By Katie Mazerov, contributing editor
A proposed rule for enhancing blowout preventer (BOP) requirements is one of four key next-generation regulatory items being considered by the US Bureau of Safety and Environmental Enforcement (BSEE), the agency’s director announced in a topical breakfast at the 2012 OTC in Houston on 1 May. “The main question is, are the BOPs we have now sufficient? And if not, what can we do to improve their reliability and effectiveness?” BSEE director James Watson said.
The BOP issue will be the focus of an all-day public forum on 22 May in Washington, DC. Topics planned for the panel sessions include technology needs identified from the Macondo incident; shearing and sealing design requirements; manufacturing, test, maintenance and certification requirements to ensure operability and reliability; real-time technologies to measure the “health” of BOPs; and training and certification for key personnel. IADC VP of accreditation and certification Mark Denkowski will be representing the drilling industry on the last panel.
Another proposed rule would heighten standards for production safety systems based on life-cycle analysis, moving beyond simple compliance and into a performance and life-cycle concept for regulation. “We need to focus on the potential that the next event will not be drilling-related but could involve one of the state-of-the-art production systems that haven’t seen new rules since the 1980s,” Director Watson said. Other priorities include completing the final safety drilling rule and SEMS 2, which requires companies to implement and maintain safety and environmental management system programs.
The SEMS rule, promulgated last November, includes several provisions, including a stop-work authority, requirements for reporting unsafe working conditions, mandates for employees to participate in the development and implementation of company SEMS programs and requirements regarding the use of independent third-party auditors and auditor training.
“Since the Deepwater Horizon (incident), the BSEE has been involved in the most comprehensive and aggressive offshore regulatory reforms in the history of our country,” Director Watson said. “Our ability to ensure the highest level of safety and responsibility in the world depends in large part on the ability of the industry to internalize the need for a robust safety culture. Safety does not simply mean doing things right when BSEE has an inspector onboard a rig or a platform. It means operating safety at all times and at all levels.”
The agency has hired 20 new engineers and 46 new inspectors in the past two years and plans to bring on an additional 200 people to keep up with the permitting process and the review of offshore response plans required for each new application. An Offshore Training and Learning Center is also being established to train new employees.
Rigs returning to GOM
“We are pleased to see rigs returning to the GOM because it demonstrates the industry’s confidence that it can do business in the Gulf and meet the safety requirements, and that it has confidence in the regulatory agencies,” Director Watson continued. He said that approximately 100 people are involved in permit review at any given time, but that number is expected to increase to 200. He anticipates the inspection workforce to grow from 50 to 125 employees. In addition to the GOM, the agency has jurisdiction over the US West Coast and the North Slope of Alaska, where activity is also expected to increase significantly.
“My measure of effectiveness is not the pace of permits or the number of instances of non-compliance,” he said. “We’re much more interested in getting the job done right, sending the right message to the industry about safety and environmental protection and using all of our authorities. We will take a measured approach, but we won’t be shy when it’s appropriate and necessary.” He indicated there will be a focus on deepwater operations because of the number of applications going beyond the limits of existing regulations.
Director Watson cited the Center for Offshore Safety (COS) as an example of the industry’s commitment to promoting safety. “The COS was an idea whose time had come and is now blossoming into a multifaceted organization with terrific connections between the industry and government.”
Another positive development has been the ongoing effort by US and Mexico to establish a boundary agreement in the vast GOM area that has been off-limits, Director Watson noted. Over the past year, both governments have worked to develop an agreement by which a deepwater reservoir on the border could be developed jointly. Under the pact, which still requires approval by the US Senate, the US would inspect activities on the Mexican side of the border while Mexican authorities would inspect drilling and production operations on the US side. “We know of no other boundary agreement like this and believe it could potentially become a model worldwide,” he said.