Developing Regulations Concerning Dispersant Use - A Recommended Good Practice Approach

Coolbaugh, T. S. (ExxonMobil) | Varghese, G. (Oil Spill Response Limited) | Taylor, P. M. (Petronia Consulting Limited) | Cox, R. T. E. (IPIECA) | Lewis, A. (Oil Spill Consultant)

OnePetro 

Dispersant use can be a critical component of an effective response to larger offshore oil spills. In particular, it is recognized that, when used appropriately, dispersants can greatly mitigate the potential for long term environmental impact by preventing floating oil slicks from remaining on the sea surface and stranding on sensitive shorelines. These benefits have been realized following large incidents such as the Sea Empress spill (UK, 1996) and well blowouts in Australia (Montara, 2009) and in the Gulf of Mexico Macondo 2010). In recent years, the decision to use dispersants in response to an oil spill incident often draws much public and media scrutiny. The possible spread of misinformation, combined with unrealistic expectations about the effectiveness other oil spill response options such as mechanical recovery and a lack of understanding regarding the potential for overall mitigation of a spill's impact through dispersant application, can establish major obstacles for its use. In the event of an oil spill incident, regulators need to ensure that all available spill response tools are considered when developing and implementing the response strategy that will be the most effective for dealing with the incident. They also need to have appropriate information to be able to justify their decisions to a wide range of stakeholder communities. Successful use of dispersants during an incident is often time dependent and therefore pre-established and well understood regulations concerning dispersant approval and use are critical to enable a timely decision-making process. The IPIECA (the global oil and gas industry association for environmental and social issues) and IOGP (International Association of Oil and Gas Producers) guidance document on Regulatory Approval of Dispersant Products and Authorization for their Use aims to provide the background and relevant information for use by regulators to ensure that a fit-for-purpose dispersant policy is established as a part of the national oil spill contingency planning framework. The main purpose of the document is to establish a common understanding of what is important for an effective regulatory approval process for dispersants and their use. Industry's recommended approach for developing regulations for dispersant approval and use are discussed, based on the IPIECA-IOGP guidance document. The primary concerns of the oil spill stakeholder community about their use are addressed. Current industry good practice is detailed and a recommended path forward to address relevant issues is offerred, e.g., from dispersant effectiveness and toxicity testing to recommendations on authorization for use and operational monitoring.