REACH and the HSE Case for Formate Brines

Abstract

This article, written by Assistant Technology Editor Karen Bybee, contains highlights of paper IPTC 11222, "REACH and the HSE case for Formate Brines," by Ylva Gilbert, SPE, Gaia Consulting; Adrian Nordone, Cabot Corporation; John Downs, Cabot Speciality Fluids; and Anu Vaahtera, Piia Pessala, and Tuomas Raivio, Gaia Consulting, originally prepared for the 2007 International Petroleum Technology Conference, Dubai, UAE, 4-6 December. The paper has not been peer reviewed. Europe's largest single piece of legislation, Registration, Evaluation, and Authorization of Chemicals (REACH), went into effect on 1 June 2007. REACH requires manufacturers, importers, and users of chemicals to demonstrate that their products are safe to use for humans and the environment. There will be increasing pressure to substitute less-hazardous materials for chemicals perceived as potentially harmful. The legislation is expected to have a significant effect on the management and application of chemicals used by the oil industry in Europe. Introduction The new European chemical legislation, REACH, represents a major revision of European chemicals management, replacing some 40 existing European Union (EU) Directives and Regulations. An objective of REACH is to place the responsibility of demonstrating the safety of chemicals on the manufacturers, importers, and users of the chemical. At the same time, the aim is to minimize the use of animal testing and encourage the substitution principle. The legislation encompasses all chemicals or chemical substances, including oilfield chemicals such as drilling and completion fluids. The full-length paper details the effect that REACH will have on management decisions and compliance procedures related to ensuring safe use of chemicals. Methodology The work presented in the full-length paper is based on a review of the literature and legislation as it applies to oilfield well-construction operations using formate brines as example chemicals throughout the discussion. Where comparisons with traditional brines are made, the data mainly have been sourced from open literature, and there are many gaps. For the formates, the authors also have had access to previously unpublished test results from the manufacturers. The findings from the literature have been complemented with information on the practical challenges of meeting REACH requirements, gleaned from discussions with four major operators. To set the scene, the following section introduces the case-study chemicals. This is followed by a brief overview of two means of ranking chemicals on the basis of regulatory data. REACH and its processes as well as the time frame of implementation are then presented, followed by an overview of data requirements to support REACH. The findings then are discussed from a management point of view, as illustrated with formate brines.