiest’ area. To achieve that mission, what we have to do is to raise the bar across the industry in terms of safety standards/practices and contract requirements.

How would you describe the current state of play in terms of regulation and guidance for operators vs industry best practice? Is one leading the other and therefore is the IOGP playing catch-up or leading the industry in a new direction?

In most case best practise always leads, as people/companies are innovative in how they want to address their risks. I think the regulations globally provide the baseline for compliance, but the regulatory process is relatively slow, and it doesn’t always focus on areas we as the industry would see as the highest risk. A classic example of that is HUMS. That is a requirement we developed through the IOGP (and in collaboration with the UK CAA & particular operators) and then championed through the IOGP ASC and it has been a baseline requirement in our guidelines for 15-16 years. It is still not a regulatory certified requirement in most countries. HUMS has been championed through the IOGP and there are many other examples, such as Flight Data Monitoring and Safety Management Systems (SMS). The Oil & Gas industry really focused on the requirements for SMS after accidents such as Piper Alpha and we championed that and brought it into the aviation sector.

We do work closely with regulators globally to share knowledge and I’d highlight EASA as particularly proactive. It has been for a number of years, but by nature we can move quicker and, because we have the contractual relationships, we have a direct lever that we can pull to bring in some of these safety initiatives sooner.

How would you summarise the key recommendations of the new standards?

The situation we have at the moment is that the previous guidelines were written back in the ‘noughties’ (the predecessor report ‘590’ was published in April 2007). Since that time everyone has moved on at a different pace. There is now far too much variability and inconsistency in the standards that we contract for as individual customers and that causes complexity and unnecessary cost for the operators themselves. It also means we are not demonstrating an aligned and effective way of reducing the risk, because we are working at different levels.

The intention is to set a new baseline for offshore flying. The changes recognise and reflect the best practise of the good operators as they operate today. There is virtually nothing in 690 that isn’t already in place out there …. What we have done is bring together that best practice and to set the bar at a new level. To highlight five key areas where there are major differences we would identify:

1. Aircraft types – we have set a certification level to take out the older aircraft that we do not believe are designed to be as safe as we need them to be. Key baseline requirements are for multi-engine, two pilot, IFR capable aircraft.

2. For safety management systems we have aligned our guidance more closely with the ICAO requirements, to make it simpler for operators to demonstrate compliance with their national regulators. We have also put more focus on safety leadership and on programmes like LOSA, which are focussing on human performance.

3. In Training, we are looking to support the more competency/ evidence-based focus that the airline industry is introducing, which hasn’t yet found its way to rotorcraft. HeliOffshore is doing some great work here with EASA and, as the regulatory framework develops, we will be able to reflect that progress in 690. We have also increased simulator training frequency to every six months – again reflecting best practice in our own industry and what is established in the airline industry, which contributes to its fantastic safety record over many years.

4. Flight path management – if we look at the accidents and serious incidents that have occurred – this is the most common cause and so an area we want to focus. Further work is ongoing, again with Helioffshore, and I’d expect the guidelines to continue to evolve here. With that, we have also enhanced the requirements for Flight Data Monitoring and other systems, such as HUMS in the airworthiness space.

   Flight path management can also be improved by moving toward the way the airlines work in the use of the systems and the automation within the aircraft. This is reflected in R690 with reference to Flight Crew Operations Manuals (FCOM) – with the intent that all operators of aircraft of the same type will be using the automation in the same way. Previously we have seen the introduction of new and complex helicopters, with each operator developing its own procedures for the use of automation and we have also seen some serious incidents and possible accident causes as a result. We want it to be more like the airlines, where if pilots from different companies jump in a machine of the same type, they would expect to use the automation in the same way and fly to the same limits. R690 moves towards that, but there is more work to be done here and our partner HeliOffshore is leading that push.

5. We also trying to address aircraft equipment upgrades. HTAWS (Helicopter Terrain Awareness and Warning System) is something the industry has been asking for (and has produced the justification for) for many years now. We and partners such as HeliOffshore have been working very closely with the with OEMS to get HTAWS developed and we have just seen certification of the first system on the AW139. We therefore need R690 to reflect the capability of such systems, so that they are contracted for and fitted when available.

This report is being published at time when investment offshore is at the lowest levels for a decade… the industry is not awash with cash and in recent weeks and months we have seen operators fighting it out for new contracts with oil companies that are openly asking them to compete aggressively on price (e.g. ‘reverse auctions’). You’ve spoken before about the inefficiencies through a having a wide range of different standards and the cost associated with that. Do you expect the new guidelines will ultimately increase costs or reduce costs for operators? Is the current commercial standing of the industry a barrier to implementation?

Not necessarily. Most of what is reflected in 690 is already happening out there in the best helicopter operators. One of the problems for them is that they are often providing (and funding) a level of service that is not being contracted for by all customers. They might have best practices in place for some customers, for which others, because they contract to a lower standard, get the benefit without paying for it. 690 will help align what is provided, with what is being contracted for.

There is an acknowledgement that cost pressures are real and will be with us for some time. By raising the bar in 690 and writing it in contractible form, we are hoping that it will be adopted by all offshore customers and that operators will be rewarded and incentivised for their safety investment and performance. It does mean though that we as the customers need to reflect the 690 requirements consistently in our contracts and that tenders reflect the cost of providing those services.

For some, there will inevitably be additional cost, depending on your starting point and what elements of 690 you don’t already have in place. For others that are already much closer to the standard, it should provide a fairer playing field and incentivise investment in safety.

With regard to some recent tendering practices, I am concerned if we are in the position where companies are willing to accept bids that are unsustainable in terms of the safety performance and I think there are some extreme examples of contracting behaviours going on around the world. Fortunately, they are not common at this point, but they do exist, and they are not conducive to promoting long term investment or maintaining safety performance. Unfortunately, it is not new and the Covid pressures will increase that tension in places. Our role in the IOGP ASC is to work together to try and moderate those behaviours and maintain the focus on safety performance.,

The IOGP has more than 80 members and looking at the list it includes NOCs such as Saudi Aramco, Petrobras, Equinor, PTTEP, ADNOC, Petronas, Kuwait Oil Company, Qatar Petroleum, IOCs such as ExxonMobil, Shell, Chevron, BP, Total, ENI, and a good number of smaller companies such as ConocoPhillips, Cairn, Tullow, BHP, INPEX, Kosmos etc. the list goes on but clearly the members represent a substantial proportion of offshore oil and gas activity. To what extent do you expect the new guidelines to be implemented and over what timeline? Where (geographically) do you see the biggest impact for the new guidelines? Is it too much of a generalisation to assume that the US GoM and Asia will see the biggest potential impact?

I think the impact will vary by oil and gas company and by operator. If you are going to focus on the transition from single engine aircraft, then it is probably the GoM where it will have the most impact, as that’s where the majority of the single engine offshore fleet is located. However, for the rest I wouldn’t say there is one geographical region that will feel a particular impact.

For the guidelines as a whole, we are looking for implementation as soon as practicable or at the next contract renewal. We have requested that all the IOGP member companies conduct a ‘gap analysis’ between R690 and their own standards and register the differences. This will enable them to plot out the journey to compliance and also identify difficulties. An example might be where the size of helidecks restricts aircraft type, or a local regulation that might prohibit compliance. But we want visibility of that so we can address compliance in a different way or write the guidelines in a different way. So there is an acknowledgement that there will be differences and that for some it may not be possible to comply with all requirements.

In terms of compliance, it's not just in the aviation space, but across the whole oil and gas industry that the IOGP is looking to achieve better levels of compliance with the industry guidelines. We are a part of Project Safira, which kicked off about four years ago with the aim of eradicating fatalities in five work disciplines, of which aviation was one

Presumably this is not just about having the latest and shiniest machines but also about operating procedures, safety management systems, crew training etc… Have you looked at where investment can be best targeted to deliver the most improvement in safety performance?

The whole document has been built to reflect the collaboration and input of a number of aviation bodies and industry groups, who are collectively working to identify and address offshore flying risk. – The consistent message is that the primary opportunities lie in flight path management, human factors and system reliability. That’s why you’ll see in 690 the direct links made to the HeliOffshore Safety Performance Model, demonstrating that we are linking our requirements directly to address those risks and achieve the related safety benefits.

The bottom line is: what we have produced in R690 is what we believe needs to be in place to deliver our zero fatality goal.

Sincere thanks to Tony for his time and insight.

As a reminder, our latest S-92 fleet census is now available. Providing unit-by-unit detail on current status and location for the offshore crew transfer fleet the report is ideal for stakeholders in the S-92 business and likewise for those that work with competing aircraft. We use state-of-the-art data analytics techniques combined with good old-fashioned primary research to establish who is operating the aircraft, where, and how that has changed. For more detail see here: