Abstract
The 2011 Penglai (PL) 19-3 oil spills in China’s Bohai Sea, resulting from two subsea accidents within a month and contaminating 6200 km2, represent the nation’s worst offshore pollution disaster. Yet, systemic analysis of lessons learned remains notably limited. The April 2021 blowout and fire at the same field, resulting in three fatalities, highlights the continuing relevance of the PL 19-3 case and the need to re-examine the 2011 accidents in depth. This study therefore focuses on the 2011 case as a systematically investigated instance to identify control failures that may explain recurring major risks at the field. This study develops a Systems-Theoretic Accident Model and Processes (STAMP)-based approach to systematically deconstruct the PL 19-3 accidents and benchmark their root causes against those of the 2010 Deepwater Horizon (DWH) disaster. Blowouts and well control incidents in the Norwegian sector are also mentioned to illustrate the well control hazard. The analysis identifies systemic control failures at the regulatory, organizational, and operational levels, revealing that the majority of human and organizational root causes identified are common to both accidents. Based on these findings, an integrated reform framework is proposed, comprising co-regulation models adapted from Norwegian practices, a national major hazard risk indicator system, and mandatory barrier management. This study contributes a theoretically grounded accident analysis and provides empirically informed policy recommendations for controlling major hazard risks in offshore petroleum activities.