Advocacy

IADC is the voice of the drilling industry, facilitating impactful advocacy across the growing number of countries where drilling operations take place.

With staff in place across the world, IADC is at the forefront of influencing sensible and fair regulations for the drilling industry.

Engaging with government officials and regulators, IADC strives to develop ongoing dialogue on issues critical to the industry and advocate for better regulatory practices.

Documents

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Date Material Posted Subject
14 February 2017 IADC response to Australian Tax Office consultation on Transfer pricing and profit attribution guidance in relation to foreign resident vessels operating in Australia and cross boarder asset leasing
16 February 2017 IADC Comments Supporting Joint Trade Letter Regarding BSEE Proposed Rule on Cost Recovery Fees
8 February 2017 Trade Letter to Majority Leader McConnell and Democratic Leader Schumer Regarding Support for the Commercial Vessel Incidental Discharge Act (CVIDA)
6 February 2017 Trade Letter to Majority Leader McConnell and Democratic Leader Schumer Regarding Support for the Regulatory Accountability Act of 2017 (RRA)
12 December 2016 Congressional Letter to Department of Interior and Commerce Concerning BOEM Draft Programmatic Environmental Impact Statement for Gulf of Mexico Geological and Geophysical Activities
8 December 2016 Congressional Letter to the President Objecting to Withdrawal of Acreage in the Arctic Planning Areas of the OCS
15 November 2016 Trade Letter to Majority Leader McConnell and Democratic Leader Reid Regarding Support for the American Energy and Conservation Act of 2016
30 September 2016 30 September 2016 – Congress Letter to Schmahl on Flower Garden Banks NMS Final Signed
19 September 2016 IADC Comments to the Coast Guard’s July 15, 2016 Federal Register Notice on the Marine Safety Manual Volume III Update
9 September 2016 20160906 IADC comments to docket USCG-2016-0640 regarding OCS Risk-based Resource Allocation Methodololgy
6 September 2016 Vida Coalition Letter to SASC HASC
19 August 2016 Joint Trade Association Comments on Draft Environmental Impact Statement Flower Garden Banks NMS Proposed Expansion
28 July 2016 Joint trades (ECSA, IADC & IMCA) letter to EC’s Joint Research Centre on proposed extension of the ATEX, Machinery and Pressure Equipment Directives to MODUs
Joint Research Centre response to joint trades letter (14 September)
22 July 2016 USCG Final Rule on Harmonization of Standards for Fire Protection and Extinguishing Equipment
IADC comments to USCG-2012-0196 Harmonization of Standards for Fire Protection, Detection and Extinguishing Equipment
15 July 2016 Final BOEM Air Quality Rule – Signed
14 July 2016 Drill Bits House Interior Appropriations Vote with amendments
21 June 2016 20160620 Joint Trades (API, IPAA, OOC, NOIA, IADC, OMSA) comments to docket BOEM-2013-0081 regarding Air Quality Control, Reporting and Compliance
20160620 IADC comments to docket BOEM-2013-0081 regarding Air Quality Control, Reporting and Compliance
201606 BOEM Presentation on the Air Quality Modeling in the GOMR Study
16 June 2016 Joint API, IADC, IPAA, NOIA, PESA, AXPC, IAGC and USOGA comments on the Proposed Outer Continental Shelf Leasing Program for 2017-2022
27 May 2016 Joint API, IADC, IPAA, NOIA, PESA, and USOGA request to BSEE for interpretation of the BSEE Blowout Preventor Systems and Well Control Rule
8 April 2016 Joint API, IADC, IPAA, NOIA, OOC, PESA and USOGA letter to OMB/OIRA regarding the proposed BSEE Blowout Preventer Systems and Well Control notice of proposed rulemaking
7 March 2016 IADC letter to the Office of Information and Regulatory Affairs (OIRA) of the Office of Management and Budget regarding the EO 12866 review of the BSEE Blowout Preventer Systems and Well Control
16 July 2015 IADC response to the 17 April 2015 BSEE Blowout Preventor Systems and Well Control notice of proposed rulemaking
Joint API, IADC, IPAA, NOIA, OOC, PESA and USOGA reponse to the 17 April 2015 BSEE Blowout Preventer Systems and Well Control notice of proposed rulemaking
28 May 2015 IADC response to the Bureau of Safety and Environmental Enforcement (BSEE) and Bureau of Ocean Energy Management (BOEM) (80 FR 9916 et seq) proposal to revise and add new requirements to regulations for exploratory drilling and related operations on the Outer Continental Shelf (OCS) seaward of the State of Alaska (Alaska OCS).
15 May 2015 20150515 IADC comments to docket USCG-1998-3786 regarding Commercial Diving Operations
Enclosure (1) to IADC 20150515 letter to docket USCG-1998-3786
7 May 2015 IADC Comments on the USCG proposed rule on Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems [Docket No. USCG-2014-0063]
28
April
2015
20150428 IADC’s 120-day comment extension request regarding BSEE’s BOP Well Control proposed rulemaking
17 February 2015 20150210 OSHA’s response to IADC’s jurisdictional question regarding OSHA recordkeeping requirements for MODU’s operating on the US OCS
20150108 IADC letter to OSHA regarding recordkeeping requirements for MODUs operating on US OCS
18
November
2014
MSC-MEPC.3/Circ.4/Rev.01: Revised harmonized reporting procedures – Reports required under SOLAS regulations I/21 and XI-1/6, and MARPOL, articles 8 and 12
13 November 2014 13 November 2014 IADC comments to docket USCG-2012-0208 regarding Offshore Supply Vessels at least 6000 GT ITC
17
October
2014
17 October 2014 IADC comments to docket USCG-2013-1006 regarding CPI OPA-90 Limits of Liability
23
September
2014
IADC response to UK DECC & HSE CD 272 on implementation of Directive 2013/30/EU on the safety of offshore oil and gas operations
IADC North Sea Chapter response to UK DECC & HSE CD 272 on implementation of Directive 2013/30/EU on the safety of offshore oil and gas operations
UK DECC & HSE Consultative Document 272
12
September
2014
Joint API, NOIA, IAGC, and IADC in response to BOEM call for information and nominations for Beaufort Sea Lease Sale 242
8
September
2014
IADC – ACD letter dtd 8 SEP 2014 to docket USCG-2013-0175 regarding Training & Manning of Personnel on MOUs and OSVs on US OCS
5
September
2014
IADC comments to USCG-2013-0175 Training of Personnel and Manning on Mobile Offshore Units and Offshore Supply Vessels Engaged in U.S. Outer Continental Shelf Activities
25
August
2014
21 AUG 2014 EPA response to IADC letter regarding eNOI default settings revision request
IADC letter dated 6 June 2014 to EPA Region 6 regarding eNOI default settings revision request
6
August
2014
SLS.14/Circ.557 (UK, for Isle of Man): Equivalent arrangements for (SOLAS III/19.3.3.4) abandon ship drill for a lifeboat arranged for free-fall launching and carriage of rescue boats on vessels operating as floating production units
6
August
2014
MEPC 67/6 – Third IMO GHG Study 2014 – Executive Summary (40 pages)
MEPC 67/INF.3 – Third IMO GHG Study 2014 – Complete report (331 pages)
1
August
2014
SLS.14/Circ.555 – Rev.1 (Malta) – Code for the Construction and Equipment of Mobile Offshore Drilling Unit, 1989
MSC-MEPC.7/Circ.9 – Guidelines for the reactivation of the Safety Management Certificate following an operational interruption of the SMS due to lay-up over a certain period
MSC-MEPC.7/Circ.10 – Guidance on safety when transferring persons at sea
30
July
2014
USCG Final Rule on Lifesaving Equipment for harmonization with international standards 30 July 2014 (79 FR 44129)
24 January 2013 IADC letter to docket USCG-2010-0048 regarding lifesaving equipment production testing and harmonization with international standards
29
July
2014
IADC letter dated 21 July 2014 to the Economic Classification Policy Committee (Docket OMB-2014-0004) regarding proposed revisions to NAICS for 2017
4
June
2014
US Coast Guard: Report of Investigation into the Circumstances Surrounding the multiple related Marine Casualties and Grounding of the MODU KULLUK on December 31, 2012.I agree with the District 17 Commander that the inadequate assessment and management of risks by the parties involved was the most significant causal factor of the mishap” — Joseph A Servidio, RADM, USCG, Assistant Commandant for Prevention Policy
USCG presentation to Towing Safety Advisory Committee (TSAC) on tasking for KULLUK Incident Report of Investigation
USCG draft tasking statement on KULLUK ROI for the Towing Safety Advisory Committee (see the USCG Homeport for possible update)
21
May
2014
Arctic Offshore Oil and Gas Guidelines: Systems Safety Management and Safety Culture, Prepared by the Protection of the Arctic Marine Environment Working Group under the auspices of the Arctic Council, March 2014
14
April
2014
“IMO Resolution A.1079(28) – Recommendations for the training and certification of personnel on MOUs
NOTE: This document supersedes IMO Resolution A.891(21)
11
April
2014
IADC comments to USCG-2013-1057 Marine Casualty Report US OCS
8
April
2014
IADC response to the Consultation on Review of Part 5 of the Australian Offshore Petroleum and Greenhouse Gas Storage (Resource Management and Administration) Regulations 2011 (January 2014)
Australia Department of Industry Issues Paper on Review of Part 5 of the Offshore Petroleum and Greenhouse Gas Storage (Resource Management and Administration) Regulations 2011
7
March
2014
IADC Comments to OSHA 2013-0023 Electronic Reporting
Proposed rule to improve tracking of workplace injuries and illnesses
1
March
2014
Redlined versions of the USCG’s STCW implementation regulations contained in the Code of Federal Regulations (46 CFR Parts 1 and 10 thru 15)

20 February 2014 CAP1145
The UK Civil Aviation Authority has issued CAP1145, announcing a series of measures to increase the safety of offshore helicopter flights. While aimed primarily at helicopter operators, some of the actions may directly or indirectly affect drilling contractors, e.g. flight limitations based on sea state, or certified aircraft ditching performance, restrictions on use of seats not adjacent to push-out windows, passenger body size considerations, Emergency Breathing System mandate, review of non-conforming helidecks, and assumption of helideck certification responsibilities by the CAA.
19 February 2014 UK CAA Research Update
Includes updates on:

  • Operations to moving helidecks
  • Helideck lighting
  • Helideck friction
  • Turbulence & plumes around platforms
18 February 2014 UK HSE: RR997 – Modelling smoke and gas ingress into offshore temporary refuges
This report sets out a model for determining TR impairment times arising from the ingress of smoke, flammable and toxic gas. The method is based upon leakage data from pressure testing and using the methods set out in the supporting document to HSE HID Semi-permanent circularSPC/Tech/OSD/30.
18 February 2014 UK HSE: RR993 – Technical input on ventilation effectiveness for area classification guidance EI15
The main aim of this work is to provide an improved methodology for assessing the adequacy of the ventilation such that an enclosure containing secondary grade release sources can be properly classified as Zone 2 as defined by BS EN 60079-10-1:2009.
It is shown that limiting the average concentration to 25% LFL in the enclosure generally achieves the ventilation objective for a Zone 2 area but the degree of confinement and congestion at the point of release must be assessed. Guidance on this assessment is provided including the use of a factor to quantify the efficiency of mixing.
9 December 2013 9 December 2013 IADC letter to Docket USCG-2012-0779 regarding SEMS Requirements for Vessels on the U.S. OCS
5 December 2013 IADC comments to the BSEE rulemaking docket on Production Safety Systems.
IADC’s comments focus on changes needed to clarify the proposed rule, particularly with regard to the regulatory obligations imposed on the drilling community.
1 December 2013 IADC Guideline for MODUs subject to the EPA NPDES Permit Requirements for Discharges Incidental to Normal Vessel Operations (Vessel General Permit)
27 November 2013 27 November 2013 IADC letter to Docket USCG-2013-0850 regarding Electrical Equipment in Hazardous Locations
17 October 2013 16 October 2013 API/IADC/OOC/NOIA/IPAA/USOGA letter to BSEE requesting removal of BAST from the proposed Production Safety regulation.
In the recent BSEE proposed changes to its production safety systems requirements (Subpart H) they also included proposed changes to the regulatory requirements related to BAST (Subpart A). The proposed regulatory text eliminates the phrase “we consider your compliance with [BSEE] regulations to be the use of BAST.” Instead, the proposed new regulation simply states that “you must use the best available and safest technology [BAST] that BSEE determines to be economically feasible.” Under this new language, it is unclear whether any equipment, practices or systems that are currently in use in the OCS constitute the use of BAST.The proposed letter requests BSEE withdraw the proposed regulatory changes to the BAST requirements, because they are premature and unwarranted at this time. Our comments assert that BSEE has an effective regulatory system in place for ensuring that BAST is used in operations, and that any proposed changes should be suspended pending BSEE’s ongoing efforts to review options for implementing BAST.
8 October 2013 8 October 2013 IADC letter to Docket USCG-2013-0240 regarding draft changes to the Marine Safety Manual Volume III (Marine Industry Personnel), Chapters 20 through 26.
10 September 2013 5 September 2013 IADC letter to Docket USCG-2013-0491 regarding Consolidation of OCMI for OCS Activities Eighth Coast Guard District
15 August 2013 IMO Circular letter No. 3394 – Interim Guidelines for Owners, Operators and Masters for protection against piracy in the Gulf of guinea region.
The IMO has issued this circular letter to direct attention of the maritime industries to Guidelines for Owners, Operators and Masters for protection against piracy and armed robbery in the Gulf of Guinea region.
7 August 2013 COMSAR.1/Circ.51/Rev.4 – LIST OF NAVAREA COORDINATORS
In consultation with the International Hydrographic Organization (IHO), an updated list of NAVAREA Coordinators has been distributed by the IMO. In accordance with the MODU Code, each unit should report its position to the relevant World Wide Navigational Warning Service (WWNWS) NAVAREA Coordinator when arriving on-site, in order for a Navigational Warning to be broadcast. Additionally, units should inform the NAVAREA Coordinator when departing from that site, in order for the broadcast to be cancelled.
20 May 2013 New Zealand – Health and Safety in Employment (Petroleum Exploration and Extraction) Regulations 2013 (entry into force on 30 June 2013)
22 February 2013 20 February 2013 IADC letter to docket USCG-2012-0848 regarding lifesaving, firefighting equipment and drills on MODUs
1 February 2013 30 January 2013 IADC Summary of EPA OCS Air Regulations final rule
2 November 2012 IADC letter to EPA docket EPA-2008-0708 on NESHAP for reciprocating internal combustion engines
15 January 2013 9 JAN 2013 USCG response that confirms BW Management Regulations do NOT apply beyond territorial seas (12NM)
1 May 2012 USCG response to IADC letter regarding Ballast Water reporting requirements and Preload Tank Classification
15 November 2011 IADC letter to USCG regarding Ballast Water reporting requirements
2 January 2013 18 November 2012 USCG response to IADC letter requesting clarification of CG-CVC Policy Letter 12-08 regarding implementation of AFS Convention
15 November 2012 IADC letter to USCG regarding CG-CVC Policy Letter 12-08 regarding guidance on implementation of AFS Convention
28 September 2012 Joint API, IADC, NOIA, OOC letter to BSEE regarding anticipated rule making on BOPSs
19 June 2012 Transportation Research Board Special Report 309:
Evaluating the Effectiveness of Offshore Safety and Environmental Management Systems
4 May 2012 The US Coast Guard is developing policies related to dynamic positioning, automated power management, gas detection systems and well control and safety shutdown systems. IADC will be commenting. The following documents are relevant to this effort:4 May 2012 Federal register Notice on recommended Interim Voluntary Guidance
27 January 2012 IADC response to the US Coast Guard’s proposed policy
29 December 2011 Federal Register NoticeDraft Coast Guard Policy Letter
Marine Safety Center Technical Note 02-11 on Review of Vital System Automation and Dynamic Positioning System Plans (15 Dec 2011)
26 April 2012 Recommendations of the Ocean Energy Safety Advisory Committee (OESC) to the Department of Interior regarding:

  • Safety Management System Enhancement
  • Safety Culture
  • Leadership and Communication Training
  • Organizational and Systems Readiness for Containment Response
  • Research Priorities for Source Control of Blowouts
4 April 2012 4 April 2012 IADC letter to Docket USCG-2011-0641 regarding Accommodation Service Vessels engaged in OCS Activities
30 March 2012 23 March 2012 USCG response to IADC letter regarding MSIB Reporting Requirements – Failure of Critical Systems
20 February 2012 IADC letter to Eighth Coast Guard District regarding MSIB on Reporting Requirements – Failure of Critical Systems
USCG District Eight Feb 2012 MSIB – Reporting Requirements Regarding Failure of Critical Systems
1 November 2011 31 October 2011 IADC letter to Docket USCG-2011-0662 regarding AB-MOU Credential Elimination
1 July 2011 UK Helideck Certification Agency “Letter to Duty Holders” regarding use of “Rate of Heave”
UK Helideck Certification Agency “Helideck Monitoring System (HMS) Operating Procedures”
1 June 2011 IADC response to the Recommendations contained in Volume I of the Joint Investigation Team’s “Report of Investigation into the Circumstances Surrounding the Explosion, Fire, Sinking and Loss of Eleven Crew Members aboard the Mobile Offshore Drilling Unit DEEPWATER HORIZON in the Gulf of Mexico, April 20-22 2010.”
10 April 2011 IADC response to US Department of Homeland Security notice and request or comments on “Improving Regulation and Regulatory Review”
1 March 2011 ISO TC 67 (Materials, equipment and offshore structures for petroleum, petrochemical and natural gas industries) Action Plan on Recent Industry Events, a proposed programme for drilling, well construction and well operations standards, resulting from the Montara and Macondo accidents.
13 January 2011 USCG 13 JAN 2011Final Rule (76 FR 2254) regarding Notice of Arrival on U.S. OCS
18 September 2009 letter to docket USCG-2008-1088 regarding Notice of Arrival on US OCS
8 October 2010 BOEM Workplace Safety (SEMS) Final Rule
IADC draft Gap Analysis between SMS of the IADC HSE Case Guidelines and API RP 75
IADC draft Gap Analysis between requirements of the SEMS Final Rule and the IADC HSE Case Guidelines (12 November 2010)
15 March 2010 IADC Companion to the 2009 MODU CodeThe IADC Companion to the 2009 MODU Code facilitates understanding of the new MODU Code by clearly identifying the differences between its predecessor, the 1989 MODU Code, and the 2009 MODU Code in a highlighted/strikethrough format. Footnotes are provided that indicate the intended purpose of the change and identify the source documentation for the change. The Companion to the 2009 MODU Code is provided on a compact disk which also contains copies of the referenced source documents.Single copy of the CD – US $200, plus S&H
Additional copies to same address – US $10, plus S&HThe Companion CD is available for purchase by contacting IADC Publications at publications@iadc.org or by phone at +1-713-292-1945 (Fax: +1-713-292-1946). Or click here to send us a message via the IADC Publications web site and we’ll contact you with ordering information.
14 August 2009 13 August 2009 IADC memo on Lifeboat Safety
23 July 2009 USCG 1 July 2009 Interim Final Rule (74 FR 31357) regarding COFR Limits of Liability
24 June 2008 Letter to National Pollution Fund Center regarding interpretation of COFR limits of liability for MODUs
18 June 2008 letter to USCG regarding Docket USCG-2205-21780 Regarding COFR limits of liability modifications.
18 June 2007 15 June 2007 reply from Eighth District USCG regarding marine casualty and drug testing reports
MODU Matrix for Marine Casualty and Drug Testing (CG-2692 and CG-2692B)

29 August 2006, Letter to USCG regarding applicability of revised alcohol and drug testing regarding foreign flagged MODUs on US Outer Continental Shelf.
6 September 2005 IADC comments in response to the 11 July 2005 proposed U.S. Coast Guard regulations governing potable water supply on inspected vessels
26 May 2004 General Ocean Tow Recommendations for Jackup Drilling Units, IADC, February 13, 1991
These Guidelines were issued by the IADC in 1991 and are now under review. Please submit any suggestions for changes to these Guidelines to Alan Spackman (alan.spackman@iadc.org) by 15 September 2004.

Resources

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Reports

Resource Link / File Resource
31 December 2016 – Federal Regulatory Actions Impacting Offshore Drilling (58 pages)
This report provides a reference summary that reflects the regulatory actions, announced in the Federal Register by US governmental agencies, which may affect operations in the offshore oil and gas industries.
PDF
1 December 2016 International Offshore Regulatory Summary Report (53 pages)
This report provides a handy reference to international regulatory and standards development activities of various organizations with the potential to affect offshore oil and gas operations (e.g., various UN agencies, including the International Maritime Organization, International Labor Organization, the International Organization for Standardization, API, and various international trade associations.
PDF
31 December 2015 – Policy, Government & Regulatory Affairs Annual Report PDF
4 November 2015 – PGRA Annual Report to the Offshore Advisory Panel PDF
13 November 2013 – IADC Submission to CNH (Mexico) regarding Guidelines for Drilling Authorization of Petroleum Wells PDF
1 September 2015 – Committee Chairman’s Meeting Presentation PDF
Directive of the European Parliament and Council on safety of offshore oil and gas operations and amending Directive 2004/35/EC PDF
eBook – IADC Policy, Governmental and Regulatory Affairs Strategy 2014 PDF
Press Release – 2014 UK Budget Statement, Issued March 2014 PDF
UK Parliamentary Briefing on bare boat charter taxation. Issued April 2014 PDF
Recent Return To The Australian Consultation On Well Notifications, Issued April 2014 PDF
Oil Spill Commission Action Website
The oil Spill Commission Action (OCSA) project is an outgrowth of the National Commission (above) supported of many of the original Commissioners.
OSCA Assessment Report on the status of implementation of the Commission’s recommendations (17 April 2012)
PDF
Republic of the Marshall Islands Website
DEEPWATER HORIZON MARINE CASUALTY INVESTIGATION REPORT (low resolution version)
17 August 2011
PDF
University of California, Berkeley — Center for Catastrophic Risk Management Website
“Deepwater Horizon Study Group Final Report on the Investigation of the Macondo Well Blowout”
1 March 2011
PDF
National Academy of Engineering– Analysis of Causes of Deepwater Horizon Explosion, Fire, and Oil Spill to Identify Measures to Prevent Similar Accidents in the Future Website
Interim Report on Causes of the Deepwater Horizon Oil Rig Blowout and Ways to Prevent Such Events
16 November 2010
Macondo Well-Deepwater Horizon Blowout: Lessons for Offshore Drilling Safety
14 December 2011
PDF
Transportation Research Board Special Report 309:
Evaluating the Effectiveness of Offshore Safety and Environmental Management Systems
June 2012
Website
Petroleum Safety Authority Norway – Macondo Incident Website
Preliminary conclusions by the Petroleum Safety Authority Norway (PSA) and action recommended after the Deepwater Horizon accident (English summary)
9 June 2011
SINTEF Executive Summary of report commissioned by the Petroleum Safety Authority
May 2011
The Petroleum Safety Authority Norway’s concluding report on its follow-up of the Deepwater Horizon accident
February 2014
PDF
Norwegian Oil Industry Association (OLF)
Deepwater Horizon – lessons learned and follow up
Website
OLF’s Deepwater Horizon Report – In English (84 pages)
OLF’s summary Report – In English (20 Pages)
June 2012
PDF
UK Health and Safety Executive – Deepwater Horizon incident in the Gulf of Mexico
The Health and Safety Executive’s Offshore Division is monitoring the situation in the Gulf of Mexico following the fatal explosion on the Deepwater Horizon drilling rig in April 2010 and has created a website to report on its findings, observations and actions.
Website
UK Ministerial commissioned Independent Review for the Deepwater Horizon/Macondo incident

Offshore Oil and Gas in the UK – an independent review of the regulatory regime December 2011

Government Response to an Independent Review of the Regulatory Regime, Department of Energy & Climate Change, December 2012

Website

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Alan Spackman
Vice President – Policy, Government & Regulatory Affairs
alan.spackman@iadc.org