IADC VP – offshore technical and regulatory affairs Alan Spackman testified today in Washington, DC, before the US Chemical Safety Board (CSB) as part of its ongoing investigation into the causes of the Macondo incident.
Mr Spackman provided a review of IADC’s HSE Case Guidelines for MODUs and described why a safety case based on these guidelines is appropriate for use in US deepwater drilling operations. He pointed out that the IADC guidelines facilitate acceptance across regulatory jurisdictions where a safety case is required; it also reduces proliferation of differing requirements by new safety case adoptees.
He also described the API-IADC Well Construction Interface Document and how it adds the elements of well basis of design, well execution plan and critical well activity risk assessments to the traditional HSE management system bridging arrangement. Further, IADC is developing recommendations for changes to the guidelines based on results of gap analyses with API RP 75 and the SEMS Final Rule of the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE).
Describing IADC recommendations to the BOEMRE, Mr Spackman said the agency should assess its resources in developing an approach to implementing the HSE case. He also encouraged the agency to establish a means for ongoing dialogue with industry for SEMS implementation and to form a multi-year implementation roadmap recognizing the complexity of that implementation.
The US Coast Guard (USCG), which also holds regulatory jurisdiction over offshore E&P activity, should establish dialogue with the BOEMRE on hazards analyses, with particular reference to matters traditionally under USCG jurisdiction, he said.
The public hearing also included testimony from other industry representatives, including API, Shell and Statoil, as well as a panel of regulators from the UK, Norway and Australia, and US labor union leaders. The CSB, an independent federal agency charged with investigating chemical accidents, is gathering information on how offshore oil and gas drilling is managed and regulated in other countries. The data will help form the board’s safety recommendations that will result from the investigation.