RIASSUNTO
Abstract
This study compares locational differences in regional and national environmental regulatory approaches to offshore environmental protection in relation to chemicals. Environmental regulations set acceptable discharge limits and define management boundaries for all related actions, from setting strategic HSE policy targets to choosing chemicals for specific operations. The local variations in regulations mean that chemicals acceptable in one location may not pass environmental consent conditions in another. Challenges such variability represents to multinational offshore operators wishing to harmonise chemical risk assessment and identify chemical Best Available Technology (BAT) on a global basis are identified and discussed.
Formate fluids are used as an example throughout the discussion. These chemicals are illustrative of some inconsistencies between legal regimes. They demonstrate a low level of toxicity and have positive environmental performance profiles, as illustrated through the use of several case studies. Yet formates cannot be used or discharged in all offshore areas in the same way.
Certain regulatory variations can be traced to how ecotoxicological data is utilised within the environmental consent process. Reliance on single test data for setting absolute thresholds may lead to very different consent conditions than combining results from several tests - which together mimic a simple food chain - and applying this as input to risk modelling. For the case study chemicals, the detailed risk assessment approach indicates a positive environmental profile, favourable for discharge consents. In contrast, the single test threshold approach leads to total containment requirements. In the face of such challenges, unified corporate risk assessment criteria can support informed decision making and give operators the benefit of consistent identification of chemicals representing BAT.
Introduction
The aim of any well construction project is to optimise profitability by delivering a high value well at lowest cost and risk. A contributing factor to the overall value created by such a project is the prudent management of health, safety and environmental (HSE) risks[i],[ii],[iii]. HSE risks related to chemical use and discharge are recognised and prioritised through:
In-house, corporate HSE risk management targets, policies and procedures
Risk evaluation and reduction to meet external regulatory consent conditions.
The internal environmental risk evaluation requirements may be directly related to external environmental consent requirements. As a consequence, corporate environmental risk management targets - and rigour - may vary between locations. This is in some contrast to, for example, health and safety risk management. H&S regulations in different countries or legislating territories vary considerably in stringency, but the details are seldom contradictory[iv]. Global corporations tend to apply global health and safety targets and policies. Environmental regulations on the other hand vary not only in stringency but also in details. Therefore, although environmental regulations around the world tend to encompass the same key principles (pollution minimisation, environmental protection and the use of BAT), the regulatory details may include very different approaches[v],[vi],[vii] to determining acceptable discharges.