Deepwater Oil Exploration Drilling Safety: The Cuban Regulatory Approach Panel discussion: One Gulf - Drilling Offshore Cuba Fidel Ilizastigui Perez Process Safety/Risk Management Specialist Office of Environment and Nuclear Safety Regulation (ORASEN) Technical Support Division 2011
The Evolution Deepwater Oil Drilling Safety Regulation in Cuba: Lessons learned Before Yamagua Well (2002 2004) After Yamagua Well (2005 2010) After Macondo (2010 - present time)
Before Yamagua Well (2002 2003) The preparatory stage What is the challenge? What regulatory strategy to adopt? How to make it work? Mature regulatory regimes Prescriptive Self-regulation
The Big Challenge: To protect people and the environment by preventing major (organizational) accidents from occurring (i.e from events that occur 1/decades!!!) Type of regulatory strategy Influence on Safety Culture Prescriptive Poor Outcomebased Regular Process-based Good Safety Case approach to Regulation: UK Safety Case Regulations (SCR) 1992
The Safety Case regime The Operator must demonstrate to ORASEN, that: Major Accident Hazards (MAHs) are identified Risks have been evaluated and measures have been taken to reduce the risks levels to ALARP. There is an adequate SMS for process safety/integrity Adequate arrangements exist for audit of the SMS Compliance with national/international regulations
Yamagua -1 Exploratory Drilling 2004 Regulatory Guidance issued by ORASEN Guidelines for preparation of Risk Evaluation Report (RER) for Offshore oil drilling facilities 2002 (now superseded). Environmental Licence issued by ORASEN for deepwater drilling: 9 Risk Evaluation Report (RER) 9 Safety Evaluation Report (SER) 9 Licence conditions for deepwater drilling operations 9 Regulatory inspection to the drilling facility
After Yamagua 1: 2005-2010 Adoption of international best practices and modernization of Facility Safety Cases 2004 2009
Strengthening the Safety Case regime for major hazard facilities in Cuba - 2009 CITMA Resolution 132/2009 Rules for Environmental Impact Assessment Process Updates previous rules and introduces Safety Cases for Major Hazard Facilities in support of Environmental Licence applications for all MHFs for the commencing of operation. ORASEN Resolution 31/2009 Guidance for preparation of Safety Cases for drilling facilities for offshore oil and gas exploratory wells Establishes new requirements for Safety Cases according to IADC HSE Case guidelines (version 3.2).
Modernization of Safety Cases ORASEN encourages the use of Bow-Tie Risk Management Methodology as part of the Safety Case process: ¾ Increasing the value of the Safety Case for SC owners - i.e managers and workers. ¾ Ensuring SC remains a Living document. ¾ Allowing better regulatory oversight.
Modern Safety Cases reviewed by ORASEN Bow Ties for all MAHs SOOB Matrix (MOPO) Safety Critical Elements (SCEs) Performance Standards (PS)
After Macondo: 2010-? Well Integrity, Emergency Response, Safety Culture Oversight CITMA Resolution 73/2010 The Safety Case Addendum Introduces the Safety Case Addendum for Well Integrity issues; following US Well Construction Interfacing Document (WCID) recommendations. CITMA resolution (scheduled for 2011): Safety Case Regulation for Major Hazard Facilities which avoids piecemeal implementation. Delineates all the features of the Safety Case regulatory regime from cradle to grave.
The Safety Case Addendum (SCA) US Well Construction Interfacing Document (WCID) Part 1. Drillsite location and Well Basis of Design (BOD). 9Bow-Tie Risk Assessment and Management for Well Major Hazards Part 2. DC Safety Case and (Well) Operator interfacing arrangements 9Bridging Document (BD) Part 3. Action Plan and justification for commencing of drilling operations 9Assess compliance with US Interim Drilling Safety Rule
Environmental Licence for deepwater exploratory drilling operations in EEZ in the GOM Environmental Impact Study (EIS) Facility Safety Case (SC) Safety Case Addendum (SCA) + Disaster Reduction Plan (DRP) Civil Defense
Regulatory Pyramid LAW 81 (1999) CITMA Resolution No. 132/2009 ORASEN Resolution No. 31/2009 ORASEN Resolution No. 73/2010 National / International Safety Standards IMO, ISO, API
A consistent, sound and state-of-the-art regulatory framework for deepwater drilling safety One Gulf means for us: One COMMON interest: To protect people and the environment while conducting deepwater drilling operations in the GOM. One COMMON challenge: To prevent major accidents from occurring and limiting their consequences should they occur. One COMMON solution: To set up a consistent, sound and state of the art regulatory framework addressing Safety Culture aspects.
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