DURING a rather boring Saturday in the middle of the Covid 19 lockdown we watched the recent film, "Dark Waters," which concentrates on a 20 year legal battle with US Chemical Giant, Du Point, and the varied chemical exposures to the general public.

There were a number of things through the film that rang true with me in a dualistic sense. You see, I saw first hand, the massive creation of financial companies and the masters of the universe, along with their dramatic downfall in 2008/9 which was described so thoroughly in the film "The Big Short".

For those not aware, the biggest reason for the global financial collapse was that the regulators (who should have been overseeing each of these financial organisations) were too close to the same pockets of the companies they were meant to be regulating. Synergy, is the word I want to use here in regard to the Fife Ethylene Plant, Mossmorran, flaring issues.

Why? basically, I am calling out the same issues that we saw in the global financial crisis and was so expertly displayed in the film "Dark Waters". Some may remember that about 2 years ago I penned a rather long email in where I noted Exxon Mobil was failing its own internal Operational Risk Management system and detailed how that was. Whether it's in Financial, or Oil/Gas, the corporate system tends to follow the same path.

In short: 1: Issues will be identified at a local level and local management will be expected to manage the resolution. This is often referred to as 1LOD or the first line of defence. 2: The Operational Risk teams who manage the GRC (Group, Risk and Compliance) oversee the 1LOD and are the 2LOD. This is often referred to as the second line of defence.

Now, we can safely assume a number of things happened over the last 2 years: A: The local issues did not get addressed quickly (often due to budget management). B: The 2LOD were not strong enough in pushing for timely resolution. C: Operational management failures have pushed Exxon Mobil and Shell into the public (PR) limelight. D: Following some form of audit activity, management decided to replace the Operations Manager and allocate Investment funding to resolve the issues.

The key thing here is that both Exxon Mobil and Shell understand (in corporate speak) that they only really have one stakeholder and that is SEPA! These are the only ones they need to keep happy. If you think that these companies give a thought to the local community then you are sadly mistaken. They will have plans on how they deal with the community, the liaison committees and local action groups such as MAG, but, in reality, they only need to answer to SEPA for their continued licensing permit.

And this is where this whole conversation turns 180 degrees. The pressure should be directed from the liaison committee, action groups and elected officials, towards SEPA as the governmental instrument in providing an 3LOD (3rd line of defence) risk assurance and protectorate, as well as making sure they (SEPA) are doing their job in a timely manner.

And here lies the issue! SEPA has no teeth, has board members with a conflict of interest and seems to be strangling itself around the axle in being able to provide timely public reports about the issues it has found with the Fife Ethylene Plant at Mossmorran.

Until there is a co-ordinated and sustained effort to pursue SEPA to do their job then everyone is wasting their time. If you want to see real change about Mossmorran then you need to canvass your elected officials in why SEPA are dragging their heels here.

Could it be that we are seeing the same complicity as was shown in the film "Dark Waters" and in the same way shown in "The Big Short"???


McKenzie Crescent,


The two managers at the Mossmorran Petro-Chemical Complex, Teresa Waddington of Shell, and Jacob McAlister, of ExxonMobil, have both emphasised that they see the plants having a big responsibility to the neighbouring communities to work hard at being good neighbours. Exxon is currently involved in a major multi-million pound investment in the FEP and it is hoped that the flaring problems of the past will no longer be part of the day to day running of the plant. The work is ongoing and they intend it is geared to having a major impact from now and into future. The Ed.