April 4, 2011
Safety Plan Guidelines and Environmental Protection Plan Guidelines have been issued to assist Operators in the development of an environmental protection plan (EPP) and a safety plan that meets legislative and regulatory requirements. The C-NLOPB has co-published these guidelines with the National Energy Board (NEB) and the Canada Nova Scotia Offshore Petroleum Board (CNSOPB).
The guidelines specifically address sections 8 and 9 of the Newfoundland Offshore Petroleum Drilling and Production Regulations. These regulations require that an Operator submit a safety plan and an EPP as part of their application for authorization of a drilling program or a production project.
The guidelines were initially issued on December 31, 2009 in draft form, for use on a one-year trial basis. Based on feedback received from various stakeholders and experience with their use, a number of improvements were made and the guidelines were re-published on March 31, 2011. The changes and improvements are as follows:
Safety Plan Guidelines:
- The role of the safety plan in the overall safety management system was clarified.
- Operator’s responsibility with respect to oversight of contractors and coordinating the activities of contractors was clarified in section 3.2 (Management of Contractors Work or Activity).
- Section 4.2 (Purpose and Scope of the Safety Plan) was clarified to reflect that plans are scalable in breadth and depth and are a function of work activity, complexity and risk.
- Guidance was added in section 4.6.3.1 (Awareness) to indicate that all stakeholders (i.e. workers, contractors, suppliers) be made aware of the requirements of the safety plan.
- The need to summarize and reference in the safety plan the policies and procedures in place to ensure that all personnel are competent was added (Section 4.6.3.2 - Competence and Training).
- Section 4.6.5 (Document Control) and 4.6.8 (Management of Change) were identified to move to section 5 (Management System) of the Drilling and Production Guidelines.
- The guidelines were edited to ensure that they were as concise and clear as possible. For example, internal and external communications in section 4.6.4 (Communication) and section 4.7.2 (Auditing) were consolidated.
Environmental Protection Plan Guidelines:
- Language was clarified as necessary and linked more directly to the regulations.
- Section 3 (Management System Linkage) was clarified to strengthen linkages with the Operator’s management system.
- The Operator’s responsibility with respect to contractors was clarified in section 3.2 (Management of Contractors Work or Activity).
- References were added in section 4.5.1 (Hazard Identification, Risk Evaluation and Mitigation) respecting the need for interactions with aboriginal authorities within NEB jurisdiction in respect of environmental assessments.
- The former section 4.6.8.3 (Spill Environmental Effects Monitoring) was targeted to move to the Drilling and Production Guidelines, since it relates directly to contingency planning which is explicitly addressed in the Newfoundland Offshore Petroleum Drilling and Production Regulations.
- The former section 4.6.8.4 (Liability for Spills and Debris) was moved to the Drilling and Production Guidelines for similar reasons.
- Section 4.7.2 (Reporting of Sheens) was added as a result of discussions within the Offshore Waste Treatment Guidelines Working Group during finalization of those guidelines in 2010.
All projects currently have safety plan and EPPs in place in connection with their ongoing activities. These guidelines will assist Operators to ensure that these plans are up-to-date in respect of regulatory requirements and expectations. Compliance with these plans is verified by the C-NLOPB through audits and inspections and by ongoing monitoring of offshore operations.
It is the C-NLOPB’s expectation that safety plans and EPPs be updated on a regular basis to capture lessons learned and any improvements to best industry practices. A formal review of the adequacy of safety plans and EPPs is undertaken at the time of the renewal of each authorization.
