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There are also issues related to people’s lack of knowledge of the risks and hazards from product release. Some people within the host communities are not aware that petroleum products have flash points – defined as the lowest temperature at which a liquid (usually a petroleum product) will form a vapour in the air near its surface that will “flash,” or briefly ignite, on exposure to an open flame. As a result, they engage in risky activities such as scooping petroleum products from failed pipelines or even coming out to look as products leaks out.

“Our people don’t know the danger of this fuel. They think fuel is just like the water they fetch from the river or their wells. They hear of fuel, fuel, fuel, fuel, so when a leak occurred, they logically went to

take a look at it.” (Community leader, 18/06/2014).

This lack of risk knowledge also makes people to encroach into pipeline ROW with buildings and other construction and farming activities. There is, therefore, a need for effective risk communication at community level.

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4.6 Framework for pipeline risk management in Nigeria

Notably, the primary issues regarding the poor safety performance of the pipelines and the problems of interdiction are socio-economic and political in nature. Therefore, a top priority in the proposed risk management framework is the engagement of communities along the ROW of the pipeline. The aim of the framework is to integrate activities that will improve legislation, enhance pipeline inspection and vigilance and engage communities in formulating risk management recommendations and deploying actions. Figure 4-19 illustrates the key actors within the framework and the lines of communication via which regulation and operation of the pipelines can be enhanced. The figure also shows the line-up of risk mitigation activities required, starting from the need for a detailed ESIA, public awareness and risk communication, strategies for surveillance, involvement of local response agencies and some pipeline technologies that can be used for optimising the integrity profile of the pipelines.

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125 4.6.1 Ensuring pipeline regulatory effectiveness

The review of regulatory framework in Chapter 2 revealed the mandatory responsibility vested on the Nigerian government for protecting it citizens and the environment from all petroleum activities including pipeline operations. This in addition to the legislative power given to DPR and NOSDRA should form the backbone of their regulatory operations. However, empirical evidence revealed that key limiting factors responsible for their inability to attain this mandate is the current misalignment of the national oil company (NNPC-PPMC) as an integral part of the Federal Ministry of Petroleum Resources with DPR (the regulator). Although this has been acknowledged as a problematic structure, this arrangement can in fact offer some advantage as both organisations receive directives from the Minister of Petroleum Resources. Consequently, with this structure, best practice safety, risk and environmental management directives can be easily cascaded to the operator as shown in the figure 4-20 below. Similarly, PPMC can easily communicate operational concern to DPR under the watchful guidance of the Minister.

Figure 4-20. Structure of communicating and ensuring safety risk and environmental management directives

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The only constrain to achieving this is the lack of commitment and willingness to change mainly due to excessive national vested interest in the petroleum industry. Therefore, the parties involved need to consider the negative safety and environmental impact of the current system, change their commitment levels and build appropriate systems that will clearly define risk management responsibilities and accountabilities in both technical and administrative strata of the pipeline integrity and safety management systems. This can only happen with political will at the highest levels of government.

Notably, there are still issues regarding poor funding and the effectiveness of national regulatory coverage which DPR can enhance by collaborating with state and local government authorities. By doing so, the authorities can also be involved in regulating third party activities such as construction and farming along the pipeline right of way. Logistical resources for this operation can be provided by the PPMC in a collaborative manner and under the supervision of DPR. This arrangement will allow DPR to focus on regulating more technical aspect of the pipeline such as the requirements for in-line inspection and monitoring of corrosion defects. Ultimately, this will perhaps solve the issues related to resource availability.

From a reactionary perspective, incident response by NEMA can be enhanced by decentralising the current practise where NEMA (mostly visible a federal level) are overburden with the responsibilities of responding to incidents which mostly happen in remote rural areas. Thankfully, the NEMA legislation allows for the creation of State (SEMAs) and Local (LEMAs) emergency management agencies (Ambituuni et al., 2014). However, interview findings reveals that while there are available resources from the National Ecological Fund (NEF) (as part of the requirement from the NEMA Act) aimed at improving the capabilities at state and local levels, there is little awareness regarding the existence of such funds or how to access it as indicated in the below citation.

“You know we run a federal structure of government. And we are not an integrated system with the local and state Emergency Management Authorities….it took the Director General (of NEMA) almost a year to

convince the national executive council to talk to them (i.e. the president and all governors and ministers). From the report of the meeting he encouraged them to form SEMAs and told them about the

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existence of the funds. And some of them were surprise that such a thing even exist” (NEMA interviewee 15th_{, June, 2013).}

From this citation, all that is required is the political will by the country’s executive to access such funds and enhance risk management capabilities within pipeline integrity systems. NEMA therefore needs to carry out a complete review of the capabilities of local response agencies especially in known incident hotspots and put in request for funds. This can in fact be included as part of ESIA of the existing pipeline as defined in the 4.6.2 below. Based on the findings from the review, NEMA can collaborate with DRP and PPMC to train state and local agencies on pipeline accident response and emergency evacuation strategies. A line of communication and feedback with the state and local agencies should be defined to ensure sustainable collaboration and capability building. As NOSDRA is responsible for ensuring spill clean-up and adequate compensation to victims, they can also be involved in training state and local responders on how to contain spills and reduce impact areas, whilst also obtaining first-hand information from local authorities about the people affected and their demands for compensation.