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Comments on the proposed changes to the BSEE Well Control Rule

The American Petroleum Institute (API), the International Association of Drilling Contractors (IADC), the Independent Petroleum Association of America (IPAA), the National Ocean Industries Association (NOIA), the Offshore Operators Committee (OOC), the Petroleum Equipment & Services Association (PESA), and the US Oil and Gas Association respectfully submit the following comments on the proposed regulatory revisions to Blowout Preventer Systems and Well Control requirements in 30 C.F.R. part 250. The Bureau of Safety and Environmental Enforcement (BSEE) published these proposed changes on May 11, 2018, in a notice of proposed rulemaking entitled, ‘‘Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Blowout Preventer Systems and Well Control Revisions.’’

BSEE’s proposed revision of the well-control rule will move us forward on safety, help the government better regulate risks and better protect workers and the environment. It is critical that revisions are made that enhance the regulatory framework to ensure updated, modern, and safe technologies, best practices, and operations. 
 
Over the past several years, API and the broader industry have worked closely with the U.S. Department of the Interior in support of numerous new rules, regulatory enhancements, standards and safety programs.  The result of these efforts is demonstrated through tangible steps by the industry and the regulator to significantly improve our capability to prevent, contain, and respond to a potential offshore incident.  A few examples include the Center for Offshore Safety, the Marine Well Containment Company, HWCG, new API standards on well containment and blowout prevention equipment, and Interior’s drilling safety rule, safety and environmental management systems rules, and risk based inspection program.

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Well Control Rule Comments as Filed by API/Joint Trades

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