OISDOISD
Decisions of meeting chaired by Secretary- P&NG on 16.09.05
• OISD assigned the safety of all oil & gas installations including offshore & PSC.
• P&NG rules under ORDA to be amended accordingly
BACKGROUND
OISDOISD
• Second meeting held by Secretary-P&NG on 07.03.06
• Draft Zero of offshore safety rules presented
• The Rules circulated to concerned ministries for comments
BACKGROUND
OISDOISD
• Legal consultant hired by OISD • Vetted by PSA Norway, MMS USA • Comments sought from Ministry of Labour,
Shipping, MOEF, MEA and MOD• Comments sought from operating
companies• After incorporation of suggestions & final
legal drafting the rules will be sent to Law Ministry
METHODOLOGY OF FRAMING THE RULES
OISDOISD
• Use of simple language in place of legal
jargon to the extent possible
• Control by means of goal setting requirements
• Detailed and specific rules may dilute the operator’s perception of responsibility towards safety
MAIN PRINCIPLES
OISDOISD
• The operator i.e. user of facility must
identify the problem areas and work out solutions
• Responsibility towards safety lies with the operator
• The operator is responsible for compliance of rules by his contractors
MAIN PRINCIPLES
OISDOISD
• Risk shall be identified in a systematic
manner and shall be reduced to an acceptable level (ALARP)
• Risk acceptance criterion to be set by the operator for his facility
• Acceptance criterion shall be limited to high level expressions of risk (Global risk estimates)
MAIN PRINCIPLES ….contd
OISDOISD
• Consent for operation required to ensure compliance
• Safety issues addressed from design stage to abandonment
• Probability reducing measures have been given priority over consequence reducing measures
MAIN PRINCIPLES ….contd
OISDOISD
Concept of barriers:
1. The operator shall establish strategies and principles so that the barriers are ensured for the lifespan of the facility
2. Barrier elements can be physical, organisational or operational
3. It shall be known at all times what barriers are non-functional or impaired
MAIN PRINCIPLES ….contd
OISDOISD
I Preliminary
II Principles Related to Health, Safety and
Environment
III Information and Records
IV Consent and Intimation
V Risk Management
VI Safety Management
CHAPTERS
OISDOISD
VII Health and Welfare Measures
VIII Transport and Stay
IX Safety Zones
X Emergency Response System
XI Facilities - Design
XII Facilities – Physical Barriers
XIII Operational Pre-requisites
CHAPTERS
OISDOISD
XIV Planning and Conduct of Activities
XV Working Environment FactorsXVI Drilling and Well ActivitiesXVII MaintenanceXVIII Specific OperationsXIX Marine Facilities and OperationsXX EnvironmentXXI Miscellaneous
CHAPTERS
OISDOISD
Comments OISD response
1. Generic & not specific
2. Competent authority –OISD
3. Penal provision
4. Definition of operator
• Goal setting approach
• Roles, respo. etc shall be notified
• As per MZI & ORDA act
• Operator refers to company
Hardy Exploration & Prod(India) Inc
OISDOISD
Comments OISD response
5. Compliance to class & flag state requirements
6. SOLAS, MARPOL
7. Too many Schedules
8. Periodic reports
• OMR (DGMS)
• Rule 30 & Rule 1(3)
• Rule 1(3) & 1(4)
• Considered optimum• Noted- will be
reviewed• Applies to onland &
territorial waters
Hardy Exploration & Prod(India) Inc
OISDOISD
Comments OISD response
1. Acco.capacity not to exceed
2. Survival suits & Life jackets
3. Periodic audit of examination of
emer.resp.eqpt4. To include all
contractors for PPE use
• Rule 50-No change
• Implied in rule 77
• Rule 37
• Noted –will be reviewed
Schlumberger Asia Services Ltd
OISDOISD
Comments OISD response
5. Special baskets, certification & night transfer
6. To include lifting eqpt certification
7. Trained crane operators
8. Hygiene concerns9. Accounting of
persons
• Rule 169(4) & Rule 175(2)
• Rule 169(1) read with rule 37
• Implied in Rule 129
• Rule 42• Rule 49
Schlumberger Asia Services Ltd
OISDOISD
Comments OISD response
1. Safety agency should be independent of the administrative ministry
Therefore Regulation of safety should be by agency other than OISD
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ONGC
OISDOISD
Comments OISD response
2. Agree to consent to operate, how ever time period be increased to 2 years from 180 days for existing installations
3. Consent for Combined opn’s not feasible
• Increased to 1 year (draft 2). Will be further reviewed
• Changed to Intimation (Draft2)
ONGC
OISDOISD
Comments OISD response
4. One time combined operations consent for specific cases
5. Certificate of Fitness
a. For existing inst. time period to be extended
b. Reputed third party
• Noted-will be reviewed
• Increased to one year (draft 2).will be further reviewed
• Operator to decide as safety is his responsibility
ONGC
OISDOISD
Comments OISD response
6. Dual regulatory regimes
a. OISD & MOEF
b. OISD & DGCA
c. OISD & DG shipping
d. OISD & DGMS
• Clarified in Draft 2 • No overlap• No overlap• Overlap in
territorial waters only
ONGC
OISDOISD
Comments OISD response
7. Legislation should be dynamically linked to global industry recognised standards like API, IMCA, NFPA, SOLAS etc
ONGC
• Shall be done wherever considered appropriate
OISDOISD
Comments OISD response
1. Combined operation definition to include construction also
2. Launchers and receivers should be included in offshore facilities rather than pipeline
NIKO RESOURCES
• Noted –will be included
• No change
OISDOISD
Comments OISD response
3. Risers to be considered up to last isolation valve in the pipeline
4. Notice of accident- to add in 12(e) whereby safety of a person or facilities likely to be endangered
NIKO RESOURCES
• No change
• Noted-will be reviewed
OISDOISD
Comments OISD response
5. Barriers shall be commensurate with the probability and consequence of the incident
6. Criteria for certificate of fitness must be defined
NIKO RESOURCES
• Rule 23(1)
• Fit for the purpose as per rule 30(1)
OISDOISD
Comments OISD response
7. Delete maintenance of communication equipment from responsibility of desig person
8. Include inspection with maintenance in rule no 107(2) on pipeline
NIKO RESOURCES
• Noted-will be deleted
• Noted- will be included
OISDOISD
Comments OISD response
1. Operator in different areas- contractor or company man
2. Operator to pay cost incurred on instrumentation
3. OIM is company or contractor man
• As per definition- drilling contractor is operator
• Clause will be reviewed
• Contractor man in case of a drilling contractor
Transocean Offshore International
OISDOISD
Comments OISD response
4. Onboard Safety Officer - not in existing contracts
5. Safety committee meeting participation and acceptance
6. Equivalent of BIS IS: 10500 for potable water
• Will follow once rules come into force
• Implied in Rule 34
• Noted- will be reviewed
Transocean Offshore International
OISDOISD
Comments OISD response
7. Helicopter coverage at all times
8. Standby vessel to be shared by maximum two installations
9. Survival suits not required
• Not covered in rules
• No change in rule 63
• Noted- will be changed
Transocean Offshore International
OISDOISD
Comments OISD response
10.Drilling and well activities chapter to be replaced by IADC guidelines
11.BOP etc to be overhauled as per API
12.Communications during Lifting operation
• No change
• Noted- will be reviewed
• Noted- will be reviewed
Transocean Offshore International
OISDOISD
Comments OISD response
13. Identification of rough weather conditions by company or contractor
• Contractor is operator as per definition in case of hired rig
Transocean Offshore International
OISDOISD
Comments OISD response
1. Regulatory expectation of word competence
2. List of monitoring parameters
3. Metocean data
• In absence of definition, dictionary meaning to be followed
• Operator to decide
• Clause will be reviewed
BG India
OISDOISD
Comments OISD response
4. Notice of accident –personal injuries & asset damage
5. Decommissioning guidelines
6. Application for consent
• Noted-will be reviewed
Rule 12 f• Noted –will be
provided
• Rule is explicit
BG India
OISDOISD
Comments OISD response
7. Material changes
8. ALARP – Rule 22(5) compliance
9. Trainings for offshore going employees to be specified
BG India
• Significant changes
• Yes for rule 22
• Rule 129
OISDOISD
Comments OISD response
10.Certificate of fitness
11.Safety officer and safety committee rules to be deleted
BG India
• Installation to be fit for the purpose as per rule 30(1)
• No change
OISDOISD
Comments OISD response
12.The competent person should be trained as HLO
13.Safety Zone to be increased
14.Safety zone area must be avoided for navigation
BG India
• Rule 129
• No change for time being
• Rule 52(2)
OISDOISD
Comments OISD response
15.Monitoring of safety zone –visual or electronically
16.Standby vessel for each field in place of installation
17.Survival suit not required
BG India
• Operator to decide
• No change
• Noted –will be changed
OISDOISD
Comments OISD response
18.Damage to subsea facilities by activities with high probability of occurance
19.Probability of occurance of single mistakes should be considered
BG India
• Noted-will be reviewed
• Implied in 82(c)
OISDOISD
Comments OISD response
20.Two independent communication facilities may not be available in temporary manned facility
21.One valve of christmas tree to be remotely operated may be dropped
BG India
• Noted-will be made compulsory only for manned facilities
• No change
OISDOISD
Comments OISD response
22.Guidance document will be required for lighting & radiation
23.Add- or pipeline systems shall have sufficient protection to mitigate the risk from these operations
BG India
• Noted-will be provided
subsequently
• Noted-will be modified
OISDOISD
Comments OISD response
24.Rule no 121 on Fire water supply includes unattended platforms
25. In some cases living qtr is a bridge & fire division as per rules 115/116 is not required
BG India
• Yes
• Noted-rule 116 will be modified
OISDOISD
Comments OISD response
26.Minimal offshore facilities such as well head platforms may be separated from main facilities with regard to fire and gas detection system
BG India
• No change
OISDOISD
Comments OISD response
27.Automatic activation of deluge in case of gas detection may be hazardous
28.Rule 149(4)- if a barrier fails no other activity shall take place in the well than those to restore the barrier
BG India
• Noted-will be reviewed
• It applies to all well operations
OISDOISD
Comments OISD response
29.Rule 153(4) applies to those well interventions before permanent tree is installed
30.Eqpt. & procedure for detecting & assessing actions of vessels intruding in the safety zone
BG India
• Yes
• Operator is free to decide
OISDOISD
Comments OISD response
1. Who sets the acceptance criterion
2. Accidental loads – not possible to quantify all
Premier Oil
• The operator as per rule 28(7)
• Agreed but these are required to be determined to best possible accuracy
OISDOISD
Comments OISD response
3. By giving consent competent authority accepts responsibility for the design, operation and ER of the operator
4. Security of installation should be added to rule 3
Premier Oil
• Responsibility is covered in rule 7(1)
• Covered by other existing rules of GOI
OISDOISD
Comments OISD response
5. There is no definition of competence in rule 4(2)
6. Rule 6 -offshore clinic can not offer curative services from all ailments
Premier Oil
• In absence of definition, dictionary meaning shall be followed
• Routine curative services only
OISDOISD
Comments OISD response
7. Not possible for future employees to contribute to HSE matters in design of a facility
8. Information and records required are not defined
Premier Oil
• Obviously
• Not intended to make rules prescriptive
OISDOISD
Comments OISD response
9. There should be some cut off time for maintenance of information & records
10.Rule 10 is to allow operation of new installation
Premier Oil
• Rule 9(5)• Agencies as per rule 8
• It is an intimation only by the operator
OISDOISD
Comments OISD response
11.Time period of 90 days is unrealistic for small unmanned installations design review
12.Schedule II should not include design information of Sch I
Premier Oil
• Noted-will be reviewed
• No change
OISDOISD
Comments OISD response
13.For a drilling rig, total lead time of 5 months to drill a well is not viable
14. In case of combined operations –Sch IV/V and Sch VI are to be submitted
Premier Oil
• Noted-will be reviewed
• Yes
OISDOISD
Comments OISD response
15.Rule 22(4) & (5) appear contradictory
16.Rule 23- all concerned may include onshore support persons
17.Rule 28- SMS should refer to OHSAS 18001
Premier Oil
• Not contradictory but complimentary
• Yes
• Operator to decide
OISDOISD
Comments OISD response
18.National performance standards w.r.t objectives
19.Rule 28(6)-accordance between operator and other participant requirements
Premier Oil
• Will be considered at a later time
• Other participant means his contractors and service providers
OISDOISD
Comments OISD response
20.Rule 28(7)-setting of acceptance criteria
21.Rule 30-certificate of fitness
22.Rule 31- information requirement is wide ranging
Premier Oil
• Operator to decide• Competent authority
may stipulate on case to case basis
• Installation to be fit for purpose as per rule 30(1)
• As required for planning & conduct of petroleum activities
OISDOISD
Comments OISD response
23.Rule 39-authorities to have training before going offshore
24.Rule 46-Maximum no of days offshore in one tour
25.Additional persons onboard
Premier Oil
• Noted-will be reviewed
• Noted-will be reviewed
• Rule 50(3)
OISDOISD
Comments OISD response
26.Rule 52- Intrusion into safety zone
27.Rule 59-assessment of vessel traffic and announcement of safety zone
28.Rule 64(2)- coordinat-ion of em. prep. In handling of situations
Premier Oil
• Noted-will be reviewed
• Not covered• Rule 59(2)
• No change
OISDOISD
Comments OISD response
29.Rule 67-operator to make his best endeavours
30.Rule 80-unacceptable risk may be defined
31.Rule 82(b)-risk reduced to as low as practically possible
Premier Oil
• Implied
• Operator to decide
• Noted-will be changed to ALARP
OISDOISD
Comments OISD response
32.Rule 86(1)a implies failsafe
33.Rule 87-suggests quantitative limits for loads
34.Rule 93-monitoring equipment for verification schemes
Premier Oil
• Implies limited possibility of human error
• Noted-will be reviewed
• No change
OISDOISD
Comments OISD response
35.Rule 103- weather limit for basket transfer
36.Rule 129(4)-necessary trainings
37.Rule 138-permit to work
Premier Oil
• Rule 175(2)
• Goal based approach
• Noted-will be reviewed
OISDOISD
Comments OISD response
38.Rule 162-classification system for identifying maintenance regimes
39.Rule 164- extent of inspection not defined
Premier Oil
• Implied in rule 162
• Operator to decide
OISDOISD
Comments OISD response
1. Clearance /time schedule
2. Combined ops. to include time comp.
3. Mapping results-not clear
Cairn Energy
Noted-will be reviewed
Noted- will be incorporated
It is quite explicit
OISDOISD
Comments OISD response
4. Reporting of accidents to be streamlined
5. Off-site Emergency Response Plan
6. Identification of
Off-shore Installations
Cairn Energy
As per regulatory frame work
Operator will have to take lead in its preparation
No change
OISDOISD
Comments OISD response
7. OIM, Safety Officer and Safety Committee for Offshore facilities
8. Supervisory Authority
9. ‘Qualified Medical person’ to include paramedics also
Cairn Energy
Offshore facilities here imply manned facilities and associated unmanned facilities
No Change
Noted – will be reviewed
OISDOISD
Comments OISD response
10.Competent person for controlling helideck operation
11.Annual probability – rule 82 (3) – less than
12.Status of safety devices- not clear
Cairn Energy
It would be on manned facilities
No change
Status means ops./non ops./bypassed
OISDOISD
Comments OISD response
13. Instrumentation for monitoring structural integrity
14. Two independent warning methods to shore
15. Launchers and receivers- automated fail safe mechanism would be expensive/ difficult retrofitting
Cairn Energy
No change
Shall be for permanently manned facilities
Noted – will be reviewed
OISDOISD
Comments OISD response
16. Warning system where gas released as extinguishing medium
17. Open drain system Vs closed drain system
Cairn Energy
Noted-will be incorporated
No change
OISDOISD
Comments OISD response
18. Pipeline monitoring within two years of installation-to be reviewed
19. Form-III - particulars of the deceased to be included
Cairn Energy
Rule 164 (5) mentions (first) inspection and not monitoring
Noted for incorporation
OISDOISD
Comments OISD response
20.Discharge point for produced water-marine out fall
21.Treatment system for collecting and treating open drainage in prod. plants
Cairn Energy
Implied in rule 106(4)
Noted- will be reviewed
OISDOISD
Comments OISD response
Cairn Energy
22. Pre-surveys- safe distances from environmental sensitive receptors
23. Consent to operate under air and water Acts
Implied in rule-127
Covered in rule
1 (4)
OISDOISD
Comments OISD response
It is in domain of MOEF
Covered under rule 1(4)-however will be reviewed for inclusion under rule 178
Cairn Energy
24. Offshore environmental monitoring protocol development
25. Off-shore disposal of drill cuttings and drilling mud
OISDOISD
Comments OISD response
It is explicit
There is no overlapping
Draft definition to be retained
IOCL
1. Rule-30 Verification of fitness
2. Rule 7(3)-Overlapping of responsibilities of operator and licensees/lessees
3. Definition of Competent person to be as per Petroleum Rules
OISDOISD
Comments OISD response
1. Chapter –I
2. Chapter –II
3. Chapter –III
para 1
para 2
Reliance
• Under consideration of Govt
• Noted-will be reviewed
• Operator to decide• Noted-will be reviewed
OISDOISD
Comments OISD response
4. Chapter –IV
para 1
para 2
para 3
para 4
para 5
para 6
Reliance
• Goal based approach• Relevant rules• It is one time consent• Noted-will be reviewed• Noted-will be reviewed• One time consent
OISDOISD
Comments OISD response
5. Chapter-VIpara 1para 2
6. Chapter –VII7. Chapter-VIII
para 1para 2
8. Chapter IX
Reliance
• Operator to decide• No change• Goal based approach
• Rule 92• No change• Beyond scope of
these rules
OISDOISD
Comments OISD response
9. Chapter-Xpara 1para 2para 3
10.Chapter –XI
11.Chapter-XII
Reliance
• Goal based approach • No change• No change• Covered & implied in
rule 79• Noted-will be reviewed