Surely, we all agree that 20 April 2010 changed offshore drilling forever. Sadly, 11 men lost their lives and the United States struggled with its biggest pollution event and largest response effort ever.
One of the results was an unsettling introduction of a large amount of legislative proposals as well as hearings and investigations to determine the cause, undoubtedly multiple causes.
Interim measures, such as the drilling moratorium, with the noble intention of fully assessing and managing the risks of offshore drilling, lacked specific requirements, leading to continuing doubts of what steps should be taken to resume safe drilling. At the same time, industry and regulators both struggled with the rapidly developing offshore drilling technology, especially deepwater drilling, and both looked throughout the industry and global regulatory regimes for “best practices” to fully assess offshore drilling risks and safely continue offshore drilling and production. It became obvious that we needed to understand the entirety or risk making decisions that didn’t fully consider a range of unintended consequences.
US and Norwegian comparison
The Norwegian Oil Federation commissioned DNV to compare the US and Norwegian regulatory regimes to identify any areas in which offshore safety could be improved in Norway; it was simply to demonstrate the similarities and differences between the two regulatory regimes, using the Norwegian regime as starting point. At the same time, a debate was ongoing about whether the US would be best served with a prescriptive or performance based regulatory regime. This needs to be seen in combination with the more fundamental question about where responsibility and accountability for offshore safety really lands. There is an increased expectation that all safety risks are identified, fully assessed and suitably managed, something the operator is absolutely best positioned to do.
Position paper
Based on our insight, DNV has produced a position paper that presents our collective knowledge of regulatory regimes and global operations to answer the question of what are the key aspects of an effective offshore safety regime. We recognised that prescriptive and performance based regulatory regimes are not mutually exclusive. There should be a blend of both.
DNV supported the requirement for the safety case as a means to ensure the safe design and operation of offshore facilities. Documentation in the safety case shows that all applicable laws and standards are met and details the major risks. Safety cases further require that all risks are reduced to as low as reasonably possible. And most importantly, a proper safety case explains what procedures and actions will ensure that the risks, and the prevention and mitigation measures, are known and monitored throughout all operations.
Step change
Feedback shows that our position paper has been helpful to the industry. We think it is a sensible and practical proposal for an effective offshore safety regulatory regime that will lead to a huge step change in offshore safety, not just an incremental bump. We hasten to add that no single operation, company or regulatory regime has adopted all of our recommendations, but we are equally quick to point out that all of these are implemented somewhere in the world. We believe our position paper lays down the foundation for a new perspective on offshore safety.