The regulatory landscape for oil and gas operations is changing. Regulations and directives issued by provincial bodies like the ERCB must now be followed, as they carry the force of law. Industry recommended practices (IRPs) on technical operating standards are still developed through the Drilling and Completions Committee, but regulators now give them greater consideration. Upcoming focus will likely remain on fracturing operations and developing standards to prevent inter-wellbore communication issues. Operators must stay informed of changing rules and ensure compliance, as ignorance will not excuse deviations from regulatory requirements.

1. So, Just What Rule Should Iin 2012
Regulatory Changes Be Following?
2012 ICoTA Roundtable

2. The Regulatory Landscape is Changing
The old way
Federal/Provincial regulations: must be followed
OHS rules: must be followed, in case of no rules must have
some justification for what you are doing.
EUB/ERCB: Guides on how to do things. ERCB only has
jurisdiction over the leaseholder.
IRPs: Best practices, in 1997 roughly 6 IRPs existed

3. The Regulatory Landscape is Changing
Our lives today
Federal/Provincial regulations: must be followed
OHS rules: must be followed, in case of no rules must have
some justification for what you are doing. IRP’s/Guides/etc
are considered ‘the right way’ in the absence of anything else.
Note ‘Accepted Practice’ is not a defence, ‘Acceptable Practice’
is.
EUB/ERCB: Directives on what must be done. ERCB only has
jurisdiction over the leaseholder but Directive is law.
IRPs: Best practices, in 2011 approximately 24 IRPs exist or in
draft form.

4. Who Issued IRP’s?
• Drilling and Completions Committee (DACC)

5. Who Now Issues IRP’s?
• Drilling and Completions Committee (DACC)
Voting members
ERCB
Traditionally the ERCB and CAPP rotated the position of Chairman. Now
Associate members
each participating member group is eligible. This year Patrick Delaney of
PSAC will be Chairman.
ICoTA
Manitoba
Energy
& Mines
Sask
Energy &
Resources

6. What Do DACC do/What About Enform?
DACC is responsible for the development of recommended technical operating
practices for the upstream oil & gas industry in the areas of drilling, completions and
servicing of wells. The primary focus for DACC will be to develop technical
recommended practices, where the objectives include cost efficiencies, technical
optimization, productivity, safety, and environmental performance.
In developing IRPs, DACC will give priority to:
Development of new IRPs.
Review and revision of outdated IRPs at a maximum time span of 5 years,
particularly where new technology requires new operating procedures.
Providing general support to foster development of non-IRP industry
operating practices that have current application to a limited number of
stakeholders.
The role of DACC is separate and distinct from that of Enform (who focus on worker
safety).

7. Who Decides to Sanction IRPs?
Governance decisions strive for consensus, but can proceed with a majority vote (e.g.
Terms of Reference, Memorandum of Understanding and Funding).
All other decisions (IRP and related decisions) shall be made by consensus.
- Each member organization is limited to one vote.
- All regular members must vote.
- IRP decisions require both consensus at DACC and sanction by the associations (as
outlined in DACC membership).
- Associate members do not have a vote, but are encouraged to provide input on DACC
decisions.
- If consensus cannot be achieved, as outlined above, the matter may be arbitrated by an
independent 3rd party.
- If arbitration is not successful then the outcome is that there is no DACC decision
- No decision at DACC does not preclude an individual association from proceeding to
address an issue at their discretion (note that individual associations always have this
prerogative).
- The consensus decision process is not complete until the member associations have
reviewed and sanctioned an IRP.

8. IRP’s for 2012/2013
• No new IRPs planned to date
• Each IRP has a 5 year review cycle
• DACC can choose to leave IRP as is if there is no
indication of any issues with the current IRP
• Any IRP can be reconsidered should one of the DACC
member organizations deem it necessary and get
committee approval to do so
• Up for review 2013
•
•
•
IRP7: Standards for Wellsite Supervision of Drilling, Completion and
Workovers
IRP8: Pumping of Flammable Fluids
IRP13: Slickline Operations

9. Any Changes to IRP21?
ERCB always envisaged making Section 2: Recommended
Coiled Tubing BOP Stack and Accumulator Specifications law
by including extracts from it in a new Directive 37
• Current status: Multi-stage horizontal fracturing a very
high visibility issue, ERCB resources are focussed on
fracturing Directive
The changes to Directive 37 will happen at some point
http://www.ercb.ca/regulations-and-directives/directives/directive037

10. Oil and Gas Conservation Act
Alberta Regulation 151/1971
With amendments up to and including Alberta Regulation
121/2012
Note: There is now no doubt that Directives 36 and 37 are law.

11. IRP24 Fracture Simulation
The introduction of multi-stage fracturing to the oil and gas
industry increased hydraulic fracturing activity throughout the
Western Canadian Sedimentary Basin (WCSB).
Horizontal wells now have lateral sections that can extend up
to and beyond two kilometers often encompassing multiple
offset wells in proximity of the fracture stimulation operation.
The result is increased inter-wellbore communication.

12. IRP24 Fracture Simulation
IRP 24 is an interim Industry Recommended Practice (IRP)
for the WCSB that industry – along with regulators –
collaboratively developed to address inter-wellbore
communication concerns. It is a risk-based IRP structured
around a hazard management process and a Hazard
Register that logs industry-known hazard scenarios related to
inter-wellbore communication from hydraulic fracturing. The
IRP document and supporting Hazard Register offers a
process and mechanism for Operators to identify and
document suitable controls for Hazard Register scenarios at
the planning stages to be carried through at execution.

13. IRP24 Fracture Simulation
IRP 24 follows a hazard management process to determine:
•
•
•
•
•
•
•
•
•
A Fracture Planning Zone (FPZ);
Identified Offset Wells (IOW);
Special Consideration wells (SCs);
IOW well integrity and risk assessment;
IOW well control plan;
Pre-planning notification to affected Operators;
IOW wellsite procedures;
Program execution; and
Reporting to jurisdictional regulatory bodies.

14. IRP24 Fracture Simulation
The section on inter-wellbore communication should be
released soon. Due to the high profile nature of this topic the
consultation period end November 15, 2012.
http://enform.ca/safety_resources/publications/PublicationDetails.aspx?a=29&type=irp
If there are no comments then it is assumed that everything is
good to go.
It may include having well control devices on adjacent wells.
Could test equipment be required on some wells too?
There have been inter-wellbore communication issues (>20)

15. What Changes Are Coming?
Much focus on crane use in BC
Need operator at controls when holding a suspended load
Safety concerns – putting people in harms way
Competency of operator
Boom Truck Operator certification. The Alberta Advanced Education
Wellhead Boom Truck Operator certification is also accepted by the
Saskatchewan Apprenticeship and Trade Certification Commission for
wellhead operations in Saskatchewan. Enform's Wellhead Boom Truck
Operator training certificate is endorsed by WorkSafeBC for wellhead
operations in British Columbia; however, operators must register with
the British Columbia Association of Crane Safety (BCACS) before they
can work in British Columbia.
Boom truck vs crane
>45 tons considered a mobile crane.
For information on Registered Apprentices :
http://www.tradesecrets.gov.ab.ca/index.html?page=working_in_alberta/working_in_trade.asp

16. What Changes Are Coming?
All IRPs were reviewed against a specific acceptance criteria
regarding what should constitute an IRP.
After review these IRPs were branded Enform IRPs but will be
converted to Guidelines:
- Volume #11 - Dangerous Tree Control
- Volume #12 - Hand Signals for Directing Vehicles
- Volume #17 - Ground Disturbance and Damage Prevention
- Volume #18 - Fire and Explosion Hazard Management
- Volume #23 - Lease Lighting Standards
Lunch and Learn - Enform CALGARY - Tuesday, Oct 30, 2012, 2:00 - 1:30 pm
Breakfast session - Petroleum Club CALGARY - Friday, Nov 2, 2012, 7:30 - 9:00 am
Lunch and Learn - Enform, NISKU - Tuesday, Nov 13, 2012, 12:00 - 1:30 pm
Go to Enform Website:
http://www.enform.ca/safety_resources/publications/Default.aspx?type=guidelines

17. Summary
• Likely that all regulatory focus will be on Fracturing in the short
term
• ERCB Directives 36 and 37 are the regulations that need to be
met in Alberta
• Be familiar with Directive 37
• If you deviate from a requirement – have a written justification
before you do it

18. Summary
• The regulatory landscape seems to be changing, we all need
to pay attention to ensure valid and timely input
• Provincial OHS groups not ‘approving’ IRPs anymore
• Remember regulation is just like marriage – ignorance is not an
excuse!

19. Questions?
Wow, I was pretty sure we
were still in Alberta!