International Regulatory Compliance and EHS Planning
Authors: Jones Fredrick V. , Caudle Dan D. , Pappworth S.S.R. 
Published: December 2007

Fredrick V. Jones, SPE Member, and Dan D. Caudle, SPE Member, and S.S.R. Pappworth, SPE Member

Exploration and production companies need to understand and plan for environment, health, and safety (EHS) requirements in international ventures. EHS laws and regulations can differ from one country to another in several ways. For example, laws can be different, they can be at separate levels of development, and they can be implemented in different ways and under variable timetables Some other factors affecting exploration and production companies include the need to satisfy other entities. Other entities may include international agencies, lending institutions and activists in the exploration and production company's home countries.

Companies operating in areas new to them need information on the laws and what they require, regulations and the system for implementing them, timing for obtaining permits and approvals, the level and availability of infra-structure, and the impact of social issues on their projects. These needs will be discussed and contrasted using examples from Russia, Venezuela and the United States. Failure to understand the specific EHS requirements can result in equipment and manpower standing by to proceed, and long waits before permits can be obtained to proceed.

EHS compliance needs in foreign countries can generate problems for exploration and production companies in scheduling, planning and costing projects This paper discusses these problems and provides insight into obtaining information that will help ensure EHS compliance and satisfy all concerns as well as giving the exploration and production companies the tools to conduct their business efficiently.

Introduction

Oil and gas companies need information on environmental issues to enable them to develop realistic costs and timing estimates on which to base decisions in their bidding processes and future operations. Issues of concern (such as obtaining a permit) can be an immediate, an ongoing, or a long term issue which can be influenced by the government, the public, lending agencies, and social issues. For example, in the environmental area an environmental impact assessment (EIA) is an immediate issue that may be influenced by lending agency requirements and public perception. Abandonment costs however, are a long range factor that may be influenced by government policies that could change over the life of the project.

Multi-disciplinary teams that include environmental and safety representation have become commonplace. However, the emphasis is usually on simply complying with the rules and regulations, instead of using compliance to the company's benefit. Formulating a successful bid on new properties requires certain essential information. The primary factors that need to be addressed are the laws and regulations of the country, the permit structure, and the established infrastructure. Project planning goes further than just requiring information on the laws and environmental regulations. It also needs information on the complexity and timing of the permitting process, as well as the supporting data required. In addition, the operator should try and anticipate any future changes in the regulations and requirements in order to determine long-term risk. With the answers to these questions the operator can determine the level of training needed, the cost, and the appropriate timing.

External standards can often also play a major role, in regulatory compliance. In many instances, companies contract with international lending organizations. Most of these organizations have EHS standards that must be followed.

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