2013IADC, Regulation, and LegislationMay/June


OSHA clarifies policy on drillers’ protective gear

OSHA issued the “Guidance on Handling Cases Developed Pursuant to the FRC Enforcement Policy Memorandum” to regional administrators and solicitors on 18 December 2012. It provides guidance on the 2010 enforcement memorandum that required oil and gas well workers to wear flame-resistant clothing (FRC) to protect against flash fires.

The guidance details OSHA’s policy stating that compliance staff should closely review operations where FRC is not in use to determine its necessity to protect workers against flash fires. A citation requires evidence that the employer had notice of the need for equipment.

To enforce the Personal Protection Equipment standard, an OSHA compliance officer must show that FRC is necessary to protect workers from hazards in their workplace. In the guidance, OSHA maintains that the October 2010 memorandum was not a significant rule change to the PPE regulation.

IADC and other associations still contend that it is, in fact, a significant regulatory change.

International Maritime Organization begins Deepwater Horizon casualty review

The International Maritime Organization (IMO) officially initiated its review of the Macondo incident during the 21st session of the organization’s subcommittee on Flag State Implementation on 4-8 March.

The group considered the marine investigation reports by the US and the Republic of the Marshall Islands related to the explosions, fire and loss of the Deepwater Horizon rig. Several issues and considerations were identified relating to fire protection, design and equipment, stability, training and oversight.

Pending endorsement by the IMO Maritime Safety Committee, the reports on the Macondo incident, as well as the analysis and comments of the subcommittee, will be forwarded to IMO technical subcommittees for more detailed review and action.

Alan Spackman, vice president of IADC’s offshore division, represented the association at the meeting. Warren Weaver of Transocean and Tom Horan of Rowan Companies also attended as members of the delegations of Vanuatu and the Marshall Islands, respectively.

Specific highlighted issues and recommendations forwarded for further consideration included provisions for fire protection, design and equipment, stability, training and oversight.

North sea countries reach agreement on safety standards

The Norwegian Oil and Gas Association, NOGEPA (the Netherlands), Oil and Gas UK, and Olie Gas Danmark (Denmark) worked to develop an agreement on safety training that has validity across borders.

In the agreement, signed 15 February, members agreed to recognize the safety training given in each of the other countries and to accept training schools and courses approved by the other national associations.

The goal of the groups is to develop a common standard that prepares the workforce to achieve a high level of competence in basic safety and emergency preparedness across northwest Europe.

Jens Hoffmark, IADC’s regional vice president for European operations, participated on behalf of the association in the National Oil Industry Associations workgroup that has been working to harmonize basic training in Holland, Denmark, UK and Norway.

Industry fights naming lesser prairie chicken ‘threatened species’

IADC has joined with industry association efforts regarding the possible listing of the lesser prairie chicken as a “threatened species” by the US Fish and Wildlife Service (FWS) under the Endangered Species Act. On 1 March, the associations sent comments to the docket listing a variety of concerns.

Should the lesser prairie chicken be listed, limits on drilling may be placed at well sites in Texas, Colorado, Kansas, Oklahoma and New Mexico.

This action has the potential to affect IADC members who drill in areas that are subject to the FWS regulations pertaining to the conservation of species and operate in areas identified as a lesser prairie chicken habitat.

IADC, along with API, the Independent Petroleum Association of America, Western Energy Alliance, New Mexico Oil and Gas Association, Panhandle Producers and Royalty Owners Association, Oklahoma Independent Petroleum Association and the Mid-Continent Oil and Gas Association of Oklahoma, is concerned with protecting the environment, and many members donate and assist in the protection of the bird’s habitat.

Clarity sought on US Foreign Corrupt Practice Act

IADC, along with 32 other organizations and associations, drafted a letter to the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC) on 19 February seeking clarity on the enforcement of the Foreign Corrupt Practices Act.

A Resource Guide to the US Foreign Corrupt Practices Act was issued on 14 November 2012 and provides a central source of information for compliance officers and others in regard to the views of the DOJ and SEC.

Signees requested that the established dialogue continue in order to address noted issues. They also asked for guidance regarding how compliance programs should be structured in order to merit favorable consideration in enforcement decisions.

API publishes new industry standards for drilling operations

API announced on 1 April the publication of two new oil and natural gas industry standards for well design and drilling operations.

The first, Deepwater Well Design and Construction, API Recommended Practice 96, provides engineers a systemwide reference for offshore well design, drilling and completion operations using subsea blowout preventers. It covers the range of considerations that must be taken into account when planning for and undertaking deepwater drilling operations, including:

Appropriate barrier and load case consideration to maintain well control;

Guidance supplementing API 65-2 on barrier philosophy and management of API 90 on annular pressure build-up; and

Risk assessment and mitigation practices for casing and equipment installation operations.

The second, Protocol for Verification and Validation of High-Pressure, High-Temperature Equipment, API Technical Report 1PER15k-1, establishes a process for evaluating equipment used in high-pressure and/or high-temperature environments both onshore and offshore.


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