Offshore Safety and Environmental

steamonlyOil and Offshore

Nov 8, 2013 (3 years and 10 months ago)

88 views

1

Before

and After
Macondo
:

Offshore

Safety and Environmental
Regulation in Historical Context

Tyler Priest

C.T. Bauer College of Business

University of Houston

tpriest@uh.edu


The National Commission on the BP Deepwater Horizon Oil
Spill and Offshore Drilling

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A Competent and Nimble Regulator


“The industry needs a robust, expertly staffed,
and well
-
funded regulator that can keep pace
with and augment industry's technical
expertise. A competent and nimble regulator
will be able to establish and enforce the rules
of the road to assure safety without stifling
innovation and commercial success.”



Testimony of Marvin
Odum
, President, Shell Oil Company,

and Upstream Americas Director, Royal Dutch Shell,

before National Commission, November 9, 2010

3

Safety and Environmental Protection


Inseparable concepts


especially offshore


Occupational vs. Process Safety Management


Prescriptive vs. Performance
-
Based, or Risk
-
Based Regulation


Historical Background on Safety and
Environmental Management Systems (SEMS)
rule






4

Major Offshore Accidents, 1980s

5


South Pass Block 60 explosion, Louisiana (1989)



Report by National Research Council Marine Board of the
National Academy of Sciences, (1990)

SEMP to SEMS


OSHA PSM Rule


did not apply to OCS


Safety and Environmental Management Program
proposed by MMS in 1991


API RP 75


Recommended Practice for Development
of a Safety and Environmental Program for Outer
Continental Shelf (OCS) Operations and Facilities


MMS decision in 1994 to make SEMP a “voluntary”
standard


Proposed “SEMS” (Safety and Environmental
Management Systems) rule of 2006


included only 4
of 12 elements of API RP 75


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MMS Resource Constraints

8

MMS Inspections

OCS Oil Production and MMS Budget

“Streamlined” Regulatory Apparatus at MMS


Inspections


Plummeting number of unannounced inspections


MOU with USCG (2002)


Training


Reduced MMS requirements


Reporting


Incident reporting requirements lagged by
international standards


Technical Cooperation


Disappearance of MMS from industry technical
literature

9

New SEMS
-

Post
-
Macondo


Transformation of API RP 75 from voluntary to
required standard, with added elements.


Applicable to all operations and to all
operators. Not required of contractors, but
must have documented agreement with
operator.


Addresses both occupational and process
safety.


Must be in place by November 15, 2011

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SEMS


Basic Elements

1. General provisions

2. Safety and Environmental Information

3. Hazards Analysis

4. Management of Change

5. Operating Procedures

6. Safe Work Practices

7. Training

8. Mechanical Integrity

9. Pre
-
start up Review

10. Emergency Response and Control

11. Investigation of Incidents

12. Audits

13. Records and documentation

11

SEMS
-

Issues


Implementation


interpreting the rules


Costs of compliance


differential impact on
international and domestic operators


Enforcement


jurisdictional overlaps and
conflicts; audits


Efficacy


effect of SEMS in making positive
impact on safety culture of companies



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For More Information on SEMS

13


BOEMRE
,
http://www.boemre.gov/semp/


PEC/Premier Safety Management

http://pecpremier.wordpress.com/


For More Information on National OSC


Web Site
:
www.oilspillcommission.gov





Final Report:
Deep Water


also available in paperback from the
Government Printing Office, Amazon.com, and Barnes and Nobel


Chief Counsel’s Report:

Macondo



also available in interactive
multimedia mode on web site


The Gulf Spill


A multimedia summary of the Commission’s findings
available on the web site


Summary Report:
Deep Water: Recommendations


Resources
:
Testimony, Correspondence, Research, Staff Working Papers

14

Reports


All available in PDF format from web site