Houston, Texas (17 July 2015) – The International Association of Drilling Contractors (IADC), along with six other oil and gas industry trade associations, submitted a joint letter today to BSEE with comments on the agency’s Proposed Blowout Preventer Systems and Well Control rule. IADC supplemented this letter with a separate letter, which specifically addresses the concerns of drilling contractors.
Specifically with regard to drilling contractors, IADC identified three major areas of concern with the proposed rule. These include its prescriptive requirements that go beyond international standards and will negatively affect the US market for MODUs; the significant costs to drilling contractors to comply with the rule, which were not accounted for in BSEE’s impact analysis; and the inspection and more massive BOP equipment requirements, which will negatively impact operations.
“At IADC, we welcome any opportunity to work collaboratively and constructively with BSEE and Director Salerno, as we believe in the need for better regulation. That is regulation that is fair, fit for purpose, practically implementable and affordable for our industry. We understand the weight of expectation on this proposed rule, given that well control is a key area of public concern, and we respect the direction of travel set by BSEE. However, the lengthy period of gestation of the rule is regrettably unmatched by the very short period for public comment on it, as the rule is both technical and wide-ranging,” said Stephen Colville, IADC President and CEO.
“Our industry has identified a number of measures that are variously technically unfeasible, with little overall benefit to safety standards and unrealistic deadlines, and the related costs of compliance are very high. IADC has identified areas where the duties of the drilling contractor need to be better defined in light of BSEE’s evolving view of the responsibilities and liabilities of entities other than the operator,” Mr. Colville continued. “Overall, the high cost imposed by the rule greatly exceeds the potential benefits derived from it, and will challenge the economics of outer continental shelf (OCS) operations. We know Admiral Salerno and BSEE share IADC’s concern to achieve the best possible outcome for safety in OCS well operations. So at IADC, we are confident that as BSEE and other key stakeholders come to recognize soon the shortcomings in the current proposed regulation, they will work urgently and collaboratively with the industry to rectify them.”
Since 1940, the International Association of Drilling Contractors (IADC) has exclusively represented the worldwide oil and gas drilling industry. IADC’s mission is to catalyze improved performance for the drilling industry by enhancing operational integrity and championing better regulation to facilitate safer, cleaner and more efficient drilling operations worldwide. For more information, visit the IADC website at www.iadc.org.