In response to the 2010 Macondo incident the US Federal regulations for the Gulf of Mexico (GOM) underwent several significant revisions. The two primary revisions were the Workplace Safety Rules, which put in place the current Safety and Environmental Management (SEMS) regulations, and the Drilling Safety Rule, which regulates the use of BOP and diverter systems. The Drilling Safety Rule mandates the independent third party verification of the “fit for purpose” status of any BOP or diverter system to be used in the GOM. The Bureau of Safety and Environmental Enforcement (BSEE) was created as the federal agency responsible for the enforcement of these new regulations.
Since the Drilling Safety Rule went into effect, owners and operators in the GOM have been attempting to understand which independent third parties are qualified to perform the verifications required under the regulations. To clarify any potential confusion surrounding this rule, it is important to understand that BSEE does not “certify” third party verifiers. Any independent third party that can demonstrate the “experience and expertise” required to perform the verification is qualified to do so under the federal regulations.
BSEE formally clarified their intentions in the final rule, published in the Federal Register (Vol. 77, No. 163/Wednesday, August 22, 2012). In their response to a comment requesting BSEE limit the qualified third parties to technical classification societies, BSEE’s response was as follows:
Section 250.416(g)(1) allows registered professional engineers, or a technical classification society, or licensed professional engineering firms to provide the independent third-party verification.
Section 250.416(g)(2)(i) requires the operator to submit evidence that the registered professional engineers, or a technical classification society, or licensed professional engineering firms or its employees hold appropriate licenses to perform the verification in the appropriate jurisdiction, and evidence to demonstrate that the individual, society, or firm has the expertise and experience necessary to perform verifications. BSEE may accept the verification from any firm or person that meets these requirements. We will not require the exclusive use of technical classification societies at this time.
The specific regulation describing the requirement for independent verification of the BOP and diverter system can be found in the Code of Federal Regulations (CFR) Title 30, Chapter II, Subchapter B, Part 250, Section 416 (30 CFR § 250.416). This regulation mandates that the BOP and diverter descriptions submitted to BSEE include independent third party verification, which shows that:
- “The blind-shear rams installed in the BOP stack are capable of shearing any drill pipe (including workstring and tubing) in the hole under maximum anticipated surface pressure.”
- “The BOP stack is designed for the specific equipment on the rig and for the specific well design;”
- “The BOP stack has not been compromised or damaged from previous service;”
- “The BOP stack will operate in the conditions in which it will be used”
The regulation also describes the qualifications for the independent third party as well as the evidence that must be submitted to BSEE:
“The independent third-party in this section must be a technical classification society, or a licensed professional engineering firm, or a registered professional engineer capable of providing the verifications required under this part.”
You must also:
“Include evidence that the registered professional engineer, or a technical classification society, or engineering firm you are using or its employees hold appropriate licenses to perform the verification in the appropriate jurisdiction, and evidence to demonstrate that the individual, society, or firm has the expertise and experience necessary to perform the required verifications.”
BSEE’s intentions here are clear. The regulations are written specifically to allow you to chose the most qualified independent third party to perform your BOP and diverter verifications. With the increasing dependence on integrated systems and automation, it is important that you select an independent verifier that views the BOP and diverter as integrated systems and can evaluate their fit for purpose status as a system.
Athens Group Services’ systems engineering approach, backed by our proprietary Proven Practices methodology and extensive regulatory checklist database provide you with the most comprehensive BOP and diverter systems verification available today. Our experience and expertise exceed the BSEE requirements and help ensure that you get a BOP and diverter system that passes the regulatory bar and meets or exceeds your internal safety, performance, and reliability requirements.
To request the new Athens Group Services white paper on this very important topic, please send a request via our Contact Us Page. The white paper will be available in early January 2015.