This study compares locational differences in regional and national environmental regulatory approaches to offshore environmental protection in relation to chemicals. Environmental regulations set acceptable discharge limits and define management boundaries for all related actions, from setting strategic HSE policy targets to choosing chemicals for specific operations. The local variations in regulations mean that chemicals acceptable in one location may not pass environmental consent conditions in another. Challenges such variability represents to multinational offshore operators wishing to harmonise chemical risk assessment and identify chemical Best Available Technology (BAT) on a global basis are identified and discussed.
Formate fluids are used as an example throughout the discussion. These chemicals are illustrative of some inconsistencies between legal regimes. They demonstrate a low level of toxicity and have positive environmental performance profiles, as illustrated through the use of several case studies. Yet formates cannot be used or discharged in all offshore areas in the same way.
Certain regulatory variations can be traced to how ecotoxicological data is utilised within the environmental consent process. Reliance on single test data for setting absolute thresholds may lead to very different consent conditions than combining results from several tests - which together mimic a simple food chain - and applying this as input to risk modelling. For the case study chemicals, the detailed risk assessment approach indicates a positive environmental profile, favourable for discharge consents. In contrast, the single test threshold approach leads to total containment requirements. In the face of such challenges, unified corporate risk assessment criteria can support informed decision making and give operators the benefit of consistent identification of chemicals representing BAT.