The Oil and Natural Gas Industry’s Ongoing Commitment to Safety, Spill Prevention, and Response

The oil and natural gas industry has a strong safety record, despite a work environment that often involves heavy equipment, hazardous materials, high temperatures and high pressures. America’s oil and natural gas industry considers safety its top priority and is committed to developing the technologies, standards and best practices, and programs needed to help ensure that workplace safety is at the forefront of our activities. • The industry is committed to a goal of zero fatalities, zero injuries and zero incidents. Our industry takes any safety or environmental incident as an opportunity to learn and to improve technology, training, operational procedures, and industry standards and best practices. The API Standards Program which dates back to the 1920’s, provides an ongoing opportunity for continuous improvement by, and collaboration among, companies throughout the industry, regulators and other stakeholders, and are accredited by the American National Standards Institute (ANSI). API also provides certification services that are accredited by the ANSI-ASQ National Accreditation Board (ANAB). The industry, through the API Standards Program, has helped create more than 235 exploration and production standards to maintain and improve operational safety. Eighty of these standards are referenced in BOEMRE regulations. These standards are developed under a program accredited by ANSI, and API undergoes regular program audits to ensure the program’s integrity. As an example, API RP 75, Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities, was recently adopted by the BOEMRE into its regulations. API RP 75, along with other API standards and practices, help industry to maintain safe operations and establish a culture of safety, and include the following basic premises: o Encouraging intervention in unsafe or non-compliant situations, and empowering operations managers and supervisors to develop solutions to safety issues and rewarding successful performance. o Ensuring company operating procedures are simple, clear and easy to understand and follow. o Applying good design principles and engineering and operating practices to reduce the likelihood and severity of safety incidents. o Maintaining structured inspection and maintenance programs, applying safe work controls, regularly testing integrity-critical equipment, and adhering to strict procedures. o Using advanced technologies and systems that alert operators to investigate abnormal operating events in offshore operations and facilities. o Routinely testing operating teams on myriad scenarios, including simulated product spills, fires, explosions, natural disasters and security incidents. o Correcting potential risks and determining their root causes to prevent recurrence. o Measuring lagging indicators, which record events that have already occurred, and leading indicators, which focus on the strength of controls, to prevent incidents; including inspections and testing of safety-critical equipment. o Working closely with local, state and federal regulators to ensure safety in the offshore operating environment. Among others, critical industry safety standards include: o RP53 - Recommended Practice for Blowout Prevention Equipment Systems for Drilling Wells o RP59 - Recommended Practice for Well Control Operations o RP T-2 – Qualification Programs for Offshore Production Personnel Who Work with Safety Devices o RP 14C – Analysis, Design, Installation and Testing of Basic Surface Safety Systems on Offshore Production Platforms o RP 14G – Recommended Practice for Fire Prevention and Control on Offshore Platforms o Standard 65-2 – Isolating Potential Flow Zones During Well Construction

API and the other trade associations representing the industry, including the International Association of Drilling Contractors (IADC), Independent Petroleum Association of America (IPAA), and Offshore Operators Committee (OOC), have developed a number of standards and programs, and sponsored workshops and conferences focused on improving safety throughout the industry. For example: • API’s Monogram Program provides the oil and natural gas industry with a way to identify equipment and products that have been manufactured in accordance with API’s drilling, production and refining equipment standards – standards developed with safety as a priority. API’s Worksafe Program provides industry with a way to make sure their workers and contractors have been trained to industry safety standards. The E&P Onshore Operations program provides training on critical safety issues found at onshore job sites and includes an examination covering industry safety practices. The Service Station Contractor Safety qualification program identifies contractor personnel who have passed a standardized examination covering the latest service station industry safety practices. API’s Training Provider Certification Program provides certification to training schools that deliver training to individuals in accordance with industry related standards and regulations. The program was developed to assist organizations in developing oil and gas training that meets the industry’s needs and to assist evaluators in judging the quality and consistency of training providers. IADC’s WellCAP Program uses quality benchmarks developed by industry well control specialists, including API RP 53 and RP 59, to emphasize training in the knowledge and practical skills critical to successful well control operations and to produce competent rig crews. By constantly adapting to industry needs, WellCAP offers the building blocks for a comprehensive well control safety culture throughout the organization. API and the other oil and natural gas trade associations regularly hold conferences on Contractor Safety and Safe Lifting Operations to focus the attention of the industry and regulators on items that are critical to maintaining a safe working environment. As it has done when faced with challenges in the past, industry came together to form four joint industry task forces following the incident in the Gulf to examine what happened, what could be learned from the incident, and how such an incident could be prevented in the future. These task forces made significant recommendations to BOEMRE aimed at reducing risk, increasing safety, and improving deepwater performance. Some of these recommendations involve the development of additional industry standards: o RP 96 – Deepwater Well Design Considerations. Identifies appropriate well design methodologies commonly used to in the industry and supplements the recommendations found in API Standard 65-2 to help prevent a loss of well control. It will also highlight risk and mitigation practices commonly implemented during deepwater casing and equipment installation operations. o Bulletin 97 – Well Construction Interface Document Guidelines. Developed in conjunction with the IADC, this document links the drilling contractor’s safety case with the operator’s safety management system. It will document how management of change and risk assessment processes will apply during well construction activities. It also assigns specific responsibilities for the operator's personnel and provides a means for the drilling contractor to intervene when unsafe acts are identified. In addition, API has begun the process of creating an industry safety program for deepwater operations that will build on API RP 75 and help to drive a culture of excellence throughout the offshore industry. The program will draw on the best and most compatible aspects of safety programs developed by the nuclear and chemical industries, embrace additional aspects of self-regulation from other programs, and utilize independent 3rd party auditing to measure performance.

The United States has the most effective oil spill prevention and response regime in the world. The current system protects America’s natural resources, while being consistent with the petroleum industry’s commitment to the safe production and delivery of energy products with the lightest environmental footprint possible. • Requirements under the Oil Pollution Act of 1990 (OPA) regulate oil spill prevention and response from upstream operations. Among other things, OPA: o Focuses on preparedness, prevention and removal; o Mandates national emergency planning; o Increases the limits of liability for oil spills; o Revises the measure of damages of natural resources; o Establishes a fund for the clean-up costs associated with a spill incident; and o Establishes financial responsibility requirements for offshore facilities. Each facility is required to create and maintain an emergency response plan. This plan, which must be approved by the US Coast Guard, establishes and identifies all of the capabilities and assets the company has put in to place to be able to effectively respond to an oil spill. Plans present a tiered response to a spill incident. This is the standard across sectors of the industry, including transportation, refining, production and exploration. The approach is based on risk assessment, the worst case discharge and the adequacy of barriers to protect against failure of success. All industry production facilities — onshore or offshore — are required to “test” or exercise their response preparedness under the National Preparedness for Response Exercise (PREP) Program. Typically, there are multiple exercises throughout a year, each involving not only the plan holder but also the government agencies and third parties identified in the plan and having a role in the response. Advancements have been made in the deployment and use of spill response technology since OPA. Areas of advancement include the following: o Oil Spill Response Organizations; o Dispersant application according to conditions and application mechanism; o Boom specific to in-situ burning; o In-situ burning as a standard practice; o Advanced computer modeling tracking of incident and location; o Community mobilization; o Strategic use of response network; and o Shoreline protection. These advancements are developed, critiqued and refined regularly within the oil spill response community. Every three years, the International Oil Spill conference provides the opportunity to peer review and present the latest science and research in spill response globally.