The US Department of the Interior (DOI) announced on 30 September two new rules that will toughen requirements for safety equipment, well control systems and blowout prevention practices on offshore oil and gas operations, as well as workplace safety requirements.
“Under these new rules, operators will need to comply with tougher requirements for everything from well design and cementing practices to blowout preventers and employee training. They will also need to develop comprehensive plans to manage risks and hazards at every step of the drilling process, so as to reduce the risk of human error,” US Secretary of the Interior Ken Salazar said.
The Drilling Safety Rule and the Workplace Safety Rule “are part of a broader series of reforms we are undertaking to reduce the risks of offshore energy operations,” said Michael Bromwich, director of the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEM).
The Drilling Safety Rule, effective immediately upon publication, makes mandatory several requirements for the drilling process that were laid out in Secretary Salazar’s 27 May Safety Report to President Obama. The regulation prescribes proper cementing and casing practices and the appropriate use of drilling fluids in order to maintain wellbore integrity.
The regulation also strengthens oversight of mechanisms designed to shut off the flow of oil and gas, primarily the BOP and its components, including ROVs, shear rams and pipe rams. Operators must also secure independent and expert reviews of their well design, construction and flow intervention mechanisms.
The Drilling Safety Rule is being issued under an emergency rule-making process. The BOEM says it will move forward with a standard rulemaking process that will include more opportunities for public comment. Additional recommendations of the Safety Report will be considered as well, such as the requirement that BOPs have two sets of blind shear rams.
While the rule is effective immediately, BOEM will accept and consider public comments submitted within 60 days of the rule’s publication. The agency will then either publish a new rule with modifications in light of comments received or publish a notice that will confirm the rule as final with no additional changes.
The Workplace Safety Rule requires offshore operators to have clear programs in place to identify potential hazards when they drill, clear protocol for addressing those hazards, and strong procedures and risk-reduction strategies for all phases of activity, from well design and construction to operation, maintenance and decommissioning.
The Workplace Safety Rule requires operators to have a safety and environmental management system (SEMS). It also makes mandatory API Recommended Practice 75, which was previously a voluntary program to identify, address and manage safety hazards and environmental impacts in their operations.
BOEM will undertake additional workplace safety reforms, such as requirements for independent third-party verification of operators’ SEMS programs, through an additional rulemaking process to be launched soon.
Highlights: The Drilling Safety Rule & The Workplace Safety Rule
The Drilling Safety Rule
This interim final rule, effective immediately, addresses both wellbore integrity and well control equipment and procedures. Provisions in the rule addressing wellbore integrity are:
- Making mandatory the currently voluntary API RP 65 – Part 2, Isolating Potential Flow Zones During Well Construction;
- Requiring submittal of certification by a professional engineer that the casing and cementing program is appropriate for the purposes for which it is intended under expected wellbore pressures;
- Requiring two independent test barriers across each flow path during well completion activities, certified by a professional engineer;
- Ensuring proper installation, sealing and locking of the casing or liner;
- Requiring approval from the BOEM district manager before replacing a heavier drilling fluid with a lighter fluid; and
- Requiring enhanced deepwater well control training for rig personnel.
Provisions on well control equipment include:
- Submittal of documentation and schematics for all control systems;
- Requirements for independent third-party verification that the blind-shear rams are capable of cutting any drill pipe in the hole under the maximum anticipated surface pressure;
- Requirement for a subsea BOP stack equipped with ROV intervention capability. At a minimum, the ROV must be capable of closing one set of pipe rams, closing one set of blind-shear rams and unlatching the lower marine riser package;
- Requirement for maintaining a ROV and having a trained ROV crew on each floating drilling rig on a continuous basis;
- Requirement for auto shear and deadman systems for dynamically positioned rigs;
- Establishment of minimum requirements for personnel authorized to operate critical BOP equipment;
- Requirement for documentation of subsea BOP inspections and maintenance according to API RP 53, Recommended Practices for Blowout Prevention Equipment Systems for Drilling Wells;
- Require testing of all ROV intervention functions on subsea BOP stack during stump test, and testing at least one set of rams in initial seafloor test;
- Require function testing auto shear and deadman systems on the subsea BOP stack during the stump test, and testing the deadman system during the initial test on the seafloor; and
- Require pressure testing if any shear rams are used in an emergency.
The Workplace Safety Rule
The BOEM will submit to the Federal Register for publication a final Workplace Safety Rule requiring offshore oil and gas operators to develop and maintain a safety and environmental management system (SEMS). It makes mandatory the currently voluntary practices in API RP 75. The 13 elements of RP 75 that the Workplace Safety Rule makes mandatory are:
- General provisions for implementation, planning and management review and approval of the SEMS program;
- Safety and environmental information: safety and environmental information needed for any facility, e.g. design data; facility process such as flow diagrams; mechanical components such as piping and instrument diagrams; etc;
- Hazards analysis: a facility-level risk assessment.
- Management of change: program for addressing any facility or operational changes, including management changes, shift changes, contractor changes, etc;
- Operating procedures: evaluation of operations and written procedures.
- Safe work practices: manuals, standards, rules of conduct, etc;
- Training: safe work practices, technical training – including contractors;
- Mechanical integrity: preventive maintenance programs, quality control;
- Pre-startup review: review of all systems;
- Emergency response and control: emergency evacuation plans, oil spill contingency plans, etc.; in place and validated by drills;
- Investigation of incidents: procedures for investigating incidents, corrective action and follow-up;
- Audits: The Workplace Safety Rule strengthens RP 75 provisions by requiring an audit every four years to an initial two-year re-evaluation, and then subsequent three-year audit intervals;
- Records and documentation: documentation required that describes all elements of SEMS program.