Comment from Calderon, Ricardo; Gulf Environmental Company

U.S. regulatory agencies have a long standing practice of incorporating by reference many national and international standards. Have the agencies involved in regulating the U.S. Oil & Gas Industry, Offshore & Onshore, considered incorporating by reference existing national and international standards (i.e. ISO-14001-Environmental Management Systems, OSHAS 18001-Occupational Health & Safety Management Systems, & ANSI Z-10 Occupational Health and Safety Management Systems) into the regulations? These national & international Environmental, Health and Safety (EHS) standards can assist companies with compliance by providing a template to effectively and efficiently comply with EHS regulations. Implementing programs based on these standards provide a tried and true method to reduce the frequency and severity of EHS incidents. These EHS systems all incorporate requirements for internal and external checks and balances; they require management commitment to provide leadership and resources for EHS programs; these EHS systems also provide a mechanism for stakeholder involvement; a closed loop system for corrective & preventative actions; a method for continuous improvement of the EHS systems, & documentation & recordkeeping requirements that provides a system to verify compliance with regulations. These EHS systems are the most efficient way for organizations to understand the regulations & to systematically address EHS risks. A properly functioning EHS system based on these standards can help save lives and the environment. As a corollary benefit these organizations can achieve an improved public image, reduce operating costs through better management of their EHS system. Smaller companies can also benefit from these system because they require less man power to manage EHS issues because the system is organized and the risks are better understood. Incorporating pollution prevention and reduction and recycling programs can also improve the organizations bottom line.