Seeking to reduce “unnecessary regulatory burdens” while maintaining or advancing safety and environmental protection, the US Bureau of Safety and Environmental Enforcement (BSEE) plans to revise the Production Safety Systems Rule governing oil and gas production on the US Outer Continental Shelf (OCS), the agency reported today (28 December).
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| BSEE Director Scott A. Angelle |
The Production Safety Systems Rule addresses safety and pollution prevention equipment, subsea safety devices and safety device testing for OCS oil and gas production, which are critical for protecting offshore workers and the environment.
In 2016, BSEE published a final rule substantially revising 30 CFR part 250, subpart-H. Since the rule took effect on 7 November 2016, BSEE has become aware that certain provisions in the rule created “unduly burdensome requirements” for OCS operators, but didn’t significantly increase worker safety or environmental protection, the agency said in the document it plans to publish on 29 December in the Federal Register outlining the new regulations.
BSEE’s proposal (which can be read here) would primarily revise subpart-H – "Oil and Gas Production Safety Systems." Amendments to the rule would add gas lift shutdown valves to the list of safety and pollution prevention equipment (SPPE). It would revise requirements for SPPE to clarify existing regulations, and remove the requirement for operators to certify, through an independent third party, that each device is designed to function in the most extreme conditions to which it will be exposed, and that the device will function as designed. Instead, compliance with various required industry group standards – such as the American Petroleum Institute and American National Standards Institute – will ensure each device will function in the conditions for which it was designed.
The updated rules would clarify and revise some production safety system design requirements, including revisions for the requirements for piping schematics, simplifying requirements for electrical system information, clarifying when operators must provide certain documents to BSEE or update existing documents.
The new regulations also would clarify failure reporting requirements, requirements for Class I vessels, requirements for the inspection of the fire tube for tube-type heaters, and the requirement for notifying district managers before production begins.
BSEE said that the proposed regulations could reduce industry compliance burdens by at least US$228 million over a 10-year period.
The rule change is part of the Presidential Order issued by President Trump earlier this year to reduce “undue burden” on the US oil and gas industry to maintain the United States’ position as a global energy leader and foster energy security.
“It’s time for a paradigm shift in the way we regulate the OCS,” said BSEE Director Scott A. Angelle (pictured above). “There was an assumption made previously that only more rules would increase safety, but ultimately it is not an either/or proposition. We can actually increase domestic energy production and increase safety and environmental protection.”
In April this year, President Trump signed executive orders to increase energy production in the OCS planning area, including areas that former President Obama banned towards the end of his time in office. Trump aimed to increase production through a review of the OCS five-year leasing program and review of regulations put in place in 2016 that could reduce OCS exploration and development. That order also directed Secretary of the Interior Ryan Zinke to implement a streamlined permitting approach for private funded seismic data collection to determine offshore energy resource potential.
The proposed regulations will be available for public comment over a 30-day period.
National Ocean Industries Association (NOIA) President Randall Luthi said oil and gas safety experts would now have a chance to comment on the regulation. “This ‘second bite at the apple’ provides an opportunity for further dialogue, discussion and debate to assure the nation’s offshore energy resources are developed safely and expeditiously – as required by the Outer Continental Shelf Lands Act,” Luthi said.
Luthi added that NOIA members also look forward to commenting on other important offshore rules currently under revision.
The OCS, which includes the Arctic, Gulf of Mexico, and Pacific regions, produces more than 550 million bo/year and 13 Tcf/year of natural gas.
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