DRILLING FLUID REGULATIONS OUTSIDE LATIN AMERICA

ABSTRACT
In recent years, drilling fluid use and discharge regulations have become increasingly restrictive and
complex. Regulators have been principally influenced by European or US policy. This paper will give
a brief history of the evolution of drilling fluid regulations in these two arenas, and give an overview of
use and discharge regulations on a global basis. Finally, the paper will examine future developments of
regulatory regimes by government departments and the strategies that operators may adopt in order to
achieve compliance.

INTRODUCTION

OIL INDUSTRY-ENVIRONMENTAL REGULATIONS AND POLICY

The requirement for countries to regulate the use and discharge of drilling fluids has been the result of a
number of drivers. In using any marine resource, there tend to be conflicts of stakeholders- for
example the needs of sectors such as the oil industry, tourism and the fishing industry may be in direct
conflict with each other. Each of the sectors may be very wary of each of the other’s activities. This
may be founded in poor past experiences, lack of understanding or any of a wide range of reasons.
Implementing regulations may implement controls to safeguard each resource users interests. In some
cases, regulated industries may even prefer for there to be some kind of statutory control in place, so
that future retroactive liabilities can be minimized and “bad actors” can be driven to make
improvements, thus potentially improving the image of the whole sector.
Political and public pressure at the citizen level may be driven either by participation in directly
affected user groups. Alternately, this may be driven by a growing public and political interest in
environmental issues and a wish to increase environmental protection as ‘doing the right thing”. Such
a mindset may apply even if some regulatory decisions are made which do not actually have positive
impacts on the whole environment, but which protect a local area of interest. It may be more
acceptable to the public to have waste materials shipped in to shore i.e. “zero discharge”, instead of
discharging them at sea, even if the impacts of shipping to shore and land disposal has a greater effect
than a controlled discharge at sea.
In addition to internal pressures to regulate, some countries have signed international conventions
which mean that they have to bring about legislation in compliance with their obligations. Examples of
this are “OSPAR”- the Oslo and Paris Commission- impacting the North East Atlantic, the “Barcelona
Convention” which covers the Mediterranean Sea and “HELCOM”, the Helsinki Commission which
covers the Baltic Sea.

MEASURING ENVIRONMENTAL IMPACTS OF OILFIELD ACTIVITIES

It is clear that as a result of the nature of chemicals in use in the drilling fluids industry, the
environment can be impacted by both uncontrolled releases and controlled releases of waste as a
disposal route. In order to minimize the impacts of either intentional or unintentional discharges,
drilling fluid suppliers have endeavored to minimize the environmental impacts of the chemicals they
use. It is important to note that minimization of environmental impact must be considered in
conjunction with the technical performance of the fluids used. The very products that have a strong
technical appeal may be the ones that show greatest impact due to the action of the active ingredient.
For example, a particularly effective surfactant may also show higher toxicity than a less effective
surfactant. If lower volumes of the active material are used, the impacts on the environment on
discharge can be lessened. If “green chemicals” are less effective than conventional counterparts then a
balance must be drawn between environmental impact and technical performance.
In order to establish the potential for environmental impact of a product of material it is clearly
unreasonable, wasteful and harmful to apply it to the environment into which it may be released to
study potential for impact, so a series of surrogate tests have been derived. These are aimed at
examining the following ecotoxicological characteristics of the material:

• Toxicity
• Biodegradability
• Bioaccumulation potential.

TOXICITY
Many materials will show toxicity to plant or animal life if applied in sufficient quantities. This may
even include commonplace materials that the human race may consider as food stuff. In the context of
drilling fluid chemistry, chemically active materials such as emulsifiers, alkalinity modifiers and
thinners are expected to show greater toxicity than more inert materials such as mineral powders,
polymeric gels and lost circulation fibers. Therefore it is important to prioritize the assessment of some
chemicals above others. After a thorough investigation, materials that are especially toxic may even be
flagged as candidates for substitution by some governments. Fluids suppliers then face the challenge of
producing materials that show good environmental acceptability without any trade-off in technical
performance.

HOW DO WE MEASURE TOXICITY?

The toxicity of materials can be measured in two principal ways. Firstly, we can examine the lethal
effect of a material by measuring the concentration at which it becomes so toxic that it causes death in
a population of animals. Alternatively, we can use more subtle sub-lethal tests and observe changes in
an animal’s behavior at a certain concentration of test substance, for example changes in breathing or
feeding rate, or altered reproductive output. These two forms of toxicity tests are referred to as LC50
and EC50, representing Lethal Concentration, or Effective Concentration which affects 50% of the
population being observed.
When conducting a study of a material’s toxicity, it is always important to consider that material’s
environmental fate. For example, when examining marine discharges of something that is insoluble
and denser than water, we should examine the potential impact on seafloor dwelling animals. In
contrast, if our test substance is soluble, it will remain in the water column, so we may want to examine
the toxicity of that substance using animals that live in the water column. This is important when
considering what we may expect the impacts of drilling fluids to be. Invert based drilling fluids, if
discharged to the sea, especially on the surface of cuttings, will sink to the seafloor. In contrast, water
based drilling fluids tend to be dispersed throughout the water column. This means that it is important
to ensure that the toxicity test for the drilling fluid matches the environmental fate of that fluid.
So- we now know that drilling fluids can be tested using a variety of methods, but what do the results
look like? Commonly, we will take a range of concentrations of the test substance, and then expose our
organisms to that substance. A number of replicates (sets of animals) are exposed to each
concentration, so that we can account for the biological variability as much as possible. Table 1 gives a
typical set of results of a toxicity test.
Table 1- Example of survivorship of 5 replicates of 20 animals in 5 concentrations of test
substance.
Concentration Rep 1 Rep 2 Rep 3 Rep 4 Rep 5 Average
(ppm)
100,000 0 0 0 0 0 0
50,000 9 7 6 7 8 7.4
25,000 10 11 13 9 10 10.6
12,000 15 16 18 1 15 16
0 20 20 20 20 19 19.8
We can see that there are five replicates, each with 20 animals in each replicate, and a range of test
concentrations from 0 ppm to 100,000ppm. Generally, the animals in the 0 ppm concentration did not
suffer mortalities, while the ones in the highest concentration of 100,000 ppm did not survive, with no
survivors (100% mortality) being recorded. If we plot the data (Figure 1) we can see the relationship
between toxicity/mortality and concentration. The LC50 in this case is around 28,000ppm. Usually
software is used instead of graphical methods to calculate the LC50 value.

100
90
80
70
Percent Survival

60
50
40
30
20
10
0
0 20,000 40,000 60,000 80,000 100,000
Concentration (ppm)

Figure 1- Relationship of Survival and Concentration, with arrow indicating lethal concentration
at which 50% of the population shows mortality (LC50).
The species used for toxicity testing in Europe under OSPAR requirements include a sediment bioassay
using amphipod crustacean Corophium volutator, a fish toxicity test using juvenile Scopthalamus,
toxicity to marine copepods using Acartia, and a marine algal growth inhibition test using Skeletonema
costatum. In the United States, sediment toxicity tests are carried out using the amphipod Leptocheirus
plumulosus as the test organism. Suspended particulate phase (water column) toxicity tests are carried
out using the Mysid shrimp (Americamysis bahia).
Tests are not always confined to aquatic media. In some areas, toxicity tests have also been done on
soils- for example wastes have been mixed into soil and the germination and subsequent growth of
plants and survival of earthworms has been observed.

BIODEGRADATION
Once we have intentionally or unintentionally discharged a substance to the environment, whether it is
toxic or not, unless that material is one that is naturally occurring, then it is desirable that it degrade to
something less toxic, or preferably a material that is naturally occurring. Mineralization to CO2 and
H2O is even more desirable. One example may be that of drill cuttings piles. It is clearly undesirable
to have the base fluid present in drill cuttings still be present in sediments on the seafloor underneath an
offshore rig several years after drilling has ceased. A more favorable outcome would be for the base
fluid to completely degrade, i.e. to CO2 and H2O, and for there to be indistinguishable differences on
comparing near-field and far-field sediment hydrocarbon concentrations. We may even be able to
enhance disposal sites by designing fluids that have beneficial effects while breaking down, for
example in a land farming situation it may be useful to have fluids that will break down and release
plant nutrients Nitrogen, Potassium or Phosphorus in controlled amounts if the material is spread to
land.

HOW DO WE MEASURE BIODEGRADATION?

As for the toxicity test, the fate of the substance must be considered when designing an investigation
into biodegradation of a substance- if their fate is the seafloor then it is appropriate to run a test of the
substance mixed into sediment and submerged in seawater. If the material will be spread onto land,
then it should be mixed into soil, and tested in air, or at least tested in freshwater.
Unfortunately, many of the early tests for biodegradation used in the oilfield were “borrowed” from
other industries, and the results of these tests are not always appropriate. For example, the household
and industrial surfactant industry was concerned about the persistence of laundry and household soaps
and detergents in the early 1960’s. These materials were not being degraded in sewage treatment
plants and were finding their way to the environment where they gave problems with foaming and
toxicity. A test was devised which combined the materials with freshwater and sewage treatment plant
bacteria. This modeled the system into which the detergents were placed, but the method is a poor way
of examining the environmental fate of drilling fluids. The inclusion of sewage plant bacteria can give
a misleading result if we are examining drilling fluids –the materials will not find their way to a sewage
treatment plant for treatment.
Sometimes, drilling fluid components will end up on land, or in the water column (for example water
based fluids), where oxygen is available, and sometimes the fluid components will be buried in the
seafloor, where very little to no oxygen is present. Therefore two groups of tests are used in
determining biodegradation of drilling fluid components- one is the aerobic test which is always run in
an excess of oxygen, the other is an anaerobic test, which is run in the absence of oxygen.
The most recently developed biodegradation test for drilling fluids is the US modification of ISO
11734. This has been adopted by the US-EPA as the appropriate biodegradation test for synthetic base
fluids. The base fluids to be investigated are mixed with marine sediments under conditions where
oxygen is purged from the system. Water is added. An indicator of oxygen presence is added to show
if aerobic conditions exist (Figure 2). Bottles are incubated in the dark, and periodically the gas
volume produced is measured. A control sample is run. Using the difference between gas volume
produced in control and experimental bottles, in conjunction with knowledge of the carbon content of
the base fluid, the percentage theoretical biodegradation can be calculated.

Figure 2- Schematic of Biodegradation test US modification of ISO 11734

Other biodegradation tests have also been used, and continue to be used. European regulators call for
use of OECD Guideline for Testing of Chemicals 306 (1992) which is a seawater, closed bottle method
which is run aerobically. In the past, anaerobic method ISO 11734, has been used, as well as methods
that have predicted degradation in more naturalistic conditions1

BIOACCUMULATION
Some organic materials have potential to bioaccumulate- that is; they can accumulate in tissues of
animals that live in the environment into which they are discharged. This is undesirable as the eating
quality or toxicity to humans and other predators of those animals can be increased. Bioaccumulation
tends to occur because accumulative chemicals can easily pass through cell membranes, and also
accumulate in fats. The accumulation can be measured using actual animals, but this is very time
consuming, and costly, so a surrogate fat is used. In the OECD Guideline for Testing of Chemicals
1981, 107 a “shake flask” method using n-octanol and water is described. In this, build up in fatty
tissues of animals is simulated by adding the substance to n-octanol and water layered in a separating
funnel, shaking this mixture for 24hrs at 20-25ºC, and then analyzing the n-octanol and water to
examine which phase the substance has partitioned to. From this, the octanol/water Partition
coefficient (Pow) can be calculated.
The affinity of a High Performance Liquid Chromatography HPLC Column for a substance can also be
used as an alternative to the shake flask method. This is described in OECD guidelines for testing of
chemicals, 1989-117. The US regulators have determined that sufficient is known about the
bioaccumulation of oilfield chemicals, and that this has been sufficiently described in the literature that
they do not require testing. However, in European OSPAR countries, testing of organic components of
drilling fluid chemicals with a molecular weight of <300 is required.

HEAVY METALS
The potential for heavy metals to impact the environment has been well described in the literature, with
the high toxicity of cadmium (Cd) and mercury (Hg) receiving particular attention. Barite, a mineral
widely used for weighting up drilling fluids, has potential to bear heavy metals. Therefore controls
have been put on Cd and Hg in some countries. In the US, this is 1mg/kg for mercury and 3mg/kg for
cadmium.

OIL SHEENS
When oil is present on the surface of a body of water, only very small amounts can give a distinctive
sheen. In the US, the presence of a surface sheen is used as an indicator of the presence of free oil.
Since this is used as a regulatory tool in determining whether an unplanned release of oil has occurred,
if sheening of the surface of a water body is observed during or after discharge of drill cuttings, or
drilling fluids, this is a reportable to the US Coastguard under Section 311 (33 USC 1321) in
enforcement of oil spills (Section 311 is also known as the Oil Pollution Act).

SALINITY
Spills of brines, drilling fluids, produced waters and other salty materials can have a profound and long
term effect on the quality of soils and freshwaters. Brine spills can be very difficult to remove-
inorganic brines do not biodegrade, and the organic materials- e.g. formates and acetates are not widely
used, frequently because of high cost. Brines must be washed out of soil to remove effectively, which
can have an effect on local water tables, thus restrictions can be placed on the electrical conductivity
(EC), sodicity or chloride content of wastes that are to be applied to land. Frequently this is dictated at
the state or provincial level.
CONTROLLING ENVIRONMENTAL IMPACTS

QUALITY OF MATERIAL
The existence of tests to investigate toxicity, biodegradation, bioaccumulation and other characteristics
that can cause environmental impact means that regulators can use as tools means that they can reduce
or minimize environmental impacts by insisting that materials meet certain standards of biodegradation
and toxicity before they can be discharged, or even used in certain environments. Regulators can
identify Best Available Technology (BAT) can be identified by comparing test performance, and
materials can even be ranked in terms of environmental performance.

QUANTITY OF MATERIAL
However innocuous a material is in terms of toxicity and biodegradation, it is generally best to
minimize the amount of material that is discharged. This waste minimization is usually in the interest
of the operator, especially in the case of use of expensive materials such as synthetic based fluids. In
this case governments may rely on the cost savings achievable by minimizing discharges as a
regulatory tool. Alternatively, restriction can be placed on the amounts of fluid that can be retained on
drill cuttings. This has been done in the US, with the EPA using data on performance of various
cuttings drying and cleaning equipment to set limits at which synthetic based fluids can be discharged
on drilled cuttings.
STOCK LIMITATIONS VS. RIG SITE REGULATION
Some regulators ask for testing of chemicals to be carried out before they can be used. Others like us
to examine what we are discharging- “end of pipe” regulations. There is a clear dichotomy in the US
and Europe over the issue of stock vs. discharge limitations. While discharge limitations measure the
direct toxicity of materials as they are discharged, the repeated testing and uncertainty of compliance
while operations are continuing is a drawback. The cost of this testing activity is borne mainly by the
operators. In contrast, the stock limitations allow operators to seek permission to discharge materials
before use and, in the absence of discharge limitations, are more confident of compliance with permits
to operate, while the service companies pick up the costs of testing.

SUMMARY AND FUTURE TRENDS

It is clear that while individual countries have been active in developing their own environmental
regulations, the strategy adopted by European regulators, and to a lesser extent US regulators has had a
significant influence. Since the late 1990’s/early 2000’s when European regulators barred the
discharge of invert based fluids, countries developing regulations and seeking direction on minimizing
impact of invert based systems on the environment have been more strongly influenced by the US.
The future of drilling fluids and discharge regulations will include the imposition and possibly
tightening of use and discharge regulations. A number of countries that are significant producers of
hydrocarbons still have minimal environmental regulations. They are currently assessing the
regulatory tools available, and in consultation with other governments, industry specialists and operator
and service companies, such countries are gradually building a portfolio of laws, guidelines, local
bioassay facilities and trained technicians to ensure that impacts of drilling activities are minimized.
APPENDIX 1

Summary of tests required by European and US Regulators

Applicability
Test Type Test Name USA Europe
Biodegradability
OECD Guideline for testing of Chemicals 306 ●
(1992). Biodegradability in Seawater, Closed
Bottle Method.
Modified ISO11734:1995 method: Water quality - ●
Evaluation of the ‘ultimate’ anaerobic
biodegradability of organic compounds in digested
sludge - Method by measurement of the biogas
production (1995 edition).
Toxicity
PARCOM (1995), A sediment bioassay using an ●
amphipod Corophium sp. Oslo and Paris
Commissions Protocol.
Paris Commission (PARCOM 1995). Protocol for ●
a Fish Acute Toxicity Test. Oslo and Paris
Commission Protocol.
OECD Guideline for Testing of Chemicals 203 ●
(1992). Fish, Acute Toxicity Test.
ISO 14669:1999(E) Water Quality - Determination ●
of Acute Lethal Toxicity to Marine Copepods
(Copepoda, Crustacea).
EN ISO 10253 : 1998 Water Quality - Marine ●
Algal Growth Inhibition Test with Skeletonema
costatum and Phaedodactylum tricornutum
OECD Guidelines for the Testing of Chemicals ●
Method 201 - Alga Growth Inhibition Test
 ASTM E1367–92 method: Standard Guide for ●
Conducting 10-day Static Sediment Toxicity Tests
with Marine and Estuarine Amphipods.
Leptocheirus plumulosus as the test organism and
sediment preparation procedures specified in
Appendix 3 of 40 CFR 435, Subpart A.
“Suspended Particulate Phase Toxicity” as applied ●
to BAT effluent limitations and NSPS for drilling
fluids and drill cuttings refers to the bioassay test
procedure presented in Appendix 2 of 40 CFR 435,
Subpart A.
Bioaccumulation Potential
OECD Guideline for Testing of Chemicals 117 ●
Partition Coefficient (n-octanol/water) by HPLC
1989.
Free Oil Appendix 6 to Subpart A of Part 435— ●
Reverse Phase Extraction (RPE) Method for
Detection of Oil Contamination in Non-
Aqueous Drilling Fluids (NAF) Federal Register
Vol. 66, No. 14. January 22, 2001.
Entrained Oil Appendix 5 to Subpart A of Part 435— ●
Determination of Crude Oil Contamination
in Non-Aqueous Drilling Fluids by Gas
Chromatography/Mass Spectrometry (GC/
MS) Federal Register Vol. 66, No. 14. January 22,
2001.
PAH Content EPA Method 1654, Revision A, PAH Content of ●
Oil by HPLC/UV,Methods for the Determination
of Diesel,Mineral, and Crude Oils in Offshore Oil
and Gas Industry Discharges, EPA–821–R–92–
008, December 1992.
APPENDIX 2
Useful sources of further information
Country/Region
Canada
Canada- British Colombia
Canada- Alberta
Canada- Canada-Newfoundland Offshore Petroleum Board
Canada- Canada-Nova Scotia Offshore Petroleum Board
Canada-National Energy Board
USA
USA-Alabama State Oil and Gas Board
USA-Alaska Oil and Gas Conservation Commission
USA-Arizona Oil and Gas Conservation Commission
USA-California Department of Conservation Division of
Oil, Gas and Geothermal Resources
USA-Colorado Bureau of Land Management
USA-Florida Department of Environmental Protection
USA-Illinois Department of Natural Resources Division of
Oil and Gas
USA-Indiana Department of Natural Resources Division of
Oil and Gas
USA-Kansas Corporation Commission Conservation
Division
USA-Louisiana Office of Conservation
USA-Michigan Department of Environmental Quality
USA-Mississippi State Oil and Gas Board
USA-Montana Board of Oil and Gas Conservation
USA-State of Nevada Commission on Mineral Resources
Division of Minerals
USA-New Mexico Energy, Minerals and Natural Resources
Department
USA-New York State Department of Environmental
Conservation
USA-Welcome to the North Dakota Industrial Commission,
Oil and Gas Division
USA-Oklahoma Corporation Commission, Oil and Gas
Website
http://www.ogc.gov.bc.ca/default.asp
http://www.eub.gov.ab.ca/BBS/default.htm
http://www.cnopb.nfnet.com/
http://www.cnsopb.ns.ca/index.html
http://www.neb.gc.ca/
http://www.ogb.state.al.us/
http://www.aogcc.alaska.gov/homeogc.htm
http://www.azgs.state.az.us/OGCC.htm
http://www.consrv.ca.gov/dog/index.htm
http://www.co.blm.gov/oilandgas/oilgas.htm
http://www.dep.state.fl.us/geology/
http://dnr.state.il.us/mines/dog/welcome.htm
http://www.state.in.us/dnroil/
http://www.kcc.state.ks.us/conservation/index.htm
http://www.dnr.state.la.us/CONS/conserv.ssi
http://www.michigan.gov/deq/0,1607,7-135-3311_4111_4231-
--,00.html
http://www.ogb.state.ms.us/
http://bogc.dnrc.state.mt.us/
http://minerals.state.nv.us/
http://www.emnrd.state.nm.us/ocd/
http://www.dec.state.ny.us/website/dmn/
http://www.oilgas.nd.gov/
http://www.occ.state.ok.us/Divisions/OG/oginfo.htm
Conservation Division
USA-Ohio Department of Natural Resources, Mineral http://www.dnr.state.oh.us/mineral/oil/index.html
Resources Management
USA-Pennsylvania Department of Environmental Protection
Bureau of Oil and gas Management http://www.dep.state.pa.us/dep/deputate/minres/oilgas/oilgas.h
tm
USA-Railroad Commission of Texas Oil and Gas Division http://www.rrc.state.tx.us/divisions/og/og.html
USA-Gulf of Mexico MMS http://www.gomr.mms.gov/index.html
USA-The Utah Division Of Oil, Gas And Mining http://dogm.nr.state.ut.us/oilgas/
USA-Washington State Department of Natural Resources http://www.dnr.wa.gov/geology/
division of Geology and Earth Resources
USA-West Virginia Department of Environmental http://www.dep.state.wv.us/item.cfm?ssid=23
Protection Office of Oil and Gas
USA-Wyoming Oil and Gas Conservation Commission http://wogcc.state.wy.us/
Europe
Europe-NE Atlantic/North Sea (OSPAR Commission for the http://www.ospar.org/eng/html/welcome.html
Protection of the North-East Atlantic- OSPAR)
Europe-Barcelona Convention (Mediterranean) http://www.greenyearbook.org/agree/mar-env/barcelon.htm
Europe-Baltic Sea (Helsinki Convention- HELCOM) http://www.helcom.fi/helcom/convention.html
Europe-UK (Centre for Environment Fisheries and http://www.cefas.co.uk/ocns/index.htm
Aquaculture Science-CEFAS)
Europe-Norway (The Norwegian Pollution Control http://www.sft.no/english/legislation/
Authority-SFT)
Europe-The Netherlands (State Supervision of Mines- http://www.sodm.nl/index_engfr.htm
SodM)
Table 3 Examples of drilling fluid use and discharge regulations in offshore producing countries. Note: These regulations are
subject to change at short notice and regulators should be consulted for updated information 2

Country Water Based Drilling Fluids and Diesel, Mineral oils, Low Toxicity Synthetic
Cuttings
Angola Discharge allowed
Australia Risk assessments required by regulator, fluid
plans are described, operators make
commitments for additional testing or monitoring
in Environment Plans are binding once submitted
and accepted by government. Discharge allowed
subject to 1% oil limit. 17% limit on KCl
content of fluids for exploratory drilling.
Sampling of fluids required before discharge,
flow rate monitored but not reported or limited.
Some dischargers monitor Hg/Cd
Azerbaijan All discharges subject to meeting negotiated
terms of specific Production Sharing Agreements
Operators in inshore/ environmentally sensitive
areas have more monitoring requirements; and
more stringent standards. Discharge rate is not
subjected to limits, but is reported monthly in the
form of daily logs records Fluids must show low
toxicity, good biodegradability. Toxicity testing
is carried out after periodic sampling. Chloride
content of discharges is limited. Before drilling,
Mineral Oils
1% oil limit on cuttings retention effectively
eliminates discharge
Restriction on fluids with aromatics >1%
No discharge of fluid or cuttings. Permitted.
Injection of cuttings or onshore treatment, such
as fixation and / or landfilling is planned.
Based Drilling Fluid
Cuttings
Cuttings discharge allowed
Discharges assessed on a case-by-case basis
In Western Australia, technical aspects, local
environment, and environmental performance of
fluid evaluated. Retention on cuttings limited to
10%. Paraffin-based fluid cuttings, Esters and IO
cuttings discharged recently. Whole synthetic
fluids cannot be discharged. Monitoring program
details determined on a case-by-case basis.
Synthetic fluid cuttings can be discharged, but
not whole fluids. Further restrictions expected,
primarily for production drilling. Discharge of
cuttings allowed as long as a low toxicity,
acceptable biodegradability fluid is used
Toxicity & biodegradability standards have not
been set. Some operators have imposed a limit
of 10% SBM fluid on cuttings, or even zero
discharge. Discharge of enhanced-mineral-oil-
based fluids is not allowed
Country Water Based Drilling Fluids and Diesel, Mineral oils, Low Toxicity Synthetic
Cuttings
fluid program is assessed for toxicity and
biodegradability. A daily inventory of
discharged fluid additives is maintained.
Canada Cuttings may be discharged if cuttings injection
is not economically or technically feasible. Bulk
disposal of water based drilling fluids is
discouraged, but allowed.
China WBM discharge is allowed. Oil use is
discouraged , with notification required for
WBM containing oils with sample submission.
Discharge of cuttings with oil content in drilling
fluid >10% is not allowed. If oil <10% and
cannot be recovered, agency approval, discharge
is allowed subject to payment of a fee. Residual
oil, waste oil, oil-containing waste discharge is
prohibited and must be shipped to shore.
Dispersant use is not allowed. Operator
responsible for daily measurement of flow rate of
Mineral Oils
Cuttings may be discharged if cuttings injection
is not economically or technically feasible. OBF
bulk discharge not allowed. Specific approval is
required to use OBF. Aromatic content of oil
must be <5% and meet toxicity requirements for
water soluble fraction (WSF). WBF or SBF use
is preferred. Cuttings from diesel or highly
aromatic oils not allowed to be discharged,
otherwise subject to 15% oil of cuttings limit.
Discharge of fluids on cuttings is not allowed at
>10% oil. If cuttings oil content <10% and
further cleanup not possible, discharge allowed
subject to approval and payment of a discharge
fee
Based Drilling Fluid
Cuttings
SBF bulk discharges prohibited. Cuttings may
be discharged if cuttings injection is not
economically or technically feasible, and subject
to a 15% Oil on cuttings limit. Draft guidelines
propose cuttings discharge only if treated with
BAT prior to discharge. SBM definition includes
paraffins. Operators should reduce fluids on
cuttings to as low a level as is reasonably
practicable, with a target of 6.9%.
SBM fluid/cuttings regulations are not known.
Country Water Based Drilling Fluids and Diesel, Mineral oils, Low Toxicity Synthetic Based Drilling Fluid
Cuttings Mineral Oils Cuttings

discharge pipe. Records in the Antipollution

Record Book include drilling fluid, oil content of
cuttings, discharge volumes and times, etc.
Congo Use and discharge allowed Diesel-based drilling fluids and associated No specific requirements
cuttings cannot be discharged. Other OBM can
be discharged on cuttings. Extensive solids
control equipment use is required to reduce
retention on cuttings
European Discharge of fluids and cuttings allowed subject Use nor discharge of diesel based fluids allowed. Use allowed, but discharge limited to <1%, so
Countries- to pre-approval testing via Harmonised Offshore Use of mineral oils and low toxicity mineral oils impossible on a practical basis.
Denmark, Chemical Notification Format (HOCNF) allowed, but discharge limited to <1%, so not
UK, reporting scheme. possible on a practical basis.
Norway,
Germany,
Netherlands
Equatorial Use and discharge allowed Discharge allowed Use and Discharge allowed
Guinea Operators presently discharging enhanced
mineral oil.
Gabon Use and discharge allowed Diesel-based drilling fluids and associated No specific requirements
cuttings cannot be discharged
Other OBM can be discharged on cuttings
Extensive solids control equipment use is
required to reduce retention on cuttings
Country Water Based Drilling Fluids and Diesel, Mineral oils, Low Toxicity Synthetic Based Drilling Fluid
Cuttings Mineral Oils Cuttings
Bahrain, May be discharged but can not “contain Use of Group Diesel and LTMO fluids requires
Iran, persistent systematic toxins” express sanction of the competent State
Kuwait, Authority. No whole Diesel and LTMO fluids
Oman, can be discharged. No diesel and LTMO cuttings
Qatar, should be discharged except in exceptional
UAE,, circumstances. Express sanction is requested for
Saudi discharge of LTMO drill cuttings. Express
Arabia sanction is requested for discharge of LTMO drill
cuttings.
Italy Discharge allowed following suitable regulatory Discharge allowed at less than 10% oil on Not considered under current regulations
authorisation cuttings. Discharge not permitted in Adriatic
Sea.
Kazakstan No discharge allowed per the Petroleum Law; No discharge allowed per the Petroleum Law; No discharge allowed per the Petroleum Law;
Environmental Protection Norms (for offshore, Environmental Protection Norms (for offshore, Environmental Protection Norms (for offshore,
coastal areas & internal water bodies); and coastal areas & internal water bodies); and coastal areas & internal water bodies); and
Special Ecological Requirements (for State Special Ecological Requirements (for State Special Ecological Requirements (for State
Nature Preserve Zone in North Caspian). Nature Preserve Zone in North Caspian). Nature Preserve Zone in North Caspian).
Presently using LTOBM and hauling cuttings
ashore for thermal desorption and fluid recovery
Malaysia Discharge allowed. Flow rate is estimated but Discharge allowed. No oil limit. Operators are using refined paraffins, esters and
not reported. Drilling fluid makeup is monitored low toxicity OBM and discharging cuttings. No
but not reported. regulatory action on SBM currently on horizon.
No oil limit.
Country Water Based Drilling Fluids and Diesel, Mineral oils, Low Toxicity Synthetic
Cuttings
Nigeria To discharge, must submit proof that fluid has
low toxicity to Director of Petroleum Resources
(DPR) with permit application. Discharges will
be treated to DPR’s satisfaction. DPR will
examine WBM to determine how hazardous and
toxic it is. Cuttings contaminated with WBM
may be discharged offshore/deep water without
treatment.
Based Drilling Fluid
Mineral Oils Cuttings
To discharge, must submit proof that OBM has SBM must be recovered, reconditioned, and
low toxicity to regulator with permit application. recycled. SBM cuttings must contain 5% drilling
Discharges must be treated to regulator’s fluid or less for discharge. (10% for esters).
satisfaction. OBM must be recovered, Special provision for higher retention limits have
reconditioned, and recycled. Oil on cuttings, 1% been granted for some deepwater wells.
with 0% goal. On-site disposal if oil content does
not cause sheen on the receiving water. Cuttings
samples shall be analyzed by Operator as
specified by DPR once a day. Point of discharge
as designated on the installation by shunting to
the bottom. DPR to analyze samples at its own
discretion for toxic/hazardous substances.
Operator to carry out first post-drilling seabed
survey 9 months after 5 wells have been drilled.
Subsequent seabed surveys shall then be carried
out after a further 18 months or further 10 wells.
Operator must submit to DPR details of sampling
and analysis records within 2 weeks of
completion of any well. Inspection of operations
shall be allowed at all reasonable times.
Country Water Based Drilling Fluids and Diesel, Mineral oils, Low Toxicity Synthetic Based Drilling Fluid
Cuttings Mineral Oils Cuttings
Russia— Base case is zero discharge with discharges from Regulations do not deal with oil based drilling Unknown
Sakhalin exploratory drilling authorized on a case-by-case fluids. Proposed regulations will not allow
Island basis. In Exclusive Economic Zone (EEZ), discharge of oil based cuttings.
control of all discharges is via "maximum
permissible concentrations”, MPC's or receiving
water criteria. All substances discharged must
have certified MPC's and meet allowable
concentrations 250m from discharge point.
1998 Law on the Territorial Sea introduced
uncertainty regarding legality of ANY discharges
within 12 mile limit. Toxicity testing on fluid
additives, lab formulated fluids carried out.
Sampling frequency not specified—several times
during drilling.Fluid constituents, discharge rates,
and other parameters may be regulated by the
Water-use License process.
Thailand Cuttings cannot be discharged if >10% oil on Not covered under current regulations.
cuttings. Regulators are reviewing existing
practices.
Trinidad Discharge of WBM allowed as long as covered Ministry of Energy (MOE) unlikely to approve Is allowed. New regulations are will probably
in an Environmental Impact Assessment which is during EIA process. No OBM proposals in allow discharge
reviewed by approved by the Ministry of Energy. offshore drilling for several years, so policy has
New regulations are being written which will not been tested. New regulations are being
probably allow discharge. written which will probably allow discharge.
Country Water Based Drilling Fluids and Diesel, Mineral oils, Low Toxicity Synthetic Based Drilling Fluid
Cuttings Mineral Oils Cuttings
United Discharge allowed beyond coastal waters (3 Discharge prohibited. Discharge of enhanced- Not specifically mentioned in current permit.
States— mi).· 50 lb/bbl in EPA generic fluid #1.Flow mineral-oil-based fluid/ cuttings prohibited. Under discussion for regional permit.
California rate is monitored and maximum annual discharge Practice is to inject OBM cuttings.
(EUSA) cannot exceed 215,000 bbl.Hg/Cd < 1/2 ppm.No
free oil/diesel/waste oil as by static sheen test.No
chrome lignosulfonate.96 hr LC50 SPP >3%.
Weekly sampling; at least 1 tox. test of each fluid
system. Fluid sample must be at 80% or greater
of final depth for each fluid systemSpecial
restrictions for environmentally sensitive
areas.Spotting fluids must meet toxicity
requirements.
United Offshore (>3 miles from shore). Discharge not allowed. Western GOM allows discharge of SBM cuttings
States— Flow rate is estimated hourly during discharge OBM cuttings are typically landfilled as non- subject to the same restrictions as water-based
GOM and limited in biologically sensitive areas. Hazardous Oilfield Waste (NOW) or injected to fluid, plus stock limitations on base fluid-
Monthly testing requires 96 hour Mysid Shrimp disposal sites onshore. Sediment toxicity and biodegradation testing
LC50 >30,000 ppm. must demonstrate base fluid to perform as well as
Barite must contain <1 ppm Hg and <3ppm Cd 16/18 Internal Olefin or C8 or C12-14 Ester.
Chemical inventory required Drilling fluid samples taken once per month are
Weekly static sheen test used to check for free oil taken for 4 day sediment toxicity testing to
discharge ensure no more toxic than C16/18 IO.
Additional testing carried out prior to shipping to
and weekly to certify <1% crude contamination.
Eastern GOM does not allow discharge.
Country Water Based Drilling Fluids and Diesel, Mineral oils, Low Toxicity Synthetic Based Drilling Fluid
Cuttings Mineral Oils Cuttings
United Coastal Waters: (e.g. inland canals and enclosed Discharge of cuttings prohibited. Discharge of cuttings prohibited.
States— bays). Discharge prohibited except for Cook
Alaska Inlet, Alaska. Alaskan coastal waters subject to
same regulations as offshore waters.
Vietnam Discharge is allowed. Toxicity requirements not Discharge of cuttings from diesel or mineral oil No stipulations regarding SBM cuttings. May
clearly stipulated. Oil content should be <1%. drilling fluids is totally prohibited. have same restrictions as OBM cuttings.
Drilling fluids, toxic and/or hazardous chemicals
use and discharge subject to pre-approval by
regulatory agency. EIA report includes details of
drilling fluid composition.
REFERENCES

1
Munro, P.D., B Croce, C.F. Moffet, N.A Brown, A.D. McIntosh, S.J.Hird, R.M. Stagg. 1998. Solid-phase test for comparison for
degradation rates of synthetic mud base fluids used in the off shore drilling industry. Environ. Toxicol. Chem. 17:1951-1959.

2
CAPP (2001) Canadian Association of Petroleum Producers Drilling Waste Management Review CAPP Technical Report Publication
#2001-0007 Calgary, Alberta, Canada, February 2001.