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Preventing Trash and Debris Accumulation in Offshore Oil and Gas Operations
Tuesday, May 14th, 2019
Offshore oil and gas platforms have many neighbors in coastal waters, including marine wildlife and vegetation, commercial fishing operations, and shipping vessels. Just like any other ship or structure in the ocean, any items brought to an offshore oil and gas rig can fall into the water if they’re not properly secured or disposed of. Marine trash and debris can harm aquatic life and cause economic problems for any industry dependent on the ocean. Any person or company that creates marine trash and debris can be subject to legal action. It’s important for everyone on the rig to know how to dispose of trash and secure items properly to prevent marine trash and debris.
What is “Marine Trash and Debris?”
Any solid items that get into the ocean that aren’t supposed to be there are considered marine trash and debris. These can include natural materials such as metal and wood, as well as man-made materials such as plastic, glass, cloth, and rubber. Most marine trash comes from human activity on land, but it can also come from derelict boats and equipment or be blown into the water during hurricanes or other storms. On offshore oil platforms, unsecured items such as drill pipe thread protectors, 55-gallon drums, pallets, tools, and personal protective equipment are common pieces of potential debris that may need to be secured.
Why is Preventing Marine Trash and Debris Important?
Trash and debris can take decades or even centuries to degrade in the water. Some materials, such as plastic and glass, may not completely degrade at all. Plastic particles can degrade over time to the size of plankton, but marine life can eat these particles, making them sick and introducing plastic into the food chain when they’re eaten by larger fish or other animals, including humans. Marine debris can also injure or kill dolphins, whales, sea turtles, seabirds and other wildlife.
Marine debris can also negatively affect coastal economies. If fish, oyster or lobster populations decline in a polluted area, commercial fishing operations will bring in smaller catches, reducing their profits and affecting the local economy. Marine debris can damage or disable boats, disrupting trade and putting their passengers at risk. Marine trash and debris can also have a major negative effect on local tourism if it washes ashore, including declining visitor numbers as well as increased cost of maintaining beaches and seaside parks.
The Environmental Protection Agency (EPA) and the U.S. Coast Guard prohibit companies and individuals from dumping solid waste into the ocean. In addition, the Bureau of Safety and Environmental Enforcement (BSEE) prohibits companies from discharging containers, chains, equipment or other materials into the ocean. BSEE requires offshore facilities to put durable identification markings on equipment, tools, containers and other materials that could fall into the ocean, and that all materials lost by accident are retrieved or cleaned up as soon as it’s safe to do so.
BSEE states that employees and contractors should complete marine trash and debris training when they arrive on a rig and be retrained on an annual basis. This training should have two parts: a training video or slideshow over marine trash and debris, and an explanation from management emphasizing the company’s commitment to preventing and containing marine trash and debris. All training records should be kept for inspection by BSEE, and an annual report should be sent to BSEE by January 31 detailing the company’s training program and certifying all personnel have been trained.
Reporting and Recordkeeping Requirements
Offshore rigs are also subject to BSEE reporting and recordkeeping requirements. Drilling facilities shall be inspected daily or as often as necessary by personnel on the rig. Any damage or active sources of pollution must be repaired immediately. If any items are lost overboard from the rig, those items must be recorded on the facility’s daily operation report, reported to BSEE, and recovered as soon as they can safely be recovered. Records of inspections or repairs must be maintained either on the rig or at a nearby manned facility for two years.
Placarding and Signage
All employees, contractors and visitors need to be aware of the potential for loose items to fall off the rig. BSEE requires placards to be posted with information about preventing marine trash and debris. These placards should explain what marine trash and debris is, the impact that marine trash and debris has on the environment, instructions on how to secure loose items, and legal requirements for preventing intentional disposal or accidental loss of materials or debris. These placards should be placed in any common area of the rig, including boat landings, helipads, kitchens, break rooms, training and orientation areas, and recreational areas. If a placard becomes lost, damaged or unreadable, it should be replaced as soon as possible.
How to Prevent Marine Trash and Debris
Keeping loose items secure is an important part of preventing marine trash and debris. Some of the most common items lost overboard include hard hats, five-gallon containers, pallets, life jackets, and hand tools. Smaller items should be stowed indoors in lockers, equipment storage areas or marked containers when not in use. Heavier objects, such as drums and pipe sections, should be tied down to keep them from coming loose during storms or high winds. Trash cans and waste disposal containers should be secured so they can’t blow off the rigs themselves and should be closed or covered when not in use. Rigs should have emergency plans in place to secure everything in the event of a hurricane or other major storm.
Companies and individual rigs should perform regular hazard assessments to determine if there are additional controls that rig personnel should use, if there are new things on the rig that need to be secured, or if materials have been lost over the side that can be secured differently in the future. Regular pre-job safety meetings and hazard assessments can help address new hazards that workers or supervisors may have found.
We all have a role to play in keeping our oceans clean and healthy, including those in the oil and gas industry. For more information on BSEE’s Marine Trash and Debris program, click here.