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PETROLEUM AND NATURAL GAS (SAFETY IN OFFSHORE OPERATIONS) RULES, 2006

PETROLEUM AND NATURAL GAS (SAFETY IN OFFSHORE OPERATIONS) RULES, 2006. OISD. OISD. BACKGROUND. 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. OISD.

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PETROLEUM AND NATURAL GAS (SAFETY IN OFFSHORE OPERATIONS) RULES, 2006

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  1. PETROLEUM AND NATURAL GAS(SAFETY IN OFFSHORE OPERATIONS) RULES, 2006 OISD OISD

  2. BACKGROUND 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 OISD OISD

  3. BACKGROUND • 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 OISD OISD

  4. METHODOLOGY OF FRAMING THE RULES • 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 OISD OISD

  5. MAIN PRINCIPLES • 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 OISD OISD

  6. MAIN PRINCIPLES • 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 OISD OISD

  7. MAIN PRINCIPLES ….contd • 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) OISD OISD

  8. MAIN PRINCIPLES ….contd • 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 OISD OISD

  9. MAIN PRINCIPLES ….contd Concept of barriers: • The operator shall establish strategies and principles so that the barriers are ensured for the lifespan of the facility • Barrier elements can be physical, organisational or operational • It shall be known at all times what barriers are non-functional or impaired OISD OISD

  10. CHAPTERS I Preliminary II Principles Related to Health, Safety and Environment III Information and Records IV Consent and Intimation V Risk Management VI Safety Management OISD OISD

  11. CHAPTERS 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 OISD OISD

  12. CHAPTERS XIV Planning and Conduct of Activities XV Working Environment Factors XVI Drilling and Well Activities XVII Maintenance XVIII Specific Operations XIX Marine Facilities and Operations XX Environment XXI Miscellaneous OISD OISD

  13. Generic & not specific Competent authority –OISD Penal provision 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 Comments OISD response OISD OISD

  14. Compliance to class & flag state requirements SOLAS, MARPOL Too many Schedules 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 Comments OISD response OISD OISD

  15. Acco.capacity not to exceed Survival suits & Life jackets Periodic audit of examination of emer.resp.eqpt 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 Comments OISD response OISD OISD

  16. 5. Special baskets, certification & night transfer To include lifting eqpt certification Trained crane operators 8. Hygiene concerns 9. 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 Comments OISD response OISD OISD

  17. Safety agency should be independent of the administrative ministry Therefore Regulation of safety should be by agency other than OISD ----- ONGC Comments OISD response OISD OISD

  18. Agree to consent to operate, how ever time period be increased to 2 years from 180 days for existing installations Consent for Combined opn’s not feasible Increased to 1 year (draft 2). Will be further reviewed Changed to Intimation (Draft2) ONGC Comments OISD response OISD OISD

  19. One time combined operations consent for specific cases Certificate of Fitness For existing inst. time period to be extended 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 Comments OISD response OISD OISD

  20. Dual regulatory regimes OISD & MOEF OISD & DGCA OISD & DG shipping OISD & DGMS Clarified in Draft 2 No overlap No overlap Overlap in territorial waters only ONGC Comments OISD response OISD OISD

  21. 7. Legislation should be dynamically linked to global industry recognised standards like API, IMCA, NFPA, SOLAS etc ONGC Comments OISD response • Shall be done wherever considered appropriate OISD OISD

  22. Combined operation definition to include construction also Launchers and receivers should be included in offshore facilities rather than pipeline NIKO RESOURCES Comments OISD response • Noted –will be included • No change OISD OISD

  23. Risers to be considered up to last isolation valve in the pipeline Notice of accident- to add in 12(e) whereby safety of a person or facilities likely to be endangered NIKO RESOURCES Comments OISD response • No change • Noted-will be reviewed OISD OISD

  24. Barriers shall be commensurate with the probability and consequence of the incident Criteria for certificate of fitness must be defined NIKO RESOURCES Comments OISD response • Rule 23(1) • Fit for the purpose as per rule 30(1) OISD OISD

  25. Delete maintenance of communication equipment from responsibility of desig person Include inspection with maintenance in rule no 107(2) on pipeline NIKO RESOURCES Comments OISD response • Noted-will be deleted • Noted- will be included OISD OISD

  26. Operator in different areas- contractor or company man Operator to pay cost incurred on instrumentation 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 Comments OISD response OISD OISD

  27. Onboard Safety Officer - not in existing contracts Safety committee meeting participation and acceptance 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 Comments OISD response OISD OISD

  28. Helicopter coverage at all times Standby vessel to be shared by maximum two installations Survival suits not required Not covered in rules No change in rule 63 Noted- will be changed Transocean Offshore International Comments OISD response OISD OISD

  29. Drilling and well activities chapter to be replaced by IADC guidelines BOP etc to be overhauled as per API Communications during Lifting operation No change Noted- will be reviewed Noted- will be reviewed Transocean Offshore International Comments OISD response OISD OISD

  30. Identification of rough weather conditions by company or contractor Contractor is operator as per definition in case of hired rig Transocean Offshore International Comments OISD response OISD OISD

  31. Regulatory expectation of word competence List of monitoring parameters Metocean data In absence of definition, dictionary meaning to be followed Operator to decide Clause will be reviewed BG India Comments OISD response OISD OISD

  32. Notice of accident –personal injuries & asset damage Decommissioning guidelines Application for consent Noted-will be reviewed Rule 12 f Noted –will be provided Rule is explicit BG India Comments OISD response OISD OISD

  33. Material changes 8. ALARP – Rule 22(5) compliance Trainings for offshore going employees to be specified BG India Comments OISD response • Significant changes • Yes for rule 22 • Rule 129 OISD OISD

  34. Certificate of fitness Safety officer and safety committee rules to be deleted BG India Comments OISD response • Installation to be fit for the purpose as per rule 30(1) • No change OISD OISD

  35. The competent person should be trained as HLO Safety Zone to be increased Safety zone area must be avoided for navigation BG India Comments OISD response • Rule 129 • No change for time being • Rule 52(2) OISD OISD

  36. Monitoring of safety zone –visual or electronically Standby vessel for each field in place of installation Survival suit not required BG India Comments OISD response • Operator to decide • No change • Noted –will be changed OISD OISD

  37. Damage to subsea facilities by activities with high probability of occurance Probability of occurance of single mistakes should be considered BG India Comments OISD response • Noted-will be reviewed • Implied in 82(c) OISD OISD

  38. Two independent communication facilities may not be available in temporary manned facility One valve of christmas tree to be remotely operated may be dropped BG India Comments OISD response • Noted-will be made compulsory only for manned facilities • No change OISD OISD

  39. Guidance document will be required for lighting & radiation Add- or pipeline systems shall have sufficient protection to mitigate the risk from these operations BG India Comments OISD response • Noted-will be provided • subsequently • Noted-will be modified OISD OISD

  40. Rule no 121 on Fire water supply includes unattended platforms In some cases living qtr is a bridge & fire division as per rules 115/116 is not required BG India Comments OISD response • Yes • Noted-rule 116 will be modified OISD OISD

  41. Minimal offshore facilities such as well head platforms may be separated from main facilities with regard to fire and gas detection system BG India Comments OISD response • No change OISD OISD

  42. Automatic activation of deluge in case of gas detection may be hazardous Rule 149(4)- if a barrier fails no other activity shall take place in the well than those to restore the barrier BG India Comments OISD response • Noted-will be reviewed • It applies to all well operations OISD OISD

  43. Rule 153(4) applies to those well interventions before permanent tree is installed Eqpt. & procedure for detecting & assessing actions of vessels intruding in the safety zone BG India Comments OISD response • Yes • Operator is free to decide OISD OISD

  44. Who sets the acceptance criterion Accidental loads – not possible to quantify all Premier Oil Comments OISD response • The operator as per rule 28(7) • Agreed but these are required to be determined to best possible accuracy OISD OISD

  45. By giving consent competent authority accepts responsibility for the design, operation and ER of the operator Security of installation should be added to rule 3 Premier Oil Comments OISD response • Responsibility is covered in rule 7(1) • Covered by other existing rules of GOI OISD OISD

  46. There is no definition of competence in rule 4(2) Rule 6 -offshore clinic can not offer curative services from all ailments Premier Oil Comments OISD response • In absence of definition, dictionary meaning shall be followed • Routine curative services only OISD OISD

  47. Not possible for future employees to contribute to HSE matters in design of a facility Information and records required are not defined Premier Oil Comments OISD response • Obviously • Not intended to make rules prescriptive OISD OISD

  48. There should be some cut off time for maintenance of information & records Rule 10 is to allow operation of new installation Premier Oil Comments OISD response • Rule 9(5) • Agencies as per rule 8 • It is an intimation only by the operator OISD OISD

  49. Time period of 90 days is unrealistic for small unmanned installations design review Schedule II should not include design information of Sch I Premier Oil Comments OISD response • Noted-will be reviewed • No change OISD OISD

  50. For a drilling rig, total lead time of 5 months to drill a well is not viable In case of combined operations –Sch IV/V and Sch VI are to be submitted Premier Oil Comments OISD response • Noted-will be reviewed • Yes OISD OISD

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