Environmental Management Systems
Environmental management systems are tools by which government and industry can strive to improve environmental compliance and perform- ance. A number of management system guidelines have been produced. Such systems generally require the establishment of:
- management commitment to managing environmental performance;
- a process for identification of applicable environmental legislation, regulations and standards; and
- a process for attaining continuous improvement of environmental performance.
The ISO 14000 series of standards focuses on corporate environmental management systems and operating practices, products and services. The standards promote continual improvement without specifying actual standards of performance. Under ISO 14001 (24), companies may register their environmental management systems when it has been demonstrated to conform to the specifications provided in the standard.
The European Union’s Eco-Management and Audit Scheme (EMAS) was made available in 1995 (25) as a tool for companies and other organisations to evaluate, report and improve their environmental performance. The European Commission has recognised ISO 14001 and its European counterpart, EN ISO 14001, as establishing a specification for environmental management systems corresponding to its regulations. (26)
Both OGP and API have produced industry- specific guidance on the development of combined safety and environmental management systems. (27,28) OGP has worked with UNEP to produce specific guidance on ‘Environmental Management in Oil and Gas Exploration and Production’. (29) In addition, the IADC has developed guidance on the development of combined health, safety and environmental management systems for mobile offshore drilling unit operations in the north-west European region. (30)
Properly implemented corporate environmental management systems continuously challenge management to assess both current operations and new endeavours to develop approaches that will help them achieve improved environmental performance, with or without the imposition of specific goals or standards by regulatory bodies.
Compliance with regulatory standards can be improved by a systemised process for identifying the applicable standards, incorporating them into company policies and procedures, distributing them to operations personnel and providing appropriate training. For drilling contractors, this might be difficult. Environmental permits or stipulations are generally issued to the operating company, can be site-specific and may be regarded as proprietary. Where such permits are in the public domain or are made available to the contractor, an important issue is whether the contactor relies on the operating company’s interpretation of the requirements or its own.
Adopting new or improved technology can be one means of improving environmental performance. For example, using slim-hole or expandable casing technology provides the potential for a well to be drilled with the production of fewer cuttings and with less total energy expended when compared with a traditional telescoping well design.
Unfortunately, these benefits can be offset by the more complex procedures required to drill such wells, the more complex well control situations that may be encountered and the potential for a longer period for return on investment because of lower production rates in the smaller well bore. Similarly, diesel engines can be fitted with selective catalytic reduction units to reduce emissions of certain pollutants. However, such units tend to reduce both fuel efficiency and the engine’s ability to respond rapidly to increased power demands. A drilling contractor may fit such equipment to satisfy the demands of one client, only to find that subsequent clients do not wish to bear the increased costs. For the contractor, this is difficult to reconcile with the goal of ‘continuous improvement’.
Revising operational procedures to improve efficiency can also improve environmental performance, for example the use of sharing agreements to obtain greater efficiency in the use of aircraft and supply vessels, or eliminating ‘standby boats’. However, the cost, in terms of responsiveness or safety, may be unacceptable either in terms of operations or to the regulator.
Environmental management systems also challenge management in other ways. Prescriptive regulatory standards may relieve management of difficult decisions on comparative benefit. Regulatory standards tend to be ‘stovepipe’ standards, i.e. they target environmental ‘benefits’ in one specific area, having already determined that potentially adverse impacts in other areas need not be considered, or simply ignoring such impacts. For example, prohibiting seabed disposal of drill cuttings solves perceived location-specific water quality problems; however, it requires that another disposal site be identified, that the cuttings be stored, handled and transported to that site (with the attendant safety concerns, energy usage and potential for spillage) and, ultimately, the disposal at the chosen site be mitigated.
Operating under an environmental management system, management is charged with deciding on the comparative benefits of the possible alternatives, with the potential of subsequently being asked to justify its decisions to shareholders or others with interest in the management system. Shareholders and others may also wish to evaluate the environmental performance for specific operations or activities or compare the company’s environmental performance with that of its peers. Some of the multinational oil producers who have reported their environmental performance publicly have already come under pressure to disaggregate their data so that their performance could be examined in specific areas. While the drilling contractor and its equipment and personnel clearly will impact the environmental performance of a particular operation, the operating company’s commitment to improving environmental performance will have a far greater impact. The operating company not only selects the contractor, but generally dictates the design of the well and the materials to be used in its construction.
Only the operating company can effectively make comparative assessments of the environmental impact of one development project against another on either a regional or global basis. Ultimately, it is the environmental ethic of the operating companies that will drive environmental performance in the drilling industry.
Category:
Environment
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