Oil and Gas Production Safety Systems (Subpart H) Final Rule
BSEE amended and updated the regulations regarding oil and natural gas production safety systems on the Outer Continental Shelf (OCS). Production safety systems play a critical role in protecting workers and the environment. Operators may not commence oil and gas production until BSEE approves their production safety system application and BSEE conducts a pre-production inspection. These regulations (30 CFR part 250, subpart H) have not undergone a major revision since they were first published in 1988. Since that time, much of the oil and gas production on the OCS moved into deeper waters and uses newer technology. This new technology includes subsea trees, which allow production in the deepwater environment. BSEE strives to keep pace with these technological advancements.
This rulemaking addressed issues such as:
- safety and pollution prevention equipment;
- subsurface safety devices;
- safety device testing;
- dry tree (surface) and subsea tree production systems;
- firefighting systems;
- shutdown valves and systems;
- valve closure and leakage;
- mechanical integrity of the fire tubes for tube-type heaters; and
- high pressure/high temperature (HPHT) well equipment.
In addition BSEE:
- implemented the use of a lifecycle approach for safety and pollution prevention equipment;
- rewrote these regulations in more precise language;
- restructured these regulations to have shorter, easier-to-read sections and clearer, more descriptive headings;
- incorporated by reference new industry standards and updated the previous partial incorporation of other standards; and
- revised the existing regulation (§ 250.107(c)) that require the use of Best Available and Safest Technology (BAST) to follow more closely the Outer Continental Shelf Lands Act’s (OCSLA, or the Act) statutory language regarding BAST.
