Shell UK gas wells in the southern North Sea are serviced by the Wells department in the NAM offices in the Netherlands. A combination of increased drilling activity and post Macondo inspections led to environmental observations that Shell wanted to address. Staff changes had led to loss of expertise and a shift in regulatory expectations was taking place. Cultural differences between the UK and the Netherlands also played a significant role. Regulatory confidence in Shell UK and Shell UK confidence in NAM was compromised. Shell put operations on hold, leading to costly schedule changes.
Failing to address the underlying causes would have resulted in further loss of confidence, production losses, withholding of drilling permits and more frequent inspections. Fines, court cases and ultimately the withdrawal of the licence to operate might have followed.
Initial management training clarified that compliance management was the problem rather than environmental performance. It was also found that the Dutch goal-setting approach didn’t mix with the desire of the UK regulator for evidence of compliance. The EnvAid method for the identification of management strategies resulted in the development of a management plan to address environmental performance, legislative compliance, company procedures as well as any additional stakeholder expectations. The management plan was the basis for further staff training and site inspections.
Subsequent visits of regulatory inspectors only resulted in minor observations. The confidence in Shell UK and in the Dutch Wells team is restored. Dutch contractors operating in UK waters are better prepared and even UK contractors learned.