How to survive a rig inspection: Environmental Inspection
A thorough environmental inspection aims to provide the operator with assurance that the drilling contractors’ environmental policies & procedures, routines, planning and remedial actions are in place to prevent unplanned releases to the environment.
Environmental inspections, at the operator’s request, can be carried out as part of a full HSE Inspection or as a stand-alone work-scope.
As with a health & safety inspection, a visit to the drilling contractor’s offices ashore will often be appropriate to meet the key players and commence review of documentation, policies & procedures.
Some drilling contractors and rigs may be certified to ISO 14001: Environmental Management Systems, while some others claim that their environmental management systems have been developed ‘in-line’ with ISO 14001 requirements. If this is the case, they have declared their commitment to environmental protection, pollution prevention and continual improvement. The inspector assesses this throughout the inspection period and looks at how it is achieved.
The inspector seeks to look at and assess the environmental leadership and communications on the rig, including dissemination of appropriate information and crew awareness of environmental aspects and issues.
A review of the environmental aspects & impacts register or equivalent would be undertaken. Good registers consider aspects in normal, abnormal and emergency operations. In conjunction with this, the inspector would consider the effectiveness of environmental committees or ‘Green Teams’.
During the inspection period, the inspector reviews numerous other certifications, policies & procedures for compliance with regulations and industry best practices. These include:
- SOPEP/OPEP
- Spill response plans
- Discharges to sea
- Record books and sampling logs
- COSHH practices
- Chemical mixing practices
- Relevant maintenance records (environmentally critical equipment)
- Mud system integrity, control of overboard lines and oil-based mud procedures
- Bulk loading and handling
- Fuel oil and bunkering
- Inboard fluid transfers
- Waste management and minimization
- Emissions
Documentation reviews are all well and good but ultimately prove only one aspect.
If any operations, e.g. bunkering fuel, are planned when the inspector is on board, he would undoubtedly take the opportunity to witness the operation from beginning to end.
The inspector will also carry out visual inspections from an environmental perspective of many areas and systems on the rig, checking for compliance with regulations, company policies and procedures and best practices.
These would include:
- Drill floor equipment
- Drill floor drainage systems
- HP and LP mud systems, mud storage, mud process and mud mix areas
- Engine rooms and machinery spaces
- Main deck areas
- Spill kits
- Waste streams and storage
- Secondary containment
- Third-party equipment (e.g. cement unit, ROV areas)
By the end of the inspection period, as well as checking compliance, the inspector will have a good overall feel for whether the rig is capable of operating in an environmentally responsible manner.