Offshore oil and gas producers and their contractors and suppliers had questions when the US Minerals Management Service issued new safety requirements in its June 8 notice to lessees. Judging by the number of e-mails from OGJ readers, the biggest of those involved independent, third-party certifications.
"Who is the 'Third Party' for independent verification?" one asked. "What constitutes a third party and how and by whom are the third parties certified?" another inquired.
Most trade association officials were equally befuddled. "There are a number of third-party inspection requirements," noted Andy Radford, senior policy advisor for offshore issues at the American Petroleum Institute. "There also are a lot of questions, starting with how the equipment would be certified. It seems indeterminate so far."
"As of [June 11], when our equipment subworking group met, it had no expectation from MMS about what the verification and certification requirements would be," Alan Spackman, vice-president for offshore technical and regulatory affairs in Houston, told OGJ that same day.
The National Ocean Industries Association, while saying that the notice offered some clarity as to which operators could move forward and under what conditions, said in a June 8 statement it was too soon to say how long it would take for firms to complete the required certifications.
Initial indications
OGJ subsequently learned that MMS considers a technical classification society; an API-licensed manufacturing, inspection, or certification firm; or licensed professional engineering firm as qualified independent third parties capable of verifying blowout preventer compatibility and blind shear ram capability.
Such a firm will need to be sufficiently capitalized, bonded, or insured; must not have a record of violating applicable laws or ethical guidelines; and be willing to sign a certification under penalty of law.
It also must allow an official MMS representative access on request to the place where tests and inspections take place, to verify the information submitted in the application, or to witness tests and inspections.
Open, with caveats
"It sounds as if they're leaving the door fairly wide open, but with a lot of caveats," said Spackman after hearing the clarifications. He said some drilling contractors hoped they could use classification societies such as the American Bureau of Shipping, while others hoped they could use professional engineering societies.
"It will take people who own the equipment and have that kind of material in front of them to determine what the verification requirements will be," he said.
Radford noted that API publishes recommended practices and specifications for equipment, some of which regulators incorporate by reference. "We recently published a document isolating potential flow zones, which deals with cementing practices and mechanical barriers. MMS was involved with the industry in developing that document," he said.
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