brazil’s safety regulatory framework

8/10/2019 Brazils Safety Regulatory Framework

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Self-sufficiency

Pre-salt discovery

20011998 19991995 20032000 20021997 2004 2005 2006

Constitu tional Amendment N 9/95

Law n 9.478/97Creation of ANP & CNPE

(National Energy Policy Council)

Implementation of the ANP

Concession contracts

signed with Petrobras

(Round Zero)

2007

Directive CNPE n 8/03

2008 2009

Bi ll s for the

Pre-Salt areas

Pre-salt IM group

2010

Pre-Salt

New Laws

2011

11th round

Pre-salt

discoveries

Brazilian Institutional Evolution


3/19

Brazilian Scenario

29 sedimentary basins, in 7.5million km2(2.5 m il l ion o ffsho re)

8,000 km of Atlantic coast

Geological knowledge: < 7%

Under concession < 4.5%

Wells drilled ~ 22,5 thousand

40 national companies

38 foreign companies

400 production fields

345 exploratory blocks

Santos

Campos

Espri to Santo

Recncavo

Potiguar

Sergipe-Alagoas

Esprito Santo

Paran

Parecis

So Franc isco

Par naba

Amazonas

Solimes


4/19

Production

Oil + LNG2.2 million bbl/day

Gas62.8 million m3/day

Imports/Exports Balance

Oil: + 292.7 thousand bbl/day

Gas:34.6 million m3/day

Proven Reserves

Oil~14 billion bbl (*)

Gas~423 billion m3(*) Pre-salt is not included, except Lula field

Brazilian Scenarioan oil exporter in 2010


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Source: PETROBRAS, 2009

Brazilian ScenarioCampos Basin

~ 2,600 wells drilled

56 platforms / 36 rigs

59 production fields

25% of worlds deepwater production


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Billion barrels

More than 30 billion bblLula, Iara, Guar, Parque das

Baleias, Franco

Brazilian ScenarioPetroleum Reserves


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Brazilian ScenarioSantos Basin needs and chal lenges

Needs

40 drillships and platforms

200 vessels

Infrastructure

Dri l l ing Chal lenges

2,200m Water Depth

2,000m salt layer

5,000-6,000m Reservoirs Depth

Product ion Chal lenges

Pipelines integrity

CO2 (08 a 12%)

Offshore LNG

Flow assuranceSource: PETROBRAS, 2009


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Worldwide ScenarioCatastrophic accidents in 2009 & 2010

http://lobusca.com

http://oilspilllawsuit.org

http://theconversation.edu.au

Does industry know how to ident i fy and control r isks?

Is the wo rst-case scenar io known?

Where was the Blowout

Preventer when we

really needed?

AreRegu latorsdoing

their job?

Does the pol i t ical environment

allow regulators to do their jobs?

Do we need str ic ter rules?

Were the events predictable/ avoidable?


9/19

How should safety regulators deal wi thsuch challenges and uncertainties???

Regional ResponseBrazil


10/19

PROCESSSAFETY

(ANP)

ENVIRONMENT

PROTECTION

(IBAMA)

NAVAL

SAFETY(Maritime

Authority)

PEOPLE

SAFETY

(Labor

Ministry)

Marit ime Autho r i ty

SOLAS

MODU Code

Further rules focusedon naval systems(Communication, hull,ballast, navigation,general condition,evacuation etc)

Labor Minist ry

Rules focused on theoccupational safetyand health risks

Petroleum Agency (ANP)

Rules focused on theprocess plant safety

Subsea / Well Control

Brazi l ian Inst i tute of

Environm ent (IBAMA)

Environmental Licensing

Spill response plans

Rules focused on theinteraction of facilitieswith the environment

Regional ResponseHSE Protection Arrangements in Brazil


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1) Very Strict onboard auditing process

- 90 audits on the last 12 months;

- 682 non-conform ity reports;

- US$ 8 mil l ion in fines; and- 10 cautionary m easures (operat ion halt) .

2) Regulator qualification improvement

- Use audits to identify gaps & needs;

- US$ 270,000.00 invested on training;

- Direct appl icat ion know ledge; and- Benchm arking.

3) Regulatory framework revision

- Safety barriers, well control, cementing;

- Imp rove perform ance indicators;

- Operators com petency ;

- Enhanced operat ions m onitor ing ; and

- Enco urage research and development.

4) Enhanced communication

- With environmental and health regulator;

- With industry (workshops);

- With society (website); and

- Among regulators (IRF).

The ANP ResponseMain I ssues


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Horizon had never been to dry dock since it wasbuilt in 2001

failed to rigorously analyze the risks created by

key decisions

procured only six centralizers () even though its

plans had originally called for a greater number

MP 12: Risk Identification and Analysis32 non-conformities (13 serious and 1 critical)

MP 13: Mechanical Integrity47 non-conformities (22 serious and 1 critical)

MP 16: Management of Change (MoC)37 non-conformities (7 serious and 1 critical)

The ANP ResponseSignals & I ndicators

http://oilspilllawsuit.org

682 non-conformity reports

MP 6: Continuous Improvement and

Performance Monitoring46 non-conformities (11 serious)

The ri g received several safety awards and a placeinside Transoceansexcell ence box, which compares

r igs based on safety performance...

Source: National Commission Report


13/19


Source: International Regulators Forum


14/19

Source: International Regulators Forum



15/19

Focus on Safety Management Systems! ! !

Regulatory Framework for Offshore Safety

Performance-Based/Goal Setting Model

Fewer prescriptive requirements

Non-restrictive approach to technological innovations

Minimum requirements for: Mechanical Integrity, Risk Assessment,

Contractors Selection, Internal Audits, Incident Investigations, Management of

Change, Safe Working Practices, Safety Critical Elements Management,

Simultaneous Operations etc.

The ANP ResponseSafety F ramework - ANP Resolution N 43/2007


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Management, Leadership and Personnel

MP 1: Safety Culture and Managerial

Commitment & Responsibility

MP 2: Personnel Involvement

MP 3: Personnel Qualification, Trainingand Performance

MP 4: Work Environment and Human

Factors

MP 5: Contractors Management

MP 6: Continuous Improvement andPerformance Monitoring

MP 7: Audits

MP 8: Information and Documentation

Management

MP9: Incident Investigation

Facilities and Technology

MP 10: Design, Construction, Installation and

Decommissioning

MP 11: Critical Operational Safety Elements

MP 12: Risk Identification and Analysis

MP 13: Mechanical Integrity

MP 14: Management of Major Emergencies

Operational Practices

MP 15:Operational Procedures

MP 16: Management of Change (MoC)

MP 17: Safe Working Practices and Control

Procedures in Special Activities

The ANP ResponseSafety F ramework - ANP Resolution N 43/2007


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- Focus on Process Safety (major hazards) other regulators areresponsible for occupational safety, health risks and environmental issues

(including oil spill response and containment);

- Maritime Authority takes care of the ship features of the facility:

agreement protocols to cope with interfaces;

- Performance-oriented audits based on safety indicators;

- Non-conformity reports system (obligation to do) is a powerful tool to

enforce continuous improvement;

- Onboard presence is necessary to feelsafety climate and culture; and

- Precautionary measures (operation halt) are working much betterthan fines

The ANP ResponseWhat is working well


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National Petroleum Agency

Thank You!

Raphael N. MouraHead of Safety Division

[email protected]

brazil’s safety regulatory framework

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