ASSE Comments for 5-Agency Expert Form on Risk-Based Reg Approaches in Oil and Gas
On September 20-21, OSHA, BSEE, EPA, PHMSA and the Coast Guard came together with stakeholders in the oil and gas industry in Texas City, Texas, to discuss regulatory issues facing the industry at the “Expert Forum on the Use of Performance-Based Regulatory Models in the US Oil and Gas Industry, Offshore and Onshore.” Government Affairs Committee and Oil and Gas Practice Specialty members Gene Barfield and Ron Sokol represented ASSE at the meeting. In its comments, ASSE commended the agencies and OSHA Assistant Secretary David Michaels’ leadership for taking the unprecedented step of bringing together 5 agencies to discuss an issue of common concern. From member input, ASSE’s comments addressed specific questions posed by the agencies aimed at gathering more information on how best to bring together risk-based with needed prescriptive approaches. Among its detailed comments, ASSE shared members’ experience with Process Safety Management (PSM) and expressed its encouragement in the risk-based approach taken in the Safety and Environmental Management Systems (SEMS) being implemented off shore.