I must admit not following this proposed rulemaking but as a former drillship hand I am always interested in this subject. Who is more up on all the provisions it contains? Does it involve sweeping changes to BOP design and operation? How about offshore personnel?
By MarEx 2015-12-01
U.S. oil and gas industry bodies are having their say on the well control rule proposed by the U.S. Bureau of Safety and Environmental Enforcement (BSEE) which they believe could increase risk and decrease safety in offshore operations.
The American Petroleum Institute (API) raised its concerns at the Senate Committee on Energy and Natural Resources on Tuesday. “The oil and natural gas industry, in coordination with federal regulators, has made great strides in making offshore energy exploration safer than ever while advancing the energy security of our nation,” said Erik Milito, API upstream group director, in testimony at the Senate hearing. “We are committed to working with the government to improve the proposals and achieve the mutually desired objective of safety by getting this rule right.”
API and six fellow trade associations, the International Association of Drilling Contractors, the Independent Petroleum Association of America, National Ocean Industries Association, the Offshore Operators Committee, the Petroleum Equipment & Services Association and the U.S. Oil and Gas Association, drew on the expertise of over 300 subject matter experts from more than 70 companies who expended tens of thousands of collective hours to provide BSEE a technically-based set of comments to aid in its efforts to create a robust and effective well control rule.
However, the compressed comment period of 90 days did not allow for full technical comments prior to a rulemaking, says the API. As a result, as proposed, the rule reflects a one-size-fits-all approach that does not recognize the variability of operations and engineering specific to each well.
“Prescriptive requirements will only serve to stifle innovation and delay implementation of new technologies that could improve safety and operations,” said Milito. “Working together, we can develop practical final rules that are ultimately both feasible and effective for the future of safe and responsible energy development.”
API has approximately 275 exploration and production standards that address offshore operations, covering everything from blowout preventers to comprehensive guidelines for offshore safety programs, and more than 100 have been incorporated into federal regulation. Since 2010 API has published over 100 new and revised exploration and production standards, including for offshore well design, blowout prevention equipment, worker safety and other elements of oil and natural gas development. The industry also launched the Center for Offshore Safety in 2011 to support continuous safety improvements.
NOIA Wades in on the Debate
America’s Offshore Energy Industry (NOIA) President Randall Luthi is also speaking out on the issue. He issued the following statement following the hearing on the proposed well control rule:
“It is in the best interest of all concerned, including the Federal regulators, industry, Congress, other stakeholders, and the general public, to get the Well Control Rule right. Congress has certainly expressed its interest in the process surrounding the rulemaking as evidenced by today’s hearing and the earlier House Natural Resources Committee hearing in New Orleans.
“A rule as complex and sweeping as this proposal requires extensive and comprehensive dialogue between drilling engineers and experts and the regulators. While there has been progress in reaching agreement and understanding on some areas of the proposed rule, we still have substantial concerns with its prescriptive and one-size fits all provisions, which may have the unintended consequence of increasing, rather than decreasing, risk.
“Safety offshore is paramount, and rushing to finalize this rule by early 2016 could produce regulations that may not meet the most current safety standards and technology. This is truly a case where additional collaboration with industry experts will result in a better, more effective and workable rule. The quality of the final rule should take precedence over a politically-imposed deadline.”
BSEE Defends Rules
However, U.S. Bureau of Safety and Environmental Enforcement Director Brian Salerno has defended the new rules saying that the focal point of numerous investigations and studies of the Deepwater Horizon tragedy all point to blowout preventers (BOPs) and associated well control systems, which is why BSEE has proposed new rules that would substantially upgrade existing regulations pertaining to BOPs and well control systems.
“Industry standards put in place in the aftermath of the deaths of eleven offshore workers and ensuing oil spill are a step in the right direction, but do not solve the problem. These standards do not have the force of law, as regulations do. Accountability matters, and, as a regulator, we need to do all that we can to drive down risks in offshore operations.”
of course, I am all for MORE safety and not LESS when it comes to deepwater operations. Sticking it to the likes of SEPCO is fine by me. I wonder if it includes a licensing scheme for subsea engineers offshore? I have always said that the old system of simply promoting people into those positions is not enough but they should be able to pass tough examinations to qualify them for the critical roles they play in preventing a blowout. In fact, I am on record that EVERY hand involved in drilling operations should be licensed just like the bridge and engineroom people are. Floorhands should be equal to an AB/oiler, assistant driller/subsea a third mate/engineer, driller/subsea engineer should be equal to seconds, toolpushers/senior subsea should be equal to chief mates/engineers. They should all be required the same level of time in grade, training and examinations as all the rest of the marine crews.