BOEMRE Proposes Additional Workplace Safety Rules for OCS

Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) Director Michael R. Bromwich Tuesday proposed a follow-up rule that further advances the purposes of the Workplace Safety rule, also known as SEMS, which requires operators to systematically identify risks and establish barriers to those risks to reduce the human and organization errors that cause many accidents and oil spills.

The follow-up rule, SEMS II, addresses additional safety concerns not covered by the original rule and applies to all oil and gas activities and facilities on the Outer Continental Shelf (OCS). SEMS II includes procedures that authorize any employee on a facility to stop work in face of an activity or event that threatens a person, property or the environment.

The rule also established requirements relating to the clear delineation of who possesses ultimate authority on each facility for operational safety; establishes guidelines for reporting unsafe work conditions that give all employees the right to report a possible safety or environmental violation and to request a BOEMRE investigation of the facility; and requires third-party, independent audits of operators SEMS programs.

"We believe these are reasonable, appropriate and logical extensions of our original SEMS rule," Bromwich said. "We look forward to the comments and suggestions of operators and other interested stakeholders as this proposed rule moves through the rulemaking process."

The SEMS rule and the Drilling Safety rule were created last October in response to the Macondo oil spill. The drilling safety rule created tougher news standards for well design, casing and cementing as well as well control procedures and equipment, including blowout preventers.

While many companies had developed SEMS systems voluntarily in the past, many had not, Bromwich said. Because the SEMS rule required substantial work by any operators, we delayed enforcement of the rule for a year. Operators will be required to comply with the rule starting in November.

The two rules introduced for the first-time performance based standards similar to those used by regulators in the North Sea. "In the immediate aftermath of the spill, we found that existing regulations had not kept up with the advancements in technology used in deepwater drilling," Bromwich said.

BOEMRE is in the final stages of completing its investigation into the Deepwater Horizon incident. Bromwich said the Deepwater Horizon tragedy highlighted the fact that the agency charged with enforcing regulations had three competing missions, including revenue generation, responsible energy development and safety and environmental enforcement. "It became clear that the agency had simply been asked to do too much with too little, and that there was inherent tension among the multiple missions it had been asked to fulfill," Bromwich said.

In 17 days, BOEMRE will cease to exist, and the Bureau of Ocean Energy Management and the Bureau of Safety and Environmental Enforcement will take its place. The creation of the new agencies separates resource management from safety and environmental oversight and allow permitting engineers and inspectors "who are central to overseeing safe offshore operations, greater independence, more budgetary autonomy and clearer focus."

Bromwich said BOEMRE is focusing substantial energy on making sure that those in the industry, the conservation community, and its sister federal agencies understand the coming changes when the transition for the restructuring of offshore energy management responsibilities is set for completion on Oct. 1.

With the new agencies, the government will extend its regulatory reach to include contractors as well as operators. "In my judgment, it is simply inappropriate to voluntarily limit our authority to operators if in fact we have authority that reaches more broadly to the activities of all entities involved in developing offshore leases."

Bromwich disputed criticism that the agency is "slow-walking" permits and plans, saying that the agency is reviewing and approving permits "as expeditiously as we can given our current resource," noting that employees have put in more than 1,350 hours of overtime reviewing plans and permits in the past six months.

"We understand that operators would like the permitting process to move more quickly," said Bromwich. "But that's very different from suggesting that there have been concerted efforts to slow things down."

American Petroleum Institute (API) Director Erik Milito said API would carefully review the proposed rules and look forward to continuing to work with BOEMRE to ensure that requirements for workplace safety, the environment and continued energy production are met. "Any additions to already intricate regulatory processes should allow for new exploration and responsible development of our domestic offshore energy resources without unpredictable barriers or delays."

Milito noted that the industry has taken steps to address offshore safety, including the creation of four joint industry task forces that provide positive recommendations to the government on how to improve safety through a systems-based approach. API and the International Association of Drilling Contractors also are jointly detailing Well Construction Interface Document Guidelines, which helps to improve safety by linking the management systems of offshore operators with those of drilling contractors.

API is also moving forward with the development of a standard on deepwater well construction, which provides practices that are intended to achieve a high level of total system reliability. Significant enhancements have been made to prevent and respond to a spill, and we have redundancies to ensure if one system breaks down, there are others in place, Milito said.


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David C. Berry | Sep. 14, 2011
While Mr. Militio and the API are to be commended for their work in the safety area, it is the observation of many effective safety professionals that systems-based aprroaches to safety do not work. Many of these systems are developed at senior management level, without input from either the employees or contractors who have to make the systems work. Further, safety-mangement-system audits are not conducted frequently enough to identify areas where improvement can be made. If audits were done on a regular basis, the system-taechnology gap would have been identified much earlier, and either narrowed or eliminated. I, for one, would much rather see a behavior-based safety program that included much more input from the employee (contractor) level. Only in this way will a program obtain total buy in from everyone affected by the program, and statistical data gathered from safety reporting will actually mean something - and be a tool for further improvement.

john weaver | Sep. 14, 2011
The political gamesmanship. How about dissolving the DOE since we have another group of (call them what you want) government employees.

Phil Landras | Sep. 14, 2011
The world of drilling offshore and production offshore is getting cluttered with too many organizations of which BOEMRE is one: API, OSHA, USCG, MODU, ANSI, ABS, DNV, DIN, SOLAR and more. All these regulatory bodies have one or more relevancies in the engineering of component associated with offshore installations. This can be the way to define the yield strength of base material, to the length of time the qualification test of materials. The safety factors are not necessarily unified. The survival design of installations may render an platform qualified for North Sea but not for GOM. It is understood that rules are a must, but zero risk does not exist. The bases for rules are to limit the cost of insurance liability. The insurance cost is based on design as per a particular regulatory body, and the design complying with DNV are more expensive than an ABS design. A DIN pipe is not an ANSI pipe, fabrication and tolerances are different. Material grade use in North Sea are not the same in the GOM although perform the same functions. All these regulations make design of installations more complex but not necessarily safer. Elements of all these regulations conflict with each other, choices have to be made which limit the geographical use of the installations, or the type of use. The bottom line is that cost of amortization goes up and zero risk is not achieved. Zero risk is the goal, and should be pursued. But there is a point where the cost benefit out weight the return. The real risk is with the decisions made by men. The Macondo oil spill was caused by poor man made decisions which caused the equipment to malfunction. Or better yet, men made the decision to knowingly continue with a component needing repair, for the sake of saving money. Since zero risk is impossible, the management should be insured like PE are. Managers vice president, the big decision makers should be insured for an amount equal to the potential disaster their decision will potentially cause. The business aspect in the decision making will take a back seat. This would be in addition to the company insurance. The control of risk is as good as the man making the decision. You hope that honesty still exist.

Adam | Sep. 14, 2011
Wow Mr. Bromwich! You aren't dragging your feet on permits you say?! Let's do the math on 1350 hrs of overtime in 6 months...that equates to 7 people in the entire BOEMRE staff working 1 extra hour per day! That's not too much to ask someone working a 40 hr work week in the office to get production/exploration/drilling going again in the Gulf of Mexico.

Travis Mathews | Sep. 14, 2011
I think being safe is a good idea. But a government entity isn't going to do squat


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