The Influence of Non-Prescriptive Legislation in the Evolution of Offshore Well Integrity Practices: An Exploratory Review

Abstract

Among the stochastic tools and risk analysis techniques, ALARP (As Low As Reasonably Practicable) concept has proved to be the most influential guidance regarding the development of regulations and standards of the offshore industry in terms of risk assessment and consequently of equipment integrity. The reasons for that can be traced back to early seventies, when the British Health and Safety Executive (HSE) released its seminal document “The Health and Safety at Work etc. Act 1974”. The 1974 Act was the first regulation to adopt a non-prescriptive approach as a basis to configure the ruling legislation of industrial activities. Since then, risk analysis methods have encountered a vast field of opportunities in the wide range of options proportionated by such framework. In this sense, the Safety Case and the NORSOK standards play a significant role in the non-prescriptive approach application in the offshore industry. The present work discusses the influence of these two frameworks in the definition of the current Brazilian offshore legislation, especially in terms of the design, tests, and monitoring of the so called Solidary Well Barriers throughout the well life cycle. The United States legislation, largely reviewed after the Macondo accident, will be used to counterpoint the prescriptive and non-prescriptive approaches.