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SITUATION
A large national and international oil and gas drilling company operates onshore and offshore drilling rigs throughout the United States, and in several countries around the world. As part of its compliance assurance program, as directed by its Board of Directors, the company solicits the assistance of third-party consultants to evaluate the company’s compliance with applicable environmental and safety regulations and internal policies and procedures.
SOLUTIONS
Premier staff conducted environmental and health and safety compliance audits of the company’s drilling rigs/sites located along the Gulf Coast and in the Gulf of Mexico, in Canada and off Canadian shores, in Egypt and off Egyptian shores, and in and around Indonesia, Thailand, and Nigeria. As part of the compliance audits, environmental and health and safety compliance issues were evaluated and corrective actions proposed, where necessary. Typical laws/regulations against which compliance was evaluated include elements of: Occupational Safety and Health Act (OSHA), Federal Clean Water Act, Federal Clean Air Act, Federal Resource Conservation and Recovery Act (RCRA), Oil Pollution Act of 1990 (OPA), U.S. Coast Guard Regulations, Federal Department of the Interior Minerals Management Service Regulations, Maritime Pollution Act (MARPOL), Basel Convention, Montreal Protocol, and country-specific (i.e., Egypt, Nigeria, Indonesia, and Thailand) regulations. As part of these audits, other evaluations included wastewater and ballast water compliance with the client’s internal environmental compliance program requirements, asbestos abatement status, and Hazcom procedures. Country-specific environmental management plans for Nigeria, Indonesia, and Thailand were also developed based on U.S. and country-specific regulations. Audit findings were reported to client’s executive management, and were used to evaluate regulatory/program compliance and effect remedies where needed.
RESULTS
The environmental and health and safety compliance audit program typically identified several process-related and facility-specific findings that needed to be corrected as part of compliance assurance. The company received such findings without prejudice and strove to correct issues of non-compliance diligently. Premier staff’s involvement in the audit program assisted the company in a consistent, objective review of its worldwide compliance status.