GCREAG Regulatory Update
January, 2014
Lincoln Stroh
J. Connor Consulting, Inc.
Key Topics
BSEE Regulatory Agenda
USCG Regulatory Agenda
DOT Regulatory Agenda
Form / Information Collection Updates
Proposed, Final Regulations & New NTL
Deepwater Exploration Plan Approval Times
BSEE Regulatory Agenda
• BOPs
– NPRM March 2014
– Final Rule October 2014
• Production Safety Systems and Lifecycle Analysis
– NPRM August 22, 2013
– Comment Period Ended October 21, 2013
– Final Action May 2014
USCG Regulatory Agenda
• Proposed regulations to add new requirements
for lifesaving, fire protection, training, hazardous
materials used as stores, and accommodation
• Add standards for electrical and machinery
installations in hazardous locations
• Provide regulations for DP systems
• Provide for USCG acceptance and approval of
specified classification society plan reviews,
inspections, audits, and surveys
• NPRM September 2014
USCG Regulatory Agenda
• Nontank Vessel Response Plans requires owners or
operators of nontank vessels to prepare and submit oil
spill response plans. Definition of nontank vessel:
– Self-propelled vessels of 400 gross tons or greater that
operate on the navigable waters of the US
– Carry oil of any kind for main propulsion that are not
tank vessels
• Updates SOPEP requirements that apply to nontank
vessels and tank vessels
• Final Rule September 30, 2013 with effective date
of October 30, 2013
DOT Regulatory Agenda
• PHMSA: Pipeline Safety regs at proposed rule stage:
– Safety of On-Shore Liquid Hazardous Pipelines
• Addresses hazardous liquid operators improving protection
of High Consequence Areas (HCA) and other vulnerable areas
• NPRM April 2014
– Issues with using Plastic Pipe in Gas Pipeline Industry
• Includes several issues regarding plastic pipe gas lines.
• NPRM April 2014
– Operator Qualification, Cost Recovery and other
Pipeline Safety Proposed Changes
• Affects renewal process for special permits, cost recovery for
design reviews, and incident reporting.
• NPRM November 2013
DOT Regulatory Agenda
• MARAD: Regulations To Be Followed by All Departments,
Agencies and Shippers Having Responsibility To Provide a
Preference for U.S.-Flag Vessels in the Shipment of
Cargoes on Ocean Vessels
– Would update and clarify the Cargo Preference rules that have
not been revised substantially since 1971.
– Next action is currently “undetermined”
Forms Update - APD / APM
• Application for Permit to Drill and Application
for Permit to Modify updates will include a
certification statement to state that false
submissions are subject to criminal penalties
• Minor APD modifications
• Comments on each are due by Feb. 3, 2014
New Form BSEE-0011 iSEE
• Internet-Based Safety and Environmental Enforcement
Reporting System
– Created to clarify the needed information when someone reports
an apparent violation
• Any person may report to BSEE any hazardous or unsafe
working condition on any facility engaged in OCS activities,
and any possible violation or failure to comply with:
– Any provision of the Act
– Any provision of a lease, approved plan, or permit issued under the
– Any provision of any regulation or order issued under the Act, or
– Any other Federal law relating to safety of offshore oil and gas
• Comments due January 17, 2014
OSHA Injury Reporting Proposed Rule
• To require DIRECT electronic submission of
workplace injury / illness data to OSHA “or its
designee” (i.e. BSEE / form BSEE-0131)
– Expands OSHA’s current direct collection abilities
– Data is already tracked by employers (this won’t
change), but is only accessed during inspections
– 3 new requirements:
• > 250 employees = quarterly e-submission of info
• > 20 employees AND in certain industries = annual esubmission via form 300A to replace annual survey
• E-submit injury / illness data as requested by OSHA
Extension of Prior Notices to Lessees
• Two NTLs previously extended until the end of
calendar year 2013 (NTL No. 2013-G02) are
being extended again until June, 30, 2014.
– NTL 2008-G04 provides guidance on the
information requirements for OCS plans required
by 30 CFR 550, subpart B, and
– NTL 2008-G05 describes the shallow hazards
program, which was designed to ensure that
exploration, development, production, and
transportation operations are conducted with a
minimum risk to human life and the environment.
Upcoming Regulations
• Mike Saucier (BSEE) listed upcoming regulations
at the December OOC Meeting:
– Blowout Prevention Systems (in preparation, due out
early 2014)
– Arctic regulations (joint with BOEM)
• Upcoming proposed rules:
– Suspensions of Production and Operations
– Natural Gas Fluids Measurement
– Oil Spill Mechanical Recovery
Deepwater Initial EP Approval Times
Time Period
EP Avg. Approval
Time (Days)
2010 (Post DWH)
Down the Road
• January 28/29 – Hilton N.O. BSEE Standards Workshop
• January 29 – USCG Sector New Orleans Area
Committee meeting
• March 19 – Central GOM Lease Sale 231 – N.O.
• March 19 – Eastern GOM Lease Sale 225 – N.O.
(following CGOM sale)
• April 9/10 – Center for Offshore Safety 2nd Annual
• June 4 - Must be in compliance with SEMS II
Thank you!
Lincoln Stroh
J. Connor Consulting, Inc.
[email protected]