REACH and the HSE Case for Formate Brines
Authors: Gilbert Ylva Maria , Nordone Adrian , Downs John David , Vaahtera Anu , Pessala Piia , Raivio Tuomas 
Published: February 2016

Europe's biggest-ever single piece of legislation, REACH (Registration, Evaluation and Authorisation of Chemicals), entered into force on June 1, 2007. REACH requires manufacturers, importers and users of chemicals to demonstrate that their products are safe to use for humans and the environment. There will be increasing pressure to substitute chemicals perceived as potentially harmful with less hazardous materials. The legislation is expected to have a significant effect on the management and application of chemicals used by the oil industry in Europe.

This paper reviews the REACH process of approval from an end users point of view. The focus is on how REACH will impact on oil companies' European exploration and production (E&P) activities in practical terms. Previous work in the area has tended to focus on the impact on the chemical manufacturers or on cost. The likely consequences of REACH to upstream oil and gas companies are here demonstrated through a discussion of management requirements, based on how four international oil companies are preparing to ensure upstream operations comply with REACH.

For the European E&P industry, the introduction of REACH will require new management focus and measures to:Identify the potential for discontinuation of supply of vital oilfield chemicalsDesign and implement more rigorous chemical management procedures at site but is also considered toSupport better and more comparative assessment of chemicals' Health, Safety and Environmental (HSE) properties.

In order to illustrate the complex processes of REACH, the regulatory requirements have been reviewed against the HSE profile of formates. These high volume oilfield chemicals used as drilling and completion fluids can be handled by employees with a high level of safety without requiring full chemical hazard suits. Formate brines demonstrate a low level of toxicity to humans and the environmental impact is significantly less than that of many traditional brines. In the tightening regulatory environment this effectively means that compliance is less arduous to achieve and requires less chemical specific management measures.

Introduction

The new European chemical legislation, REACH (Registration, Evaluation and Authorisation of Chemicals), represents a major revision of European chemicals management, replacing some 40 existing EU Directives and Regulations. An objective of REACH is to place the responsibility of demonstrating the safety of chemicals with the manufacturers, importers and users of chemical. At the same time, the aim is to minimise the use of animal testing and encourage the substitution principle. The legislation encompasses all chemicals or substances, including oil field chemicals such as drilling and completion fluids.

This paper looks at how REACH will impact on oil companies with upstream European activities. The effect of REACH is demonstrated by looking at measures four international oil companies have identified or implemented to ensure compliance of their upstream oil/gas Exploration and Production (E&P) operations with the regulations.

The requirement within REACH to demonstrate limited hazard in order to manufacture, import or use a chemical is indicative of a global trend of an increasingly tight regulatory approach to the control of chemical risks.

The subject scope of this paper has been limited to a discussion of the effect REACH will have on management decisions and compliance procedures related to the essence of REACH, namely: Ensuring safe use of chemicals.