1

National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling

CONTINUOUS IMPROVEMENT IS ESSENTIAL: LEVERAGING GLOBAL DATA AND CONSISTENT STANDARDS 

FOR SAFE OFFSHORE OPERATIONS

Staff Working Paper No. 18

Staff Working Papers are written by the staff of the National Commission on the BP 

Deepwater Horizon Oil Spill and Offshore Drilling for the use of members of the 

Commission. They do not necessarily reflect the views of the Commission or any of its 

members. In addition, they may be based in part on confidential interviews with 

government and non-government personnel.

“To get where we need to be on safety, continuous improvement is essential. In an 

industry such as ours, which operates 24 hours a day around the world, the need to 

manage risk never ends. Even the best safety framework should be viewed as a work in 

progress.” Rex Tillerson, CEO ExxonMobil1

Introduction

The participants at the 3rd International Regulators’ Offshore Safety Conference 

concluded: “Wherever possible, the best standards should be identified and applied 

internationally.” 

They met over 18-20 October, 2010 in Vancouver, British Columbia, Canada after two of 

the worst offshore blowouts and spills in history on opposite sides of the globe and 

agreed that the need for international cooperation and collaboration could not have 

been clearer. They noted: “Regulators should serve as catalysts for learning by 

distributing information, hosting workshops, participating in research, and identifying 

gaps in standards and best practices...Sustaining outstanding performance is critical to 

the reputation of industry and government.”2

Despite variations in regulatory regimes, geological settings, and marine environments, 

oil and gas drilling operations have a lot in common, and these commonalities allow for 

uniform data collection. Such data can then be used as the basis for international 

 1 Testimony of Rex Tillerson, ExxonMobil, Hearing before the National Commission, November 9, 2010, 256. 2

 “Conference Summary,” International Regulators’ Forum,

http://www.irfconference2010.com/showcontent.aspx?MenuID=940.
2

standards that would provide oil and gas regulators a common language in which to 

discuss and assess ways to manage the challenges presented by work offshore.

Today there are many different standard-setting bodies involved in the creation of 

technical standards. The resulting variations in standards creates a high regulatory 

“transaction cost” for companies working under multiple regulatory jurisdictions. These 

transaction costs could be lowered by more globally unified standards.

Creating well-informed standards with regard to best practice and safety requires 

comprehensive, objective, high-quality data in order to highlight trends and areas in 

need of specific attention. While the economic benefits of equipment standards and 

bare minimum requirements are often clear, the value of improved safety and risk 

management can be hard to quantify. 

This paper identifies the various organizations that collect incident and personal injury 

data for offshore oil and gas operations, what data each collects, and how that data 

might be used. This paper also considers the various national and international 

standard-setting organizations related to offshore oil and gas activities and their 

governing guidelines. 

Offshore Oil and Gas Incident and Injury Databases

Collecting High-quality, Objective, Comprehensive Data. Complete and accurate 

industry incident data are critical to informing industry and regulators about the safety 

of offshore operations, identifying areas that need work, and guiding both industry and 

regulators toward improvements. In countries where competent regulatory systems 

exist, the regulators can impose a high degree of compliance in developing quality 

statistical information. Industry organizations also collect such data from their members 

but rely on voluntary compliance. Yet, while voluntary, these industry sources provide 

the only information in areas of the world where the regulatory regimes either do not 

exist or are not engaged in proactive oversight of offshore activity. Comprehensive data 

reflecting the common experience of this global industry is lacking because national 

regulators and these other organizations collect offshore data in a nonuniform fashion. 

As a result, data from different jurisdictions is not relatively comparable, undermining 

meaningful efforts to compare how differing regulatory regimes and safety standards 

work in application.

For that this reason, there is a compelling for national regulators with the cooperation 

of the industry organizations to establish uniform standards for comprehensive and 

objective data collection in order to promote improvements in safety globally. 

Incident Data-Collecting Organizations. There are a number of organizations that strive 

to maintain databases reflecting offshore oil and gas activity and practice, for both 

occupational and process safety, covering such things as fires, explosions, structural 
3

failures, release of hydrocarbons, near-misses, minor and major injuries to personnel, 

and fatalities. 

Offshore Regulators 

The International Regulators’ Forum (IRF), a group of offshore health and safety 

regulators for the oil and gas industry, was formed to promote information sharing and 

collaboration through joint programs. Through its Performance Measurement Project,

3

the IRF collects incident data from its member countries to measure and compare 

offshore safety performance on a common set of criteria.4

The Performance Measurement Project includes annual data related to number of 

fatalities, injuries, collisions, fires, and losses of well control. The program uses hours 

worked, production, number of offshore installations, and the number of well-related 

activities as bases for comparison. IRF data include helicopter-related incidents only if 

they are “at or near” an offshore installation. Detailed information is compiled based on 

data reported by companies to each government regulator. IRF compiles the 

information based on criteria (scope, definitions, and data collation guidelines) 

developed jointly by IRF members.5

INTERNATIONAL REGULATORS FORUM GLOBAL OFFSHORE SAFETY

 There is a comparable data set across the group of 

countries for the years 2006 through 2009. 

Member Country Profiles6 Reporting Authority

Australia National Offshore Petroleum Safety 

Authority

Brazil National Agency of Oil, Gas and Biofuels 

(ANP)

Canada

Canada-Newfoundland and Labrador 

Offshore Petroleum Board & Canada-Nova 

Scotia Offshore Petroleum Board

Netherlands State Supervision of Mines

New Zealand Department of Labour

 3

“IRF Performance Measurement Project,” International Regulators’ Forum,

http://www.irfoffshoresafety.com/country/performance/scope.aspx.

4 Ibid.

5 “IRF Country Performance Measures,” International Regulators’ Forum, 

http://www.irfoffshoresafety.com/country/performance/.

6

“Member Country Profiles,” International Regulators’ Forum, http://www.irfoffshoresafety.com/country/.
4

Norway The Petroleum Safety Authority

United Kingdom Health and Safety Executive

United States Bureau of Ocean Energy Management, 

Regulation and Enforcement

The data are published annually in an online database, accessible as data downloads to 

allow for easy third-party data analysis. 

Industry Associations

The International Association of Drilling Contractors (IADC)7 is an industry organization 

of the oil-and-gas and geothermal drilling and completion industry worldwide.8

Incident Statistics Program

 

Through its , it collects and tracks safety and accident 

information for the drilling industry in order “to record data reflecting accident 

experience which can be compared to other industries, to identify causes and trends of 

drilling industry injuries...”9

Detailed information is collected from drilling contractors voluntarily participating in the 

IADC program.10

IADC data are published in quarterly summary reports and an annual report known as 

the 

 Thus the data is a subset of all oil and gas operations. The program 

collects monthly data related to number of fatalities, number of injuries, and total hours 

worked for both onshore and offshore operations. Participating companies file detailed 

information about each reported incident. In order to ensure the integrity of its data 

and analysis, IADC periodically refines its definitions, categories, and reporting 

guidelines. The data include helicopter-related incidents only if they are at or near an 

offshore installation.

Summary of Occupational Incidents.

11

The 

 In this annual online report, data are 

compared across geographic regions by calculating rates of fatalities and injuries; 

incidents are further analyzed through charts and tables that delineate various 

categories and causes. Each annual online report is accessible as data downloads to 

allow for easy analysis by interested third parties. Given that categories and reporting 

guidelines change, it can be difficult to compare trends over time. 

International Association of Oil & Gas Producers (OGP)12

 7 “International Association of Drilling Contractors,” http://www.iadc.org/.

is an industry organization 

of the world's oil and gas exploration and production (E&P) companies. Through its 

8 “About IADC,” International Association of Drilling Contractors, http://www.iadc.org/iadc.htm.

9 “IADC Incident Statistics Program (ISP) – Introduction,” International Association of Drilling Contractors, 

http://www.iadc.org/asp.htm.

10 Ibid. 11 International Association of Drilling Contractors, IADC Incident Statistics Program 2010: Reporting Guidelines

(January 19, 2010).

12“International Association of Oil & Gas Producers,” http://www.ogp.org.uk/.
5

Safety Performance Indicators report, OGP tracks safety incident data for the E&P 

industry.

Detailed information is collected from OGP’s 43 member companies and their 

contractor employees.13

OGP data are published in an annual report, which provides “trend analysis, 

benchmarking and the identification of areas and activities on which efforts should be 

focused to bring about the greatest improvements in performance.”

 Thus the data is a subset of all offshore oil and gas operations. 

The program collects annual data related to the number of fatalities, number of injuries, 

and total hours worked for onshore and offshore operations. Additionally, companies 

must report information about each incident, indicating the cause of the incident and 

the activity being performed when the incident occurred. Like IADC, the OGP 

periodically refines its definitions, categories, and reporting guidelines. OGP data 

include offshore helicopter-related incidents.

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Other Sources of Offshore Data

 In this report, 

data are presented and analyzed by geographic region, function, and company by 

calculating rates of fatalities and injuries, and incidents are analyzed further by various 

categories and causes. The data are presented in tables in each annual report, but are 

not accessible through direct download.

Det Norske Veritas(DNV) is an “independent foundation with the purpose of 

safeguarding life, property, and the environment.”15 DNV has “collected accident data 

and provided the offshore industry with statistical material since 1975.”16 Through its 

Worldwide Offshore Accident Databank (WOAD), DNV tracks safety and accident history 

to be a source of data “available for offshore risk assessments and emergency 

planning.”17 Through its Leak Program, DNV tracks incidents in the UK HSE Hydrocarbon 

release database in order to allow companies “to calculate leak frequency in process 

equipment and manage [the] risk.”18

The WOAD database is compiled from information available from authorities, official 

publications and reports, newspapers, databases, rig owners, and operators globally.19 

WOAD consists of data for over 6,000 accidents and incidents from 1970 forward.20

 13OGP, Safety Performance Indicators – 2009 (International Association of Oil & Gas Producers, May 2010), iv-v.

 The 

data include details such as “name, type and operations mode of the unit involved in the 

accident, date, geographical location, chain of events, causes and consequences, and 

14 Ibid., iv. 15 ”Safeguarding Life, Property and the Environment,” Det Norske Veritas, 2010, 

http://www.dnv.com/moreondnv/profile/about_us/.

16 “Woad – Offshore Accident Databank,” Det Norske Veritas, 2010, 

http://www.dnv.com/services/software/products/safeti/safetiqra/woad.asp.

17 Ibid. 18 “Leak – Calculate Leak Frequency,” Det Norske Veritas, 2010, 

http://www.dnv.com/services/software/products/safeti/safetiqra/leak.asp.

19 “Woad – Offshore Accident Databank,” Det Norske Veritas. 20 Ibid.
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evacuation details.”21 WOAD also contains technical information about “approximately 

3,700 offshore units including mobile drilling units’ locations and operation modes at 

any time.”22

The 

 Both databases are available for purchase. 

SINTEF Group is an independent research organization based in Norway.23

Offshore Blowout Database

 Its 

“is a comprehensive event database for blowout risk 

assessment. The database includes information on 573 offshore blowouts/well releases 

that have occurred world-wide since 1955. The blowouts/well releases are categorized 

in several parameters, emphasizing blowout causes. A user-friendly interface allows for 

customized search patterns.”

The descriptions contain “51 different fields describing each blowout/well release,” 

which are organized into six groups: “category and location, well description, present 

operation, blowout causes, blowout characteristics, [and] other.”24 The database and 

annual report are confidential and accessible only by the project sponsors.25

From Gathering Data to Setting Standards

Standards are a core component of safety programs for any industry, particularly those 

dependent upon complex processes and technology. Developing international standards 

for incident reporting in the offshore environment is crucial to developing a consistent, 

high-quality, global data set to inform the need for other new and/or improved risk 

management and safety standards.

The offshore oil and gas industry operates internationally with rigs, barges, support 

vessels, and personnel moving from one region to another. Components of a 

deepwater production facility, whether it is being built for Brazil, West Africa, or the 

Gulf of Mexico, are made throughout the world. The consistent application of standards 

can promote safety and prevent pollution, enhance operational efficiency and facilitate 

international commerce. Developing collective, international offshore standards, 

rather than relying on an array of different national standards, would promote efficiency 

and facilitate information sharing to ensure best practices are embodied in standards.

Who participates in the standardization process? The primary groups that govern the 

standardization process for oil and gas activity inside and outside the United States are 

the International Organization for Standardization (ISO), the American National 

 21 Ibid. 22 Ibid. 23 “About SINTEF,” SINTEF, January 7, 2011, http://www.sintef.no/Home/About-us/. 24 “SINTEF Offshore Blowout Database,” SINTEF, April 16, 2010, http://www.sintef.no/Home/Technology-andSociety/Safety-Research/Projects/SINTEF-Offshore-Blowout-Database/. 25 The project sponsors are Statoil, Total E&P Norge, Shell Research Limited, BP Norge, Safetec A/S, Scandpower Risk 

Management, DnV, Lilleaker Consulting a.s., Eni Norge AS, ConocoPhillips Norge, and BHP Billiton.
7

Standards Institute (ANSI), and the American Petroleum Institute (API).

26 ANSI is the 

U.S. Member Body and dues-paying organization of the ISO.”27

The ISO, the world's largest developer and publisher of international standards, is a 

network of the national standards institutes of 163 countries, one member per country, 

with a secretariat in Geneva, Switzerland that coordinates activities.

ANSI is the official U.S. representative to ISO, but delegates most responsibilities for oil 

and gas standards to API. As the U.S. member of ISO, ANSI is responsible for 

participation in those technical areas of work where U.S. interests have indicated 

support. ANSI normally looks to the body that develops national standards in a 

particular area or industry to determine U.S. positions in similar international 

standardization activities. ANSI adds an additional level of transparency to the process 

by providing notifications of U.S. standards development activities, including national 

adoptions of international standards, through the ANSI “Standards Action” newsletter. 

In the case of oil and gas activities ANSI looks to API. Thus this portion of the paper 

focuses on API’s standardization process, as approved by ANSI and ISO. “Part of ANSI’s 

responsibilities as the U.S. member body to the ISO includes accrediting U.S. Technical 

Advisory Groups (U.S. TAGs). The primary purpose of these groups is to develop and 

transmit, via ANSI, U.S. positions on activities and ballots of the Technical Committees 

(and as appropriate, subcommittees and policy committees). These technical issues 

include the approval, reaffirmation, revision and withdrawal of ISO standards.”28

ISO Technical Committee (TC) 67, “Materials, equipment and offshore structures for 

petroleum, petrochemical and natural gas industries” is responsible for the materials, 

equipment, and offshore structures used in drilling, production, pipeline operations, and 

oil and gas processing, and is the most important committee from the standpoint of 

offshore oil and gas operations. API serves as the secretariat of TC 67’s Subcommittee 

4, “Drilling and Production Equipment” on behalf of ANSI. “All U.S. TAGs to ISO must 

adhere to the procedural requirements contained in the 

 In 

accordance with ANSI accreditation procedures, API is required to respond to all public 

comments and objections resulting from this public notification.

ANSI Procedures for U.S. 

Participation in the International Standards Activities of ISO.”29

ANSI Essential Requirements: Due process 

requirements for American National Standards

 Additionally, API must 

also follow the guidelines outlined in 

, which outlines “the minimum 

acceptable due process requirements for development of consensus... The standards 

development process shall not be dominated by any single interest category, individual, 

or organization... The standards process should have a balance of interests.” However, 

 26 API is also a lobbying organization. 27 “ANSI Accredited U.S. Technical Advisory Groups (TAGs) to ISO,” American National Standards Institute,

http://www.ansi.org/standards_activities/iso_programs/tag_iso.aspx?menuid=3.

28 “ANSI Accredited U.S. Technical Advisory Groups (TAGs) to ISO,” American National Standards Institute. 29 Ibid.; ANSI, ANSI Procedures for U.S. Participation in the International Standards Activities of ISO (January 2010).
8

“no test for dominance is required... Appropriate, representative user views shall be 

actively sought and fully considered in standards activities.”

When the ISO committee responsible for petroleum and natural gas was reactivated in 

1989 (ISO TC 67) API offered up a suite of API standards to be used as the basis for ISO 

standards. That coordination continues, with about 70 percent of all the published TC 

67 standards being based on API standards.30

Phases of Standards Development 

The process for developing oil and gas standards generally consists of three main 

phases: establishing the need for a standard, negotiating the specifics of the standard, 

and approving the standard. According to ISO, “[i]nternational standardization is 

market-driven and therefore based on voluntary involvement of all interests in a given 

marketplace.”31

The need for a standard is usually expressed by an industry sector, which 

communicates this need to a national member body. The latter proposes the new 

work item to ISO as a whole. Once the need for an International Standard has been 

recognized and formally agreed, the first phase involves definition of the technical 

scope of the future standard. This phase is usually carried out in working groups 

which comprise technical experts from countries interested in the subject matter.

 ISO describes the standards development process as follows: 

32

Once agreement has been reached on which technical aspects are to be covered in 

the standard, a second phase is entered during which countries negotiate the 

detailed specifications within the standard. This is the consensus-building phase.33

In the ISO process, “The final phase comprises the formal approval of the resulting 

draft International Standard (the acceptance criteria stipulate approval by two-thirds 

of the ISO members that have participated actively in the standards development 

process, and approval by 75% of all members that vote), following which the agreed 

text is published as an ISO International Standard.34

API follows a slightly different method:

API [also] develops industry standards on the basis of consensus. Consensus is 

established when substantial agreement has been reached. Substantial 

agreement means more than a simple majority but not necessarily unanimity. 

 30 David Miller, Director, Standards, API, e-mail message to Commission staff, February 16, 2011. 31 “How are ISO Standards Developed?,” International Organization for Standardization, 2011, 

http://www.iso.org/iso/standards_development/processes_and_procedures/how_are_standards_developed.htm.

32 Ibid. 33 Ibid. 34 Ibid.
9

Consensus is defined as approval by a majority of those eligible to vote and at 

least two-thirds of those voting, excluding abstentions.35

API (as well as ISO) requires proper notification of standards activities “in order to 

provide an opportunity for participation by all directly and materially affected persons. 

Such announcements may be in the form of notices or copies of committee notices, to 

known interested parties or announcements in suitable media, including electronic, 

appropriate for the known affected interests.”

 API’s procedures are 

approved by ANSI for compliance with its “Essential Requirements” of openness, 

balance, consensus and due process. ANSI conducts regular audits of the API 

standards program to ensure ongoing compliance.

36 Public notifications must be issued for: 

meetings of standards committees; intent to develop, revise, reissue, or withdraw 

standards; availability of drafts of standards; and letter ballot approval of new, revised, 

or reissued standards or approval of withdrawal of standards. API also submits “a list of 

planned standards activities each year (both new standards under development and 

existing standards under revision) to the National Institute of Standards and Technology 

(NIST) for publication in the Federal Register.”37

Adoption

 API is one of only two U.S. standards 

development organizations that regularly publish their annual standards plan in the 

Federal Register.

The adoption of ISO/TC67 standards is accelerating internationally. API has now adopted 

75 ISO standards. In the last two years the Russian Federation adopted 30 of the 145 

published ISO/TC67 standards as national standards. The Gulf Standards Organization 

(which provides standards for Saudi Arabia, Bahrain, Qatar, UAE, Oman, and Kuwait) has 

adopted 50 ISO/TC67 standards. Over the last four years China and Kazakhstan have 

adopted 57 and 94 standards respectively, and in the last 10 years the European 

Committee for Standardization (CEN, representing 30 member countries in Europe) 

adopted 124 standards.38

Adoption simply means that an international standard (typically ISO) is embraced by the 

national standards organization (in this case ANSI/API) as a national standard. The 

standard may be revised to accommodate national and regional differences. The 

national adoption must include identification and explanation of these deviations. 

Unless national laws and regulations dictate otherwise, a company may follow the 

guidance in an international standard whether or not it is domestically adopted.

 35 API, Procedures for Standards Development, 3

rd ed. (May 2006, approved by ANSI September 2006), 3. 36 Ibid. 37 Ibid. 38 David Miller, Director, Standards, API, e-mail message to Commission staff, February 16, 2011. 
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Revisiting and Updating 

A five-year review cycle is stipulated by ISO, ANSI, and API. Technological evolution, new 

methods and materials, new quality or safety requirements may render a standard out 

of date. Therefore, ISO has established the general rule that all standards should be 

reviewed at intervals of not more than five years.

39

API follows a different review process: If a standard has not been revised by the end of 

year four of the five year period, API staff will advise the responsible standards 

committee, who will then a) revise the standard, b) reaffirm it, or c) withdraw it. The 

standards committee may ask its parent committee for an extension of up to two years 

for the revision, reaffirmation, or withdrawal of a standard. Any standard that is not 

acted upon (revised, reaffirmed, or withdrawn) at the end of seven years will be 

administratively withdrawn as an API standard. Requests for extensions should 

demonstrate that work is underway to revise, reaffirm or withdraw the document.

 In the ANSI review process, the 

review team must revise, revoke, or reaffirm each existing standard every five years. 

This is a large task performed by industry volunteers and trade associations.

40

API Standards Process

The API Procedures for Standards Development state that “API committees responsible 

for standards development shall maintain written procedures in accordance with API 

Policy 602 addressing individual committee organization, scope, membership, and 

conduct.”

For the API Upstream Process, this is further delineated in the API document 

“Organization and Procedures for Standardization of Oilfield Equipment and Materials: 

Policy and Procedures Guide”, API S1, available at API’s Standards Committee website,

41

“Members of a subcommittee shall be representatives of companies or other interests

whose business is directly and materially affected by the activities and standards under 

the subcommittee’s jurisdiction. Members may include users and manufacturers of 

products covered by the standards, plus other particularly qualified individuals. They 

shall be qualified by reason of training, experience, and company responsibilities.”

the following is stated in 5.3, Subcommittees, and in particular 5.3,3.1, Membership 

General:

Likewise, S1 defines voting members as follows, “[a]ny member of the ECS,

42

 39 “How are ISO Standards Developed?” International Organization for Standardization. 

a 

subcommittee or of a task, work, resource, or advisory group designated by their 

company to vote on consensus issues.”

40 API, Procedures for Standards Development, 8. 41 “CSOEM: Committee on Standardization of Oilfield Equipment and Materials,” API Energy, 

http://mycommittees.api.org/standards/ecs. 

42 Ibid., 2. The ECS is the Executive Committee on Standardization.
11

The document also provides information on how standards are progressed through the 

API committee approval process and provides an organizational model in Figure 1. In 

essence, while the API “Procedures for Standards Development” provide information on 

how the API standards process meets the ANSI essential requirements for balloting, 

comment resolution, etc., the individual committees have procedures for how 

subcommittees are organized and standards are progressed, and are available on the 

API Standards Committee website. 

According to API’s Procedures for Standards Development, “API standards reflect current 

industry practices and encourage best practical environmental and safety performance 

throughout industry.” Current industry practice, however, is not necessarily equivalent 

to “best” environmental and safety performance. Steps should be taken to ensure 

timely sharing of industry research and operational experiences to further strengthen 

the standards process.

API plainly possesses considerable, longstanding technical expertise and has certainly 

authored many widely used standards, especially with regards to equipment and 

general practice. Also, it is important that the regulator actively participate in the 

standards-setting process; doing so allows it to stay current with accepted industry 

practices and understand the relative level of specific standards. Federal and state 

regulators, including staff of the Bureau of Ocean Energy Management, Regulation and 

Enforcement (BOEMRE), participate in the API standards process. According to API, 

regulator participation is considered key to improving industry standards and safety 

performance.43

Regulators’ use of standards 

Standards have an important role in almost every regulatory program, regardless of a 

nation’s culture or regulatory philosophy. In a safety management or safety case 

regime, the operator identifies the standards that will govern an activity, how they will 

be employed, how risks will be mitigated, and how management will ensure that the 

standards are being followed. In a prescriptive regime, the regulator requires 

compliance with referenced or incorporated standards, and approves and inspects 

operations to verify compliance.

According to OGP’s Report on Regulators’ Use of Standards (2010, Report No. 426), 

1,140 different standards are referenced by the 14 regulators that were surveyed; 87% 

of these standards are referenced by only one regulator. This means that only 13% of 

the standards were referenced by two or more regulators, and implies an inconsistent 

application of standards among regulators.44

 43 David Miller, Director, Standards, API, e-mail message to Commission staff, February 18, 2011.

 

44 OGP, Regulators’ Use of Standards (International Association of Oil & Gas Producers, March 2010).
12

The OGP’s report noted that the standards used by the 14 regulators were written by 

more than 60 different international, regional, national, and industry standards 

organizations.45

Unlike many of their international counterparts, US regulators reference only specific 

editions of standards. This means that the regulator must incorporate new versions 

after they are finalized, a time-consuming and burdensome process that may delay the 

use of the latest technical and procedural advances. More API standards (225) are 

referenced than those of any other standards development organization. However, 

almost half of those references are by U.S. regulators, and 49 of the references are for 

production measurement standards. 

Different organizations may write standards that cover the same 

subject matter. For example, at least six different organizations have developed 

standards covering offshore structures. In some cases, different versions of the same 

production safety standard are referenced by different regulators. Also, an ISO standard 

may differ significantly from an API standard with the same title. 

In the U.S., promulgating regulations is a long, costly, and difficult process. Two years is 

typically required per standard, and some new rules have taken a decade or more to 

finalize. By requiring compliance with standards, the regulator may opt to use the 

expertise held by industry and various standard-setting organizations while minimizing 

the burdensome process of promulgating rules.

 45 OGP’s report Regulators’ Use of Standards analyses standards referenced by the following regulators :

• Canada, represented by:

–– Canada-Nova Scotia Offshore Petroleum Board (CNSOPB)

–– Canada-Newfoundland and Labrador Offshore Petroleum Board (C-NLOPB)

–– National Energy Board (NEB)

• China National Offshore Oil Company (CNOOC), China

• Danish Energy Agency (DEA), Denmark

• Department of Labour (DoL), New Zealand

• Department of Mineral Fuels (DMF), Thailand

• Ministero dello Sviluppo Economico (MES), Italy

• National Agency of Petroleum, Natural Gas and Biofuels (ANP), Brazil

• National Offshore Petroleum Safety Authority (NOPSA), Australia

• Oil Industry Safety Directorate (OISD), India

• Petroleum Safety Authority (PSA), Norway

• Russia represented by:

––The Ministry of Natural Resources of the Russian Federation (MNR)

––The Ministry of Industry and Energy of the Russian Federation (Minpromenergo)

• State Supervision of Mines (SODM), The Netherlands

• UK Health and Safety Executive (HSE), UK

• United States represented by:

–– US Coast Guard (USCG)

–– US Minerals Management Service (US MMS).
13

Ongoing and Future Work

The International Regulators Forum, at its October 2010 conference in Vancouver, 

discussed a number of consensus recommendations to improve offshore safety 

including the following:

Regulators should serve as catalysts for learning by distributing information, 

hosting workshops, participating in research, and identifying gaps in standards 

and best practices. Wherever possible, the best standards should be identified 

and applied internationally.46

The regulators agreed that the Netherlands and the U.K. would take the lead on 

assessing options for evaluating existing standards and applying them internationally. 

The two were expected to report back to IRF members during the first quarter of 2011 

with a proposed action agenda.47

 46 “Conference Summary,” International Regulators’ Forum,

http://www.irfconference2010.com/showcontent.aspx?MenuID=940.

47 Elmer “Bud” Danenberger, interview with Commission staff, December 17, 2010.