While contentious arguments over new offshore drilling technology requirements and well control rules grab headlines, behind the scenes industry and regulators continue their quiet work on a culture of safety in offshore energy extraction.
This week will mark the sixth anniversary of the Deepwater Horizon drilling rig accident and the onset of the 2010 Gulf of Mexico oil spill. Post-spill reforms continue six years later, with the Department of the Interior and Bureau of Safety and Environmental Enforcement (BSEE) issuing well control rules and new regulations on blowout preventers, or BOPs.
BSEE and the industry have been engaged in a yearlong spat over the well control rules since the agency first opened the proposed regulations for public comment in April 2015. Industry worries that the new rules will prove too onerous and drive rigs out of the Gulf of Mexico (Greenwire, April 14).
Meanwhile, a lot of work is moving forward on safety and environmental management systems, or SEMS. Here, industry and regulators are proceeding much more harmoniously, people engaged in the efforts say.
"The SEMS is very much collaborative," said Brady Austin, a health, safety and environment consultant with Lloyd’s Register in Houston.
Work on SEMS was one of the earliest initiatives to move forward post-spill after the former Minerals Management Service was reorganized into three independent agencies: BSEE, the Bureau of Ocean Energy Management and the Office of Natural Resources Revenue.
Largely based on recommendations by the American Petroleum Institute, SEMS aims to steer the industry toward tight and highly regimented workplace safety management practices while trying to keep the initiative with the industry itself, rather than see industry forced to simply respond to the government’s commandments.
BSEE’s SEMS rules do place some mandates on companies.
For instance, offshore operators must submit to third-party audits of their SEMS program. Where auditors find problems, companies must tell BSEE what their plan is to come into compliance. SEMS aims to identify industry best practices and elevate these to requirements, formalizing what API and others deem as suitable safety standards, with BSEE playing an advisory role.
Officials contrast this to the well control and BOP rulemaking process, which is seen as a mix of top-down and collaborative work by BSEE but is viewed by industry as more prescriptive, as the well control rules require the use of specific technologies, like BOPs with double shear rams.
BSEE official Douglas Morris said in an email that the agency takes a different and lighter touch toward industry on SEMS.
"We view the well control rule as a hybrid rulemaking containing both performance based and prescriptive requirements," Morris explained. "We view SEMs as primarily performance based."
Lloyd’s Register, which has recently expanded its offshore equipment training capacity in Houston, is receiving certification to run SEMS audits. Austin agreed that the oil and gas industry and BSEE are on the same page with the direction of SEMS, which much less of the friction that’s evident in other BSEE rules application.
"When you’re dealing with technical issues, you can get technical," he explained. "But when you’re dealing with a management system, you have to stay at a high level, because every company does things differently, and even though they all work toward the same [guidelines] and understand what must be done, they’re not told how to do it."
Will contractors be included?
Austin says that major changes to SEMS are coming.
API is in the midst of revising its guidelines, known as Recommended Practice 75, or API RP 75. Institute representative Carlton Carroll confirmed that an update is in the works but couldn’t say when those revisions might be completed.
Meanwhile, the Center for Offshore Safety is said to be close to finalizing its own documentation on SEMS audits and compliance monitoring.
The Offshore Energy Safety Institute (OESI) is also playing a role that BSEE Director Brian Salerno described in an earlier interview as key to the ongoing review and improvement of SEMS practices. OESI is an industry-academia collaboration led by principals at Texas A&M University, the University of Houston and the University of Texas, Austin.
"We’ve asked them to hold a number of forums for us, which they have done," Salerno said. "There’s some additional work in terms of dialogue with industry that is on schedule."
Austin says one lingering uncertainty is whether the mandatory auditing requirement for operators will extend to contractors, as well.
Morris said BSEE doesn’t anticipate veering from the current approach, though it may not matter much if the auditing requirement is extended to contractors — Austin argues that the momentum suggests operators will require third-party SEMS audits of their contractors in their contract provisions regardless of whether BSEE mandates them.
"The operators are responsible ultimately for anything that happens on their lease or their operation," Austin said.
Austin said that contractors have nothing to fear from SEMS requirements or audits that operators may require of them, and that it makes sense to involve the contractors, as they vastly outnumber the offshore oil and gas companies that employ them and since contractors do most of the work in the Gulf of Mexico’s oil and gas fields.
Despite some uncertainty, he and others contend that industry and regulators are making great progress on enhancing offshore drilling and production safety management.
"SEMS rule and the implementation of the SEMS audits and industry participation in it is definitely improving things," Austin said. "Are we all the way there yet? No, and hopefully, we’ll never say that we’re all the way there yet because that’s when you get lax and complacent."