In most countries the legislation regarding the design and operation of oil and gas producing wells does not specifically prescribe production packers or downhole safety valves. When interpreting the legislation, Operators generally specify a requirement for double barriers in wells that can sustain natural flow. Production packers and downhole safety valves are used commonly in completions to satisfy this requirement. The resulting policies provide a standard for well barriers and define an operational envelope that ensures pressure integrity and environmental protection consistent with safe operating practice. Through detailed risk and hazard analysis it has been possible to demonstrate that the elimination of packers and downhole safety valves from completions can be tolerated while achieving substantial savings through reduced equipment, workover and intervention costs. This paper summarises some of the reasoning and methodology used to justify the elimination of packers and downhole safety valves from completions and encourages the wider use of risk-hazard analysis techniques to develop more radical completion solutions.

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