By Doug Foster, GM OTC Solutions
In the last e-newsletter we discussed operator exposures to regulatory compliance on blowout prevention systems. Often we find that the requirements in the regulation were not known nor understood by the operator and/or rig, which can make an Incident of Non-Compliance (INC) a nasty surprise. An operator’s reliance on equipment and trust in service providers to be fully compliant with all regulations can be a costly assumption.
These exposures increase with each vendor and sub-contractor added to a project, each one with their own understanding and implementation of regulatory requirements. We’ve seen various levels of effort placed on regulatory compliance assurance in our interactions. All vendors have integrated the regulation into their processes. However, too often the implementation is reactionary and only modified when an issue arises. As such, we continue to identify non-compliance issues on behalf of our clients, that have the potential to result in cost, loss of productivity and reputation damage.
Here are a few of the areas where we continually see gaps:
These gaps are not the result of ill intent on the part of equipment and service providers. The regulations and the incorporated documents for well control equipment consist of more than 1,225 pages of strict requirements. Even the best effort, without a full understanding of these requirements, will come up lacking given the amount of information. It is our opinion that equipment and service providers identify and acknowledge their understanding of the rules and regulations that apply to the equipment, personnel and services that they provide to clients and ensure that they have the appropriate measures in place to prove compliance.
Operators should have an expectation, through contractual language or other processes to confirm that their exposures are limited by assessing adherence during the provision of contractors.
OTC Solutions is committed to regulatory compliance for well control equipment and systems and available to support its clients in any way possible. For more information, contact OTC Solutions at (832) 463-5081.