Shifting sands of regulatory manifests.

By Payload • September 5, 2020

Part of our core business is understanding change, the different ways it comes to a mature industry and the onset of what will eventually be the digital oilfield.

Sometimes change is driven by a remarkable new technology that creates immediate value or solves an existing industry problem. Sometimes it’s driven by broader market forces, as pressures of price or cost or demographics force a new way of doing things. But sometimes, it’s something far more old-fashioned that creates the conditions for change: top down regulation and the threat of fines.

As part of a broader cross-industry move towards electronic communications, the requirements for manifests are changing in the oil & gas industry, with the adoption of electronic manifests or “eManifests” for hazardous materials.

The changes will affect both producers and service providers within oil & gas, with the potential of significant fines being levied for non-compliance. Transport Canada will be deploying on-the-road inspection vehicles to ensure accurate information for all transported hazmat cargo.

For many players in the oilfields, the new requirements will be a big change to the way things have been done in the past. Handwritten documents have regularly been completed based on quick conversations. Loads have may have been transported with inaccurate or incomplete information and in vehicles not suited for their (sometimes hazardous) contents. Materials have also been received at facilities that aren’t designed to handle them.

While producers are ultimately responsible for manifest contents, drivers (and their organizations) will face fines if they’re caught transporting materials without proper documentation. They’ll have real choices to face when picking up a hazmat load with wrong or incomplete information, or that their vehicle isn’t designed to carry. And at the producer level – they will need to take a hard look at their standard operating procedures. How compliant are they now? What has to change?

Going forward, it will be incumbent on everyone administrating or transporting things from wastewater to chemicals used on drilling sites to contaminated soils to make sure they are compliant with regulatory requirements.

One of the most interesting pieces of this very specific shift is how it challenges broader conventions in the oilfields towards utilizing carbon copy documents, the industry’s comfort with incomplete documentation and a more casual way of doing things. With pressure coming from multiple angles, eManifests are only one piece of the shifting sands of change moving underneath the oilfields. Ultimately, those old ways may finally have to be put aside.

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