When it comes to HSE, the ‘E’ or environment is often set aside and talked about as a separate entity. This separation is most likely due to the different challenges and concerns that come with environmental management.
In any country and in any industry there are many challenges in regulating and managing environmental concerns. In the oil and gas sector a small mistake or lack of regulation could lead to a huge disaster with countless consequences to the environment. The oil and gas sector is a complex industry dealing with dangerous, and often very toxic products. Even in the best situations mistakes happen. This is why it is imperative to not only have safety standards, but to also have contingency plans to take care of and clean up any accident.
The position of Minister of State of Environmental Affairs was created in 1997 and was given the responsibility to define environmental policies, set priorities and implement initiatives for the protection of the environment in Egypt. Within the Ministry is the Egyptian Environmental Affairs Agency (EEAA), which acts as the executive arm of the Ministry. The EEAA has three principal functions, which include: formulation of environmental policies, preparing the necessary plans for environmental protection and environmental development projects, in addition to following up to ensure their implementation. The EEAA is also the national authority in charge of promoting environmental relations between Egypt and other states, as well as regional and international organizations.
In terms of the oil and gas industry the Environmental Impact Assessment (EIA) is one of the strategic ways the Ministry of Environment protects the environment and regulates projects. In accordance with the environmental protection law 4/1994 and the executive regulations 338/1995 all oil and gas projects must be subject to an EIA before they are able to obtain a permit. Law 4/1994 was enacted to address pollution problems with existing projects as well as reducing negative environmental effects of expansions/renovations of existing establishments and for future projects.
The EIA (known in other systems, like the World Bank, as environmental assessment (EA) process) is a process by which the Egyptian government gathers all relevant information regarding the environmental consequences of activities so that they can mitigate environmental issues before a project starts. The EIA first documents the results of a potential project, then it analyzes potential environmental and social impacts the project may have. If needed, the process calls for project alternatives and an environmental management plan (EMP). If the EIA finds considerable environmental concerns the project can be denied. Not to mention the fact that a project started without an EIA will be forced to pay a fine and could be subject to license revocation.
All projects that go through an EIA are sorted into three categories based on size and scope of the project. Category A is for the smallest projects with minimal environmental impacts such as natural gas or petrol stations in environmentally non-sensitive areas (“sensitive” areas are residential areas, protected areas, agricultural areas and other areas specified by the EEAA). Category B has a bigger scope, and includes projects with potentially adverse environmental impacts such as onshore/offshore seismic exploration for oil and gas, onshore/offshore pipeline of length less than 50 km in non-sensitive areas, and fuel (petrol, gas, or diesel) storage tanks which have a combined storage of 15,000 m3 or less. The last category, category C, contains the biggest projects and those that have the potential to cause the largest environmental disasters. These include onshore/offshore exploratory drilling and development for oil and gas, oil and petrochemical refineries, and distribution networks of natural gas for cities.
In addition to the EIA, law 4/1994 also requires that companies keep an Environmental Register. An Environmental Register is a document that records the companies’ impacts on the environment. For example, a company must record the level of harmful emissions that come from their facilities through periodic testing throughout the year. In addition to the final numbers, the register also requires companies to record their sample and analyses rates. Companies such as Petrosafe aid oil and gas companies with their Environmental Register by showing their management how to correctly track the environmental impacts and by providing resources to do so.
While the EIA and the Environmental Register are good ways to mitigate environmental threats, accidents still happen. In case of accidents the Egyptian General Petroleum Company (EGPC) currently runs four spill centers throughout Egypt and has plans for seven more along the Nile and on the Mediterranean. The biggest spill center is in Alexandria with the other four smaller centers located on the Red Sea to take care of tier 1 and 2 spills. Here in Egypt, like elsewhere around the world, tier 1 is the mildest spill with damage in a localized area. Usually, it is the responsibility of the respective company to clean up these spills. Tier 2 spills are a bit larger and usually require the resources of the government for the clean up. Tier 3 spills are the largest and are often considered catastrophic events, such as the BP Horizon accident where the equivalent of 4.9 million barrels of oil spilled into the Gulf of Mexico. Tier 3 spills usually require resources and cooperation from foreign governments as well as the national government.
In addition to governmental spill centers there are also private oil response companies that are specialized to clean up oil and gas accidents. The International Environmental and Marine Services Company (IEMS) is one of these companies here in Egypt. IEMS, the first independent environmental service company in the Middle East, works in conjunction with EGPC and foreign oil companies on oil spill response both onshore and offshore for tier 1 and 2 spills. Foreign oil companies can also contract IEMS for custom contingency packages as well as spill seminars. IEMS is also a member of both the Oil Spill Response Alliance (OSRA) and the Mediterranean Oil Industry Group (MOIG), which help with coordination on oil spill efforts for tier 3 spills. Similar to EGPC, IEMS also runs a private spill center in Abu Quir Military harbor. This center currently has 22 employees working on two shifts throughout the day. Eng. Hamed El Ahmady, the Chairman of IEMS, told Egypt Oil & Gas that as they receive more contracts they hope to add more spill centers throughout Egypt.
In Egypt, one of the biggest challenges in dealing with the environment is the overall lack of environmental awareness, evinced by the huge amounts of pollution on the street, in the Nile and in the air. Many people simply throw trash out their windows without any concern for where it may end up or how bad it can be for the environment. Some may say, fine, polluting is bad, but how does the habit of throwing one’s Chipsy bag out the window affect the oil and gas industry? Surprisingly, the affects are substantial and can be disastrous for the environment.
Wessam Mahmoud, the QHSE Manager for Fugro, commented on this issue, stating, “we don’t have the culture of preserving the environment in Egypt. You can see the gas station attendants changing oil and pouring it out onto the street.” The seemingly insignificant habit of pouring car oil into the streets can result in environmental disasters when these same habits are carried out on a larger scale in the oil and gas industry. For example, if workers see something leaking into the Nile they might be less inclined to report it, or to try and clean it up. When left unchecked a small leak can turn into an immense problem. This broad lack of awareness corresponds to the level of importance the Egyptian government places on taking care of the environment and cleaning up after any accidents. While the government has environmental regulations in place and a few spill centers around the country there is a lack of environmental awareness that plagues the industry. “It’s not just about the government controlling the issues, it’s the culture of preserving the environment that’s not there,” said Mahmoud.
The lack of environmental concern also relates to the serious lack of manpower to deal with a major oil spill and to check environmental regulations. While there is a governmental spill center in Alexandria, and plans for more, it is not nearly enough to cover the entire country. Mohamed Abdullah, Manager of Oil and Gas Projects for the Egyptian Association for Energy and Environment acknowledges that while they have some resources to protect the environment overall there just are not enough. Abdullah also added that even more critical than lack of basic manpower is the lack of specialized environmental experts in the country. When a spill happens you need experts in country to help evaluate the spill and determine the best way to take care of it. Without these experts a small spill can turn into an environmental disaster for years to come if it is not taken care of effectively.
Egypt has a good foundation for environmental regulation, however the lack of environmental awareness by the people is a major roadblock towards cleaning up the environment and limiting accidents in the future. “We have very good and solid environmental law with limits and specializations and everything, but we still don’t have the culture to implement it or the commitment to do it,” explained Mahmoud. Hopefully, as environmental awareness spreads, more environmental accidents can be prevented. While Egypt is headed in the right direction, it still has a long way to travel. It is going to take effort from all parties – the government, the public, and private companies – to clean up their country and protect it for future generations.
By Tatianna Duran