In our December newsletter, we described how the US Code of Federal Regulations for drilling in the Outer Continental Shelf allows significant flexibility in choosing an independent third party to provide the BOP inspection and verification as required for the Application for Permit to Drill (APD). In selecting that qualified third party, it is important to consider that the regulations have a limited scope, focus only on a small number of BOP component specifications, and an undefined generic requirement that the BOP be “fit for purpose.”
The scope of the regulations is intended to ensure the BOP has the capability to act as the last barrier of protection in the event of a loss of well control. The goal is to prevent harm to people and the environment. While this is without question an important and necessary goal, it is only one of many goals you should have for your overall well control equipment (WCE) system.
In addition to the regulatory compliance of the BOP, you should also be concerned about the operational performance of the WCE system and its ability to function in a way that supports your safety, operational, and business goals. This is known as your operational framework. Ensuring the WCE system meets the requirements of your operational framework is well outside the scope of the federal regulations for BOPs.
Inspections and verifications that are limited to meeting regulatory requirements alone do not include any consideration of the operational framework requirements that the WCE system must meet in order to ensure a safe and effective drilling operation. Thus, it is important that you select an independent third party that understands this and can implement an inspection and verification program that meets both the federal regulatory requirements as well as the requirements of your own operational framework. Compliance to regulations should be a byproduct of a well designed and executed program to ensure WCE operational framework quality.
In choosing an independent third party partner for WCE inspections and verifications, we recommend you look for:
- A Systems Engineering approach that encompasses functional and operational verification of the equipment and related components (i.e., cover BOP and all interfaces to Riser, ROV, Choke Manifold, Diverter, Positioning System, Drilling Control System, etc.). The approach should focus on improving the WCE system effectiveness, which includes safety, reliability, availability, and efficiency.
- Proven inspection and verification tools such as a comprehensive regulatory database and knowledge base to effectively assess the full operational framework for the equipment (e.g., Preventive Maintenance Inspection and Test Program, Critical Spare Inventory Management, Supply Chain Management, etc.) and provide measurable recommendations based on industry best practices.
- Verification that the equipment not only conforms to the regulations, but also fulfills the requirements of your operational framework and is functionally ready to drill the well,
Finally, don’t confuse federal regulatory requirements for the APD, or your own operational and business requirements with marine class inspection issues. Inspection/verification for class is usually done only to ensure that the equipment still retains the original design capability verified when the class certificate was issued. Regulations require the BOP be fit for purpose. Your operational framework requires the WCE system satisfy operational and business requirements. Neither of these is addressed by a class inspection that verifies the BOP to original design specifications.
You don’t want to engage an independent third party that just visually inspects the BOP and available documentation to produce a checklist. Make sure the independent third party you select is verifying compliance with both regulatory and operational requirements, and is willing to work with your internal and supplier teams to provide you with meaningful solutions and improvement opportunities.
To request the new Athens Group Services white paper on “Choosing the Right BOP Verifier,” please send a request via our Contact Us Page. The white paper will be available in early February 2015.