Optimum Worldwide Safety Management for MODUs: Using Our Experiences Toward Adaptation of the ISM Code as an International Standard for the Offshore Drilling Industry
Authors: Tranter Paul , Legrand Michel , Festa Capella , Grieve Andy 
Published: December 2007

Our industry now faces proliferating requests for demonstrations of safe and pollution free operations from regulators and clients worldwide. At times this can be burdensome and confusing. Sedco Forex and IADC have two useful mutual experiences which may assist in tackling this problem. One is the UK safety case regime, the other is the International Maritime Organisation (IMO). We note with interest the development of the IMO International Safety Management Code. It seemed appropriate to use these experiences to work together for a trial assimilation of the ISM Code for MODUs and drilling operations. We give an overview, then consider the tasks for working in the IMO with flag States, Classification Societies, the E & P Forum and with different types of coastal state regulators (inactive, prescriptive, and goal-setting). This paper, the result of our initial investigation, concludes that the ISM Code could provide one worldwide standard for safety management systems for MODUs. We fear further confusion if industry does not act to develop such a standard. We therefore seek to promote discussion toward a drilling industry consensus for action to achieve this aim.

Introduction

The international focus on safety in the offshore industry is unprecedented and we now face a proliferation of requirements for safety management systems from individual coastal states and from major oil company clients and regulators. These requirements have resulted in a number of responses from drilling contractors. Though the general objectives of each party are the same, the modus operandi, or means to the stated end, of conducting safe and continuously improving operations can differ substantially, often causing confusion. For the offshore drilling contractor who moves units between unique sovereign states and undertakes operations for numerous clients, compliance with differing methodologies and differing demands of demonstration can detract from meeting general objectives of safer operations by reduction of risk. What we are left with is, in effect, barriers to international trade promulgated by the coastal state, and abetted by the oil companies whose task is to exploit their mineral resources under the coastal state's system of laws. These barriers could be overcome by cooperation to adopt common standards. However, this is difficult as coastal states are reluctant to harmonize their requirements, apparently due to confrontational aspects of comparing their regulatory regimes.

However, there is one way forward. MODUs belong to the world's shipping fleet and Operate under the requirements of a flag State administration who adopt and act according to codes, standards and conventions of the International Maritime Organization (IMO), often with the assistance of the Classification Societies. Over recent years the IMO has recognized that the shipping industry must continue to take firm steps to improve standards and formalize its approach to safety on an international basis.

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