Sensitive environments - Enhesa’s regulatory registers assure protection

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Oil and gas exploration and production are perhaps the most closely scrutinized activities of all when it comes to protecting the environment, and even more so when it comes to sensitive, or even protected environments. Indeed, a company’s very permission to operate will be contingent at the very least on meeting both the spirit and the letter of the law governing the protection of such environmental treasures. So how can such companies ensure that they are fully compliant with their legal obligations at all jurisdictional levels? Perhaps the most effective approach is to compile a comprehensive and detailed registry of all environmental regulatory and legal requirements that the operations must comply with and link these to compliance verification tools, such as detailed EHS compliance audit protocols. But how can a company ensure that all such requirements are properly identified and included in such registries and protocols?

Enhesa was engaged by one of the world’s six “supermajor” oil companies to develop just such a registry for three separate activities: two in central Asia and one in the Indian Ocean off the coast of Australia. Enhesa’s client, an American multinational energy company active in more than 180 countries and engaged in every aspect of the oil and gas industry, from exploration to production to refining to marketing and transportation, tasked its global business units to develop the necessary mechanisms to ensure that all activities and operations are conducted in strict compliance with all applicable EHS laws and regulations. Three of these business units turned to Enhesa to develop the necessary details of regulatory requirements with which they must comply.

Two such business units are engaged in producing and transporting oil and gas, as well as manufacturing pipeline components, in central Asia and are taking positive steps to ensure that all operations under their control are carried out in full compliance with best management practices as well as all applicable environmental laws and regulations. Enhesa has been tasked to identify the requirements and to detail the company’s obligations in Regulatory Registers for Kazakhstan, Azerbaijan, Turkey and Russia that management can use to implement the necessary compliance programs as well as to meet the requirements of the ISO 14001 international standard for environmental management.

Conscious of past concerns with respect to assuring full compliance, and determined to ensure that its permission to operate should not be compromised, particularly in one of the world’s oldest environmental reserves, the third business unit tasked Enhesa to detail all legal and regulatory requirements its activities must comply with for the planning, construction, operation, and even eventual decommissioning of all facilities in Western Australia. Such activities and installations ranged from the primary submarine gas collection operation, to undersea and overland gas pipelines, a liquefied natural gas (LNG) plant, as well as all ancillary and support infrastructure and activities, such as worker accommodation and recreation facilities, waste management installations, a deep-sea port facility, an airstrip, and marine transport activities and operations.

Of particular concern was that these operations are being carried out in a Class A nature reserve subject to some of the most stringent environmental protection requirements administered by Australian Commonwealth and State of Western Australia authorities. Home to many rare and endangered marine species and birds, the island is subject to extensive quarantine and other protective measures with which compliance is paramount to assure continued permission to operate. Enhesa’s Regulatory Registers, and the data management system to which they are uploaded, have played a critical role in assuring the authorities of the seriousness with which our client takes its regulatory obligations and have thus been instrumental in helping to secure the needed permits and authorizations to proceed with the development of Western Australia’s largest natural gas reserve.

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