Contents

• DOI Lifts Drilling Moratorium, October 12, 2010
• DOI Issues Interim Final Rule for Safety Measures, September 30, 2010, effective immediately 
• DOI Issues Final Rule for SEMS, October 16, 2010, effective November 15
• International Regulators' Forum: Meets with BOEMRE and Third International Offshore Safety Conference
• International Association of Drilling Contractors (IADC) HSE Europe Conference & Exhibition, Amsterdam, September 28 - October 30, 2010
• Drilling Safety Legislation Pending

DOI Lifts Driling Moratorium

Tuesday, October 12, 2010, Interior Secretary Ken Salazar lifted the moratorium on deepwater drilling. Experts say it will still take several months for all permits to be issued to re-start drilling and gear up to full production. Meanwhile, the debate continues whether this is the right time to life the drilling ban or just a political, pre-election move.

Read more >>

• DOI Press Release Salazar: Deepwater Drilling May Resume for Operations Who clear Higher Bar for Safety, Environmental Protection, 10/12/2010
• BOEMRE The Fact Sheet: Enhanced Requirements to Resume Deepwater Drilling Activities
• PennEnergy DOI, BOEM lift deepwater drilling moratorium, 10/12/2010
• CNN Obama administration lifts deep-water drilling moratorium, 10/12/2010
• Houston Chronicle Obama lifts deep-water drilling ban, But industry fears rules on safety, permits to slow renewed exploration

DOI Issues Interim Final Rule, Increased Safety Measures for Drilling, Well Completion, and Well Workover 

September 30, 2010, the U.S. Department of the Interior issued its Interim Final Rule for increasing safety of deepwater drilling. It is based on Interior Secretary Ken Salazar's May 2010, Safety Measures Report. Its official title is "30 CFR 250, Increased Safety Measures for Oil and Gas Drilling, Well-Completion, and Well-Workover Operations" (thank you to the IADC for providing this download) and it amends subparts D, E, F, O, and Q of 30 CFR 250.

Intentions of the Rule are to better ensure reliability of well intervention and blowout containment systems; ensure safer practices in casing and cementing; strengthen requirements for blowout protectors (BOPs).

It is effective for ongoing and suspended operations, and:

• It is effective on its date of publication in the Federal Register (we could not find that it was published as of October 16, 2010)
• Comments should be submitted within 60 days of publication in the Federal Register; BOEMRE will review comments and either confirm the rule as final or issue a revised final rule; particularly welcome are comments about potential impacts of the Rule on small entities (small companies defined by NAICS as having fewer than 500 employees)  
• It incorporates by reference are API RP 53 and 65, as well as items from the Notice to Lessees (NTL) No. 2010-N05 effective June 8, 2010, from the MMS

From the Safety Measures Report, the emergency rulemaking recommendations addressed in the Rule are

• secondary control system requirements, and
• deepwater well control procedure requirements.

Not included in the Rule are

• new blind-shear ram redundancy requirements, and
• safety case requirements

These last two items were considered likely to require more time to initiate and the BOEMRE will address those topics in the near future, and they are listed as two of the items for future rulemaking. Yet other items are identified as anticipated for futher expansion in the future, such as new ROV operating capabilities, deepwater well-control procedure guidelines, and tigheter primary cementing practices.

Be aware that any comments, including personal information such as name and address, may be made public. The various ways to deliver comments are outlined under ADDRESSES on Page 2 of the Rule: http://www.iadc.org/offshore_GOM_reform/documents/Interim-Final-Drilling-Safety-Rule.pdf (thank you to the IADC for providing this doanload

Read more >>

• BOEMRE, NTL No. 2010-N06: Information Requirements for Exploration Plans, Development and Production Plans, and Development Operations Coordination Documents on the OCS  

• BOEMRE, Fact Sheet, The Workplace Safety Rule on Safety and Environmental Management Systems (SEMS)

• BOEMRE, Fact Sheet, The Drilling Safety Rule, An Interim Final Rule to Enhance Safety Measures for Energy Development on the Outer Continental Shelf

DOI Publishes Final Rule, Oil and Gas and Sulphur Operations in the Outer Continental Shelf SEMS

The DOI published its SEMS Rule in the Federal Register October 16, incorporating in its entirety the American Petroleum Institute Recommended Practice (API RP) 75, for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities. This was expected and the API has hosted education sessions over the last month or so to explain RP 75 and answer questions of industry professionals.    

This final rule requires "the operator (a lessee, the owner or holder of operating rights, or the designated operator) to integrate a comprehensive SEMS program into the management of their OCS operations, thereby providing for the preservation of waste and conservation of natural resources of the Outer Continental Shelf." The BOEMRE highlighted some requirements of API RP 75 to clarify compliance requirements. The intent is to "hold the operator accountable for the overall safety of the offshore facility, includuing ensuring that all contractors and subcontgractors have safety policies and procedures in place that support the implenentation of the operator's SEMS program and align with  principles of managing safety set forth in API RP 75."

The ERM North America Risk Practice will review the entire Rule in the new few days and prepare a summary of what this means to the Gulf of Mexico and other U.S. offshhore drilling interests; watch our Facebook page for the latest.

International Regulators' Forum

The International Regulators' Forum (The Forum) is "a group of nine regulators of health and safety in the offshore upstream oil and gas industry." Their objectives are to promote safety performance, exchange information among regulators, and provide mutual support and advice.

The Forum convened in September with the BOEMRE; this was The Forum's "first extraordinary meeting convened in its 17-year history". The purpose was to address issues related to recent offshore oil and gas incidents. The nine member countries shared case studies, key regulatory processes, lessons learned, and best practices.

The Forum adjourned with three resolutions:

• To provide leadership on safety and safety related regulatory matters for offshore oil and gas activities
• To develop an audit protocol looking at BOP integrity and operation issues for use by all IRF members
• Continue to strengthen sharing regulatory practice and experience and provide a sounding board for key initiaties of members

These and other matters will be discussed at the next regular meeting of the IRF following the Third International Regulators' Forum Offshore Safety Conference in Vancouver, B.C. October 17-20. The theme is Offshore Safety: Where Do We Go From Here? Follow ERMRiskPractice tweets from the Vancouver conference.

 

IADC HSE Europe Conference & Exhibition, Amsterdam 

 

Almost 200 industry professionals attended the 2010 IADC (International Association of Drilling Contractors) Drilling HSE Europe conference and exhibition in Amsterdam September 28 through October 2, 2010. It would be impossible to provide a review of all the presentations made over two days, so we have selected a few to highlight here.

Focus On The Risk was the keynote topic by Peter Sharpe. Sharpe, Executive Vice President, Wells, for Shell International Exploration & Production B.V., was enthusiastic and committed to Shell’s “Goal Zero” program. The typical 400 to 500-page risk management system could not be absorbed; thus, it was not useful and could not be effectively implemented. So Shell focused on the areas of high risk and adopted a “simplify to comply” philosophy. The company identified 12 life-saving rules. “If you choose not to comply,” Sharpe said, “you choose not to work for Shell.”

Regulations

In the Regulations section, the process of introducing a standard bridging document in the Dutch oil and gas sector was discussed by Gert-Jan Windhorst of Noble Drilling Netherland. The project was launched in November 2009, after the Netherlands’ first Industry Day, and it will be presented at Industry Day 2010. The resulting document, he said, is very similar to what has come from the Joint Industry Task Force in the U.S.— a Well Construction Interfacing Document. He emphasized the need for standardization so such documentation can be adopted throughout the industry, be familiar to all stakeholders, prevent “reinventing the wheel”, focus on key interfaces, and force stakeholders together before the job begins. But, as brought out in a later session, because bridging documents must follow national regulations and contracting standards, some standardization of the documents might be in the hands of regulators.

Safety Culture & Behavior-based Safety

The next five hours was devoted primarily to developing a safety culture and behavior-based safety —the most time awarded to any topic at the conference. For example:

Rig Audit and Insurance

In addressing rig audit and insurance, Eric Olson and Peter Lazarri of Ensco credited, in large part, the company’s Core Value Team concept with stabilizing downtime and reducing total recordable incident rate to well below industry rates within four years. A Core Value Team acts as the “eyes and ears” of executive management in conducting safety, health, and environment (SHE) audits. A team spends three to four days on a rig and the audit is guided by standard protocols (such as policies and procedures and operations manuals). Findings are documented, distributed, measured, and monitored. Repeat findings are not accepted. However, Olson and Lazarri emphasized that the Core Value Teams interact with crewmembers as much as possible, rather than isolating themselves, earning trust and respect and learning more in the process.

Safety Management

Practical Safety Case Development, presented by Neil Holland and Neil Smeaton of Marex Marine and Safety Services, reviewed the IADC HSE case outline and suggested how safety cases could be written to be more practical than most are today. For example, providing a true quantitative risk assessment summary in plain language (rather than including all the assumptions and equations) would better serve the rig workers. Other real examples from various sections of safety cases were highlighted as being technically dense and probably understandable only to the most learned engineers in the field, not by rig workers for whom safety cases are guiding documents.

User Group: IADC HSE Case Guidelines for MODUs

After the conference, this User Group met to review and decide upon changes to the HSE Case Guidelines for MODUs, which changes incorporate language relative to well construction interface documents (bridging documents) and the relationship between rig operator and contractor. Most changes were small and accepted. A couple of them were sent back to be rewritten. Watch the IADC website for advice when the changes are finalized.

Drilling Safety Legislation Pending

U.S. House Bill HR 3534 Consolidated Land, Energy, and Aquatic Resources Act of 2009 was introduced in September 2009. It was amended in and passed passed the House in July 2010 and is now with the Senate

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Contact the ERM North America Risk Practice Group group, a global leader in assessments of engineering design and operations safety for hazardous facilities. The Risk Practice conducts facility siting, consequence analysis, process hazard assessments, hazard identification, and a host of other safety and hazard analyses.

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