BSEE Introduces New Offshore Safety Rule

U.S. Bureau of Safety and Environmental Enforcement (BSEE) Director James Watson yesterday announced another key step to strengthen both human safety and environmental protection on the U.S. Outer Continental Shelf.

The proposed rule, which will be published in the Federal Register today, implements best practices and updates regulations regarding production safety systems and equipment used to collect and treat oil and gas from offshore production facilities.

“Our guiding focus throughout the development of this proposed rule has been and will continue to be worker safety and protecting the marine and coastal ecosystems by helping to reduce the number of production incidents resulting in oil spills, injuries and fatalities,” said Director Watson. “The commonsense changes we are proposing, which will address issues such as production safety systems, subsurface safety devices and safety device testing, will help regulations keep pace with changing technologies that have enabled the industry to explore and develop resources in deeper waters. The rule also implements best practices currently being deployed by industry leaders as we continue to strive for safety at all levels, at all times.”

The proposed rule will revise 30 CFR 250 subpart H, Oil and Gas Production Safety Systems, to address recent technological advances. This section of the regulations has not had a major revision since it was first published in 1988. During that period, industry’s use of subsea trees (the assembly mounted on a well head used to control the flow of oil and gas) and other technologies have evolved or become more prevalent offshore. These devices and materials include foam firefighting systems; electronic-based emergency shutdown systems; subsea pumping, waterflooding, and gaslift; and new alloys and equipment for high temperature and high pressure wells. The proposed rule ensures that the regulations governing their use and maintenance are keeping pace with industry’s advancements and that they address these newer and emerging safety technologies.

Proposed Changes in the Rule

The proposed Subpart H revisions will:
• Completely restructure Subpart H to have shorter, easier-to-read sections, address
specific operating requirements for subsea production systems, and update and expand
the industry technical standards that are incorporated by reference;• Contain regulatory language concerning the use of best available and safest
technology that is consistent with the Outer Continental Shelf Lands Act’s statutory
mandate;
• Clarify the operator’s regulatory obligations related to life cycle analysis of critical equipment. Life cycle analysis is the control and traceability of a wide range of activities during the service life of the equipment ranging from design verification to repair and maintenance. The requirements have previously been included in standards that were incorporated by reference into BSEE regulations;
• Add rigorous design and testing requirements for boarding shut down valves, as they are the most critical component of the subsea system. These valves allow hydrocarbon flow to a facility to be stopped in an emergency. These new requirements will ensure the maximum level of safety for personnel located on the production facility;
• Add new inspection and repair requirements for tube type heaters. These heaters are used in the treatment process to help to separate water and oil. Failure of this equipment to be properly inspected and maintained has resulted in several incidents in recent years;
• Prohibit the installation of new single bore production risers from floating production facilities. BSEE believes that this technology does not provide an acceptable level of safety since the integrity of the riser may be compromised when operations are performed;
• Codify existing BSEE policy and guidance related to deepwater production equipment and systems to make sure they represent best practices, that the regulatory process is transparent, and that the requirements are enforceable;
• Require that documentation/schematics are certified by registered professional engineers (based on the Atlantis investigation); and

• Increase approved leakage rates for certain safety valves to ensure consistency with industry standards and to reduce risks created by replacing these valves in deepwater and subsea applications.

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Press Release, August 22, 2013