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Archive for the ‘Regulation’ Category

The Ultimate Single Regulator Solution

Posted in IRF, Offshore Energy - General, Regulation, tagged , , , , , , , on November 5, 2010| Leave a Comment »

The above slide is from the excellent presentation that Jan de Jong (Inspector General, State Supervision of Mines, the Netherlands) never got to deliver in Vancouver. As session chair, Jan graciously yielded his time to his panelists.

Jan’s presentation notes the growing importance of international cooperation. This trend has the potential to improve regulatory capabilities, expand data availability and access, reduce regulatory costs through the sharing of resources, reduce costs for industry through greater international consistency and regulatory certainty, and improve international relations.  The Netherlands, Russia, Norway, Cuba, the US, and everyone else should be on the same team when it comes to offshore safety and pollution prevention.  Some near-term suggestions follow:

  • Except where regional conditions dictate otherwise, the same standards should be applied worldwide.  Government and industry should be collectively questioning, testing, and improving these standards. Remember that the goal is continuous improvement, not mere compliance.
  • An international information system should provide for the collection and verification of incident and performance data.
  • Using international data and expertise, a cooperative risk assessment program should be initiated.
  • An organized international audit capability should be established to evaluate operators and regulators.
  • To improve access to expertise and reduce costs, a network of specialists should assist regulators worldwide.
  • Industry training requirements should be uniform and consistently applied, and regulator training programs should be consolidated regionally or internationally.
  • The international research network should be expanded.
  • To ensure that accidents are investigated independently and to minimize the potential for political influences on the investigation process, an international accident investigation capability should be established.
  • The safety culture message should be promoted worldwide.  Successes and failures should be cooperatively examined.

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Western Australia Resists Single Regulator

Posted in Regulation, tagged , , , on November 4, 2010| Leave a Comment »

From Western Australia Business News:

The gulf between the Western Australian government and Canberra continues to widen, with state mines and petroleum minister Norman Moore writing to local oil and gas companies for support to block plans for a single national oil regulator.

Comment: What is Mr. Moore offering the companies in return for their support? This “turf” battle shows why you can’t have multiple authorities regulating the same facilities.  Disputes, self-interest, conflicting agendas and priorities,  and “turf” issues drain too much energy from the regulators and the industry being regulated.  Concerns about critical operational risks are superseded by coordination activities and debates about who is in charge.

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Back to the Future!

Posted in Regulation, tagged , , , , , on November 1, 2010| Leave a Comment »

 

Hyannis Halloween - 1981

 

Note the sign (above) on our office at Barnstable Municipal Airport in Hyannis. Prior to 1982 when the Minerals Management Service was formed, the OCS regulatory program was part of the US Geological Survey (Conservation Division) and the leasing program was in the Bureau of Land Management. After a 28-year marriage, these functions are again being separated.

As one who worked in the OCS program for 10 years prior to the formation of MMS, I think the the pre-1982 framework is conceptually preferable. However, unless the separation is carefully executed, disruptive conflicts between the two organizations are guaranteed.  Such conflicts were common in the pre-MMS days, and the Department of the Interior had to set up a special office to coordinate activities and manage disputes.

In addition to being independent, the new regulatory authority must be fully responsible (without interference) for all regulatory actions from plan approval through abandonment.  Without such independence and authority, the separation will only add to the regulatory confusion that has handicapped the OCS program throughout its history.

Technical and scientific personnel in the OCS regulatory program must be freed from non-productive and time-consuming internal disputes and coordination responsibilities so they can concentrate on performance measurement, risk assessment, safety leadership, standards, and technical studies.

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API provides free access to industry standards

Posted in Regulation, tagged , , on October 28, 2010| Leave a Comment »

As promised, API is now providing free access to referenced safety standards.  Ironically, the system was initiated while I was looking for online access to RP 53.  I tried the new system and it seems to work fine. Registration is required, but the process is quite easy.

Kudos to API for taking this important step.

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And here is the final SEMS rule

Posted in accidents, Regulation, tagged , , , , , , , , , , on October 7, 2010| Leave a Comment »

Safety and Environmental Management Systems

This rulemaking will incorporate in its entirety and make mandatory the AmericanPetroleum Institute’s Recommended Practice 75, Development of a Safety andEnvironmental Management Program for Offshore Operations and Facilities, with respectto operations and activities under the jurisdiction of BOEMRE. This final rule will applyto all OCS oil and gas and sulphur operations and the facilities under BOEMREjurisdiction including drilling, production, construction, well workover, well completion,well servicing, and DOI pipeline activities.

The rule will become effective on November 15, 2010.

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Post-Macondo Drilling Safety Rule Posted by the Federal Register

Posted in drilling, Regulation, tagged , , , , , , , , on October 7, 2010| Leave a Comment »

The complete interim final Drilling Safety Rule is now posted on the Federal Register site.  This rule was announced on 30 September along with the Safety and Environmental Management System rule. The latter rule has not yet been posted by the Federal Register.

The Drilling Safety Rule is effective immediately.  With regard to comments:

While BOEMRE will not solicit comments before the effective date, BOEMRE will accept and consider public comments on this rule that are submitted within 60 days of its publication in the Federal Register. After reviewing the public comments, BOEMRE will publish a notice in the Federal Register that will respond to comments and will either:

1. confirm this rule as a final rule with no additional changes, or

2. issue a revised final rule with modifications, based on public comments.

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NOPSA CEO Jane Cutler on Leadership

Posted in Regulation, tagged , , , , , on October 3, 2010| Leave a Comment »

Jane Cutler, CEO of the National Offshore Petroleum Safety Authority, makes important comments on leadership in this interview.

I’m privileged to work with some great people who are passionate about improving safety. This role within NOPSA provides me with a great opportunity to make a difference and allows me to foster a really proactive work culture, removing obstacles that make it harder for people to do their work well.

Almost everyone involved with offshore safety is passionate about their work and wants to make a difference.  Unfortunately, they are often frustrated by administrative and organizational processes that prevent them from identifying and addressing important safety issues in the most effective and efficient manner.  While there has been much post-Macondo talk about safety policy, there has been little discussion about the organizational constraints that stifle initiative and creativity within regulatory programs.  The focus should be on enabling bright and dedicated people to create and sustain an optimal regulatory environment for safety achievement by the operating companies and their contractors.

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Drilling and Safety Management Rules Announced

Posted in accidents, Offshore Energy - General, Regulation, tagged , , , , , , , , , , on September 30, 2010| 2 Comments »

Today, BOEM released fact sheets describing the Drilling Safety and Safety and Environmental Management (SEMS) rules. The complete documents will be available for review as soon as they are published in the Federal Register.

Based on the fact sheet, the Drilling Safety Rule does not appear to include any significant surprises.  The rule seems to be generally consistent with the recommendations in Secretary Salazar’s 27 May Safety Measures Report to the President (the “30-Day Report”).  This is an Interim Final Rule that will be effective upon publication.

According to the fact sheet, the SEMS Rule will incorporate all elements of API RP 75 into BOEM regulations.  This is an improvement, in my opinion, from the proposed rule which incorporated only 4 elements of RP 75.  The effective date for this rule is not indicated in the fact sheet.

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BOEMRE Addresses “Idle Iron”

Posted in accidents, Offshore Energy - General, Regulation, tagged , , , , , on September 16, 2010| 1 Comment »

The Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE) has issued a Notice to Lessees and Operators (NTL) that specifies deadlines and other requirements for plugging and abandoning non-producing wells and removing platforms that no longer have utility. In my view, this regulatory action is necessary, appropriate, and consistent with authority provided in the Subpart Q (for quit :)) Decommissioning regulations. Post-hurricane experiences have demonstrated the enormous costs, operational challenges, and safety and environmental risks associated with plugging damaged wells and removing toppled platforms.

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International Regulators’ Offshore Safety Conference, 18-20 October, Vancouver

Posted in conferences, IRF, Offshore Energy - General, Regulation, tagged , , , , , on June 8, 2010| Leave a Comment »

 

Vancouver, BC, Canada

 

The program for the International Regulators’ Offshore Safety Conference has been updated to include keynote presentations on the Montara and Macondo blowouts, and roundtable sessions that will address the lessons learned and how they should be applied by operators, contractors, and regulators.  The presentations, discussions, and debates are sure to be thought provoking and informative.  If you would like to participate, visit the conference website for more information.

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