International vs USA EHS Standards: Upstream, Midstream Oil & Gas

I've been asked, regarding the Oil & Gas industry, what are the differences between the USA and International EHS standards.  Interesting question, and one that is very easy to answer.

There really isn't any major difference in the basic legal standards.  The difference remains in the execution of those laws on the books.  Think of it this way, in the USA you really have 50 individual countries that have an overarching standard, but there are 50 individual standards associated with each of those countries.  We of course refer to the 50 countries as states, and I'm not including those other places that are wishy washy such as Puerto Rico.  

So, before I get to much further let us talk about the USA standards.  The federal government has its regulations, and each state has their own.  Now the states' regulations are not less governing than the

federal.  The thing is that in general all the state regulations are the same, yes yes there are some nuance differences that set one state apart from another which typically depend on the industry.  Such as Texas has a lot of petroleum based industry, so that the air regulations are not as tough as those found in California.  

Tough is based on perception.  Air regulations in the USA is a EHS category that ebbs and flows with every passing minute, but the basics again remain the same.  What remains the primary difference between the 50 states is the execution.  Go back to the Texas and California examples. Texas economy remains heavily influenced by the petroleum industry, which California's is not.  So the execution of the regulations in both states is not quiet the same, although the regulators in Texas may want to say otherwise.

One of the things I have seen with most all industries is their confusion on the regulations of the locations they operate.  The reason for the confusion is the goal of meeting the minimum standard.  Why do I say that?  If a industry focused on the best available method, and equipment then the minimum standard would be meet.  But some industry managers believe the bottom line is hurt by keeping up with the regulations, and they are right.  This is because they are operating their facilities one step beyond the minimum standard (regulation).  There is also a economic reason for the minimum, because some companies have evaluated the economics of fine versus compliance.   

Now I'm digressing

It all comes down to implementation of the regulation by the state, as well as the country.

Internationally the situation is the same.  Basically the same regulations, just difference in  implementation which will include who is being regulated.  In underdeveloped (formally referenced as 3^rd world), and developing countries there is a double edge sword based on the industry.  We are focused on Oil & Gas right now so let me speak on that subject.  Oil is a commodity that all oil companies seek, and pay high dollar.  This is something known by all countries, and is seen as easy money.  There are many competing interests from the developed countries both West and East, so big revenues for all involved both private and government.  No one wants to upset that golden goose, so some of those minimum standards may not be expected by the country regulators.  Now if the project is financed by the international financial fund then there is the potential that some level of minimum standard, even for appearance sake, would be expected.

The answer to the question that started this whole discussion:

For the planet there are similar minimum standards for EHS requirements for the Oil & Gas Industry. 

Now how to figure it all out is the question.  You recall my discussion on minimum standards, and the madness that creates?

I'm a strong advocate of proactive management, such that the company establishes the highest economically feasible standard possible.  By doing this the company should be maximizing profits, while meeting nearly every regulator requirement.

In order to accomplish this feat (not really that hard) requires a cooperative working relationship between the EHS and Operations divisions.  And just as important this requires that the EHS leader point of contact be business savvy.  Most EHS professionals can recite the specialty regulations from heart, but do not know how to merge these with business operations.  It is not unusual to hear an EHS manager complain about how no one listens to them, the Rodney Dangerfield of the company.  This is because EHS has the reputation of being overly cautious, and impedance to real world operations. 

A corporate level EHS manager must be business astute, maybe not MBA but at least understand the business model in order to integrate EHS into that model.  No matter how old and mature the industry, Oil & Gas is not new, there is room for improvement.  This is where a good Corporate EHS Manager and EHS Management System comes into play.

A good EHS management system will be built on the highest standard, so that no matter where the industry operates it is the same process; cookie cutter.  The company staff do not work off of different standards simply due to location.  All the equipment and training is then uniform and standardized; this saves money. 

This is not a revolutionary, or touchy feely endeavor.  It is all based on practical business sense.  Looking for the next software solution, behavior based this or that, check list, computer system, etc will not do as much as simply having the EHS and operations teams sit down and run through each process, to include equipment/material, to identify potential improvements in the process as well as safety concerns from those who are in the line of fire.