Focus Sharpens on Chemical Risk AssessmentPublished December 19, 2014
Chemical risk assessment is an evolving element in the health, safety, security, environment, and social responsibility sector of the exploration and production (E&P) industry. On 24–25 February 2015, the Society of Petroleum Engineers (SPE) will hold its first workshop on chemical risk. The workshop, to be held in San Antonio, Texas, will discuss chemical risk related to human health and the environment within the E&P industry.
Kristin M. Koblis is the global manager of environment, health, and safety (EHS) strategic planning for Noble Energy. At an October meeting of the Society of Petroleum Engineer’s (SPE) Gulf Coast Section Health, Safety, and Environment Study Group, she presented her company’s screening process for chemical risk assessment.
Q: Why is the risk-screening process you outlined in your paper and presentation necessary?
A: Noble Energy is committed to protecting human health and the environment. Communities express their concerns of the chemicals the industry is utilizing and the potential for adverse health. Developing a risk assessment approach that factors in hazard and exposure was very important to us. In addition, there are potential regulatory changes to the Toxic Substance Control Act regarding chemical hazard, exposure, and risk. Noble Energy wants to be a leader in evaluating chemical risk.
Q: What are the objectives of the screening process?
A: The process will allow Noble Energy to identify chemicals where no additional concern is warranted and to also identify the chemicals where additional risk characterization and management may be needed. It is also specific to Noble Energy operations and identifies the field-specific exposure likelihood. We felt it was imperative to ensure that the process evaluates not only the potential human health and environmental hazards but also the potential for people or ecological receptors to be exposed to the chemicals in the products. Chemical risk is based on both the chemical’s inherent hazard to human or ecological receptors and the potential for such receptors to be exposed to the chemical throughout the life cycle of the chemical.
Q: How is the risk screening conducted?
A: The process was developed to be consistent with existing publically available approaches, including the US Environmental Protection Agency’s (EPA’s) methods for the Toxic Substances Control Act Work Plan Chemicals, which rely heavily on both the EPA’s Design for the Environment and the UN Globally Harmonized System (GHS). Each chemical in a product was assessed in terms of hazard, persistence, and bioaccumulation. The parameters for hazard followed GHS for human and environmental hazards. Human health and environmental hazard scores, as well as persistence and bioaccumulation scores (each ranging from 1 to 3), were calculated for each chemical in a product.
Then, each chemical in a product was scored (each ranging from 1 to 3) for relative risk. The key element of this step is the exposure assessment, which allowed an evaluation of risk by scoring the potential for exposure to the product using four factors. The four exposure factors included the amount of the product used, the number of locations where the product is used, the potential for human exposure, and the potential for exposure of ecological receptors to the product.
Separate, overall human health and overall environmental risk scores (each ranging from 1 to 3 for low, 4 to 6 for medium, and 7 to 9 for high) were calculated for each chemical, incorporating hazard, persistence and bioaccumulation, and exposure scores.
Q: What are the challenges to implementing the screening process?
A: One of the biggest challenges is obtaining sufficient data to conduct the scoring. Although we encountered confidential business information (CBI), it was not as frequent as discussed in the media. Noble Energy occasionally encountered CBI data. For some products, there will be both product level data and chemical level data for the constituents that are contained within the product. Where both product level and chemical level data are available, a strategy was developed to guide the selection of one or the other source of information to characterize the hazard of the product. Product-level testing data, when available, are typically limited to specific hazard-related endpoints. Although persistence and bioaccumulation data might also be available for a product, such data rarely, if ever, exist.
Efforts were made to find hazard data that would support scoring of all human and environmental parameters for a given chemical; however, in some cases, data were not available for all parameters. In these instances, it was assumed that the practice of adopting the highest human hazard score and highest environmental hazard score available for the parameters that could be scored was sufficiently conservative to characterize the hazard of the chemicals in a product.
For some of the chemicals, no hazard information was available or hazard information was available only to characterize human health or environmental hazard, but not both. Additional discussions with both service companies and chemical manufacturers is needed to obtain additional information.
Q: What is chemical stewardship and how does it fit in the scope of safety in the E&P industry?
A: Chemical stewardship ensures that EHS protection is an integral part of the chemical lifecycle. It is a continued commitment to assessing and mitigating chemical-related risks to both human health and the environment. The development and understanding of the risk scoring involves partnerships with the company’s drilling, operations, and supply chain departments. This ensures that all groups are integrating human health and environmental risk perspectives into chemical use.
Q: How does chemical stewardship apply to social responsibility in the E&P industry, and how will the screening process affect that?
A: Although there are no regulatory requirements for conducting the chemical risk scoring, Noble Energy wanted to ensure we are going beyond any regulatory compliance requirements. The process ensures that protection to both human health and the environment are factored into the chemical uses decisions, thus ensuring that Noble energy is conducting its operations in a responsible manner.