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Archive for the ‘Regulation’ Category

C-NLOPB’s prompt public notification of incidents is good regulatory practice

Posted in accidents, Canada, Offshore Energy - General, Regulation, tagged , , on March 28, 2022| Leave a Comment »

Below and linked is the most recent C-NLOPB incident posting:

  • Timely
  • Front page
  • Advises about any casualties or pollution (none in this case)
  • Briefly describes incident without speculating on causes
  • Informs about next steps
  • Well done

INCIDENT DISCLOSURE 2022

NEAR MISS ON THE HIBERNIA PLATFORM

March 25, 2022

Hibernia Management and Development Company (HMDC) has reported that on March 20, 2022 a crane on the Hibernia Platform was lifting a mini container when it made contact with a scaffold hoarding. There were three people working inside the hoarding at the time of contact. No one was injured and there was no damage to the scaffold hoarding.

West pedestal crane operations were halted and HMDC has initiated an investigation to determine the potential classification of the incident.

C-NLOPB Safety Officers were already scheduled to travel to the Hibernia Platform in the coming days and will follow up with HMDC to review this incident and the near miss that occurred on March 15.

The C-NLOPB is also monitoring HMDC’s investigations of these incidents.

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Well Control Equipment Systems Safety Report

Posted in drilling, Gulf of Mexico, Regulation, well control incidents, tagged , , , , , on March 10, 2022| Leave a Comment »

This useful SafeOCS report summarizes and itemizes well control equipment failures associated with well operations on the Gulf of Mexico OCS in 2020. Of particular note was the absence of any loss of containment (leak of wellbore fluids) events in 2020 or the prior two years.

Unfortunately, there appear to be significant reporting gaps despite the fact that reporting of these data is required by regulation (30 CFR 250.730(c)). The reporting issues are particularly serious for surface systems (surface BOP and associated equipment). Per SafeOCS, surface rig reports were received from less than 50% of active operators and rigs. Reporting for subsea systems (subsea BOP and associated equipment) was much better with 85% of the active rigs represented.

Of further concern with regard to the reporting of surface equipment events, the data indicate only 5.3 events per 1000 hours for surface systems vs. 71.5 for subsea systems. While subsea systems are more complex, the cost of pulling and repairing subsea equipment dictates newer, better maintained equipment. As a result, surface BOPs have historically had higher failure rates than subsea BOPs. The data below are from a presentation to MMS approximately 15 years ago. Both the Sintef and OOC data show higher failure rates for surface BOPs.

The SafeOCS team did a very good job of analyzing the reports and presenting the data. However, the reporting issues need to be investigated and resolved to get maximum value from this very important work.

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OSHA vax standard lives on as a proposed rule

Posted in Health, Regulation, tagged , , on January 27, 2022| Leave a Comment »

Although OSHA is withdrawing the Vaccination and Testing ETS as an enforceable emergency temporary standard, OSHA is not withdrawing the ETS to the extent that it serves as a proposed rule

OHSA Notice

Should we call the proposed rule an ETS variant?

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More on 2021 compliance (US offshore oil and gas operations)

Posted in Alaska, California, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , , , , , , , , , , , on January 20, 2022| Leave a Comment »

While the Fieldwood Energy violations drove up the number of Incidents of Non-Compliance (INCs) in the Gulf of Mexico in 2021, most operating companies appear to have had good compliance records. Among companies that were subjected to at least 10 facility inspection and drilled at least one well, BHP Billiton, Eni US, and Murphy (listed alphabetically) had the most impressive compliance records. These three operators were cited for 7 or fewer INCs, none of which required a facility to be shut-in. Other operators that exceeded those activity thresholds and had excellent compliance records were (listed alphabetically) Anadarko, ANKOR Energy, Chevron, EnVen, Shell, and Walter Oil and Gas.

In the Pacific Region, Beta Operating Co., Chevron (now overseeing the former Signal Hill properties), and Exxon had excellent compliance records, although none of these facilities produced for the full year. In Alaska, Hillcorp had an excellent record at the Northstar Unit. (This is a gravel island facility in the State waters of the Beaufort Sea, but some of the wells produce from portions of the reservoir that are in the Federal sector).

Unfortunately, only summary inspection data are posted online. Without knowing the specific violations and circumstances, it’s not possible to fully assess the risk exposure. These oil and gas operations are conducted on public lands and are monitored by Federal employees. Inspection data and reports should be publicly accessible without having to submit Freedom of Information Act requests.

As has previously been discussed, incident updates should also be posted in a timely manner. Reference is made to this important recommendation in the 2016 National Academies report entitled Strengthening the Safety Culture of the Offshore Oil and Gas Industry:

Recommendation 4.2.2: Because accident, incident, and inspection data all are needed to identify and understand safety risks and corrective actions, the committee recommends full transparency such that regulators make all these data readily available to the public in a timely way, taking into consideration applicable confidentiality requirements.

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Gulf of Mexico violations surged in 2021; one company is largely responsible

Posted in accidents, Gulf of Mexico, Offshore Energy - General, Regulation, tagged , , , , , on January 20, 2022| Leave a Comment »

Per BSEE’s Incidents of Non-Compliance (INC) data base, the number of violations surged in 2021, both in terms of the total number of INCs and the INCs/inspection ratio (see chart below). Remarkably, a single company – Fieldwood Energy – was responsible for 845 INCs or 44% of the total number issued. Normalizing for the number of inspections, Fieldwood facilities were cited for 1.46 INCs/inspection versus 0.46 INCs/inspection for all other companies. An unprecedented 61 of Fieldwood’s 2021 INCs called for facility shut-ins, many times more than any other operator. Through the first 17 days of 2022, Fieldwood has already been cited for 21 INCs, 5 of which required facilities to be shut-in.

Fieldwood and its affiliates have experienced multiple bankruptcies and the company has once again been reorganized with the blessing of the courts. Chevron’s comprehensive objection to the reorganization plan asserted that Fieldwood has $9 billion in current and anticipated decommissioning obligations. These enormous decommissioning liabilities and their implications for predecessor lessees (former facility owners) and the Federal government were the main issue in these proceedings, and the bankruptcy plan includes settlements with predecessor companies and the government.

Even more significant than the financial matters and INCs are the following:

While BSEE regulations provide for the removal of operating rights for poor safety performance, companies can reorganize and problem managers can reappear elsewhere. As a result, marginally financed and ineffective operating companies are a major challenge for BSEE as evidenced by the INCs, civil penalties, and investigations. (See the related saga of Platforms Hogan and Houchin in the Pacific Region.)

Poor safety performers drag down the entire industry. The costs of mega-disasters like the Santa Barbara and Macondo blowouts have been widely discussed. However, chronic poor performance and the associated incidents also weaken the industry and damage the integrity of the offshore oil and gas program. These performance issues can’t be left entirely to BSEE and the Coast Guard to resolve. The industry needs to do a better job of self-evaluation, calling out poor performers, and exercising judgement in the assignment of offshore properties.

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Supreme Court nixes OSHA vax “work-around”

Posted in energy policy, Health, Offshore Energy - General, Regulation, tagged , , , on January 13, 2022| Leave a Comment »

This should not surprise experienced OSHA regulators given the absence of clear legislative authority.

Offshore regulators in the US have used “work-arounds” in the form of Notices to Lessees, Conditions of Approval, and other types of guidance documents. However, there was a general understanding that requirements imposed by these methods would not survive legal challenges unless they were clearly authorized by legislation or regulations. Most work-arounds aren’t challenged because the regulatory authority is reasonably clear, their issuance is at least minimally acceptable to the regulated industry, or the perceived cost of challenges exceeds the cost of compliance.

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While we await the Supreme Court decision on the US (OSHA) vaccine mandate…

Posted in energy, Health, Norway, Regulation, Uncategorized, tagged , , , on January 13, 2022| Leave a Comment »

A Norwegian union representing offshore oil and gas workers has criticized Aker BP’s process to introduce a Covid-19 vaccine mandate for its offshore employees.

offshore-energy.biz

“We agree that we must protect our employees and our suppliers in the best possible way, but it also requires that we are involved in how it should happen and how our employees and suppliers are taken care of in this process.”

Ingard Haugeberg, Industri Energi

Seems like a reasonable position on the part of the workers. As previously reported, many US oilfield workers are skeptical of the vaccine mandate and have warned that they will quit.

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Important reading for offshore safety leaders

Posted in accidents, California, Gulf of Mexico, Regulation, tagged , , , , , on January 11, 2022| Leave a Comment »

Yesterday, BSEE issued investigation reports for 2 of the fatal 2020 incidents. Both of these incidents involved falls, a chronic and preventable cause of offshore worker casualties. Not enough industry and trade association attention is given to such incidents, which have been trivialized in the past by categorizing them as “slips, trips, and falls.” The reports are linked below:

The reports describe how the incidents occurred and what we can do better to prevent similar events in the future. Despite the advance in safety management programs over the past 30 years, there has been no discernible improvement in preventing these incidents. We need to rethink training programs, planning, and methods. Deadly falls are not inevitable.

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Dept. of Transportation seemingly expands Integrity Management Program requirements to all offshore liquids pipelines

Posted in energy policy, pipelines, Regulation, tagged , , , on December 21, 2021| Leave a Comment »

New PHMSA (DOT) regulation

At the behest of Congress, coastal areas and beaches are now designated as Unusually Sensitive Areas (USAs). Given that any offshore liquids pipeline has the potential to affect coastal waters or beaches, the rule would seem to require that all such pipelines be included in Integrity Management Programs, which are mandatory for pipelines that could affect USAs. (The IMP requirements would almost certainly apply to all DOT regulated offshore pipelines. Their applicability to DOI/producer pipelines is less certain. Of course, very little is clear and consistent in US offshore pipeline regulation.)

As one would expect, the recent Huntington Beach pipeline spill is among the incidents cited in the justification for this regulation. More surprisingly, the Santa Barbara well blowout was also cited. This incident occurred 53 years ago, was the result of a reckless drilling program, and had nothing to do with production operations or pipelines.

As noted in a recent BOE post, the regulatory regime for offshore pipelines is badly in need of overhaul. DOT and DOI, with inconsistent jurisdictional boundaries, regulations, and approaches, have primary responsibility and multiple regulatory entities have roles.

Lastly, PHMSA seems to have inadvertently posted a highlighted copy of the new regulation. Nothing at all scandalous (looks like someone was highlighting potential talking points), but possibly amusing to other regulation nerds. 😃

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Appeals court reinstates vaccine mandate. Supreme Court next. Will the mandate cause oilfield workers to quit?

Posted in energy, Health, Regulation, tagged , , on December 18, 2021| Leave a Comment »

Vaccine mandate revived.

WSJ story on oilfield workers. Highlights:

  • Many oil workers are skeptical of the mandate and have warned they will quit
  • Ann Fox, chief executive of Nine Energy Service estimates that <15% of the company’s field workers are vaccinated.
  • Justin Clark, a field services manager understands why workers resist:

“I don’t like to be forced to do anything. I almost want to just do the opposite when someone tells me, in that manner, you’ve got to do this.”

WSJ

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