Global installed wind capacity from onshore and offshore sources increased from 7,600 megawatts (MW) at the end of 1997 to more than 282,000 MW at the end of 2012. Of the total, approximately 21 percent (60,007 MW) is installed within the United States (GWEC 2013), all of it onshore—the world’s second-highest wind turbine1 generating capacity (GWEC 2013). Yet the United States has vast untapped wind energy resources: estimates of potential U.S. onshore “installed capacity” exceed 10 million MW.2 In addition, potential offshore wind resources in U.S. coastal and Great Lakes waters are conservatively estimated at more than 2 million MW.3 Offshore wind could help the United States provide energy to coastal cities, where much of the nation’s population and electricity demand lie (NREL 2012).
Nevertheless, no offshore wind turbines have been installed in U.S. waters as of December 2012. Development of offshore wind farms4 is more advanced in Europe. Countries such as Denmark, Germany, Norway, and the United Kingdom already produce electricity offshore, with an installed capacity of more than 4,900 MW (EWEA 2013).5
1 A wind turbine converts the energy of moving air into electricity.
2 http://www.windpoweringamerica.gov/docs/wind_potential_80m_30percent.xls. “Installed capacity” is the potential megawatts of rated gross capacity that could be installed on available windy land areas (after exclusions) in all 50 states.
4 Wind farms consist of one or more independently operating wind turbines that generate power and are connected to an electrical substation that transfers the power to the grid.
5 As of December 31, 2012, global cumulative offshore installed capacity exceeded 5,400 MW (GWEC 2013).
Through the Energy Policy Act of 2005, Congress authorized the Secretary of the U.S. Department of the Interior (DOI) to grant leases for activity that involves the production, transportation, or transmission of energy on the outer continental shelf (OCS) lands from sources other than gas and oil.6 In April 2009, the President and the Secretary of the Interior announced the final regulations for the OCS Renewable Energy Program, which defined the regulatory process and provided a framework for “leases, easements, and rights-of-way” for activities promoting the safe and environmentally responsible production and transmission of energy on the OCS from sources other than oil and natural gas (Federal Register 2009).7 In November 2010, the Secretary of the Interior announced the “Smart from the Start” wind energy initiative for the Atlantic OCS “to facilitate siting, leasing, and construction of new projects, spurring the rapid and responsible development of this abundant renewable resource”8 and to improve coordination with local, state, and federal partners in the wind development process. The initiative encouraged an accelerated process for offshore wind development, with a goal of issuing leases in 2011 and 2012. To support this rapidly evolving process, the federal government needed to provide timely guidance in many areas of offshore wind development, especially in ensuring the health and safety of offshore workers.
Working offshore in a marine environment is challenging and introduces multiple hazards.9 Weather conditions can be harsh and change constantly. European offshore wind operations already face such hazards as transfers to and from turbine platforms from vessels in shifting seas and injuries associated with dropped objects or with crane operations and suspended loads. Assembling sections of a wind turbine offshore can
6 As discussed in Chapter 3, the Secretary of the Interior delegated to the Minerals Management Service (MMS) the new authority that was conferred by the Energy Policy Act of 2005. In June 2010, MMS was renamed the Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE). On October 1, 2011, DOI reorganized BOEMRE and established two new, independent bureaus—the Bureau of Safety and Environmental Enforcement and the Bureau of Ocean Energy Management.
9 A hazard “is any source of potential damage, harm or adverse health effects on something or someone under certain conditions at work”; see http://www.ccohs.ca/oshanswers/hsprograms/hazard_risk.html.
TABLE 1-1 Growth in Rotor Diameter and Capacity of Offshore Wind Turbines, 1997–2020
|Year||Capacity (MW)||Approximate Rotor
present many workplace hazards, which are discussed in Chapter 2. The turbine equipment itself is massive and must be installed with barges equipped with large cranes or with a specialized installation vessel; in just the past 12 years, the capacity (in megawatts) of offshore wind turbines has more than tripled, while the rotor diameter more than doubled (from approximately 75 to 164 meters) (see Table 1-1 and Figure 1-1).
Manufacturers such as Alstom, REpower, and Siemens are testing 6-MW prototype offshore wind turbines; Vestas is ready to test a 7-MW offshore turbine; and reports indicate that GE Energy is developing an offshore turbine with a potential capacity of 15 MW (EWEA 2012).10 To illustrate the size of these wind turbines, the nacelle of the Vestas 7-MW turbine will rise more than 110 meters above sea level, and its three rotor blades, 80 meters each, will have a diameter of more than 164 meters, exceeding the diameter of four Airbus A380 passenger planes placed nose to nose.11 A turbine blade of the Siemens SWT-6.0-154 measures 75 meters, nearly the width of an Airbus A380 (see Figure 1-2).12
FIGURE 1-1 Growth in size and capacity of offshore wind turbines.
(SOURCE: American Wind Energy Association presentation to committee by Michele Mihelic.)
FIGURE 1-2 (a) Diameter of Vestas V164 7-MW turbine blades compared with four Airbus A380s; (b) blade length of Siemens SWT-6.0-154 6-MW turbine compared with Airbus A380.
Given the hazards of working with this massive equipment in a marine environment—in addition to the more typical hazards of working with high-voltage equipment, at heights, and generally in a marine environment—providing guidance that addressed the health and safety of offshore workers became of paramount importance to the responsible agency. In October 2011, DOI issued final regulations under 30 CFR 585, Renewable Energy and Alternate Uses of Existing Facilities on the Outer Continental Shelf, for renewable energy development activities on the OCS, giving the Bureau of Ocean Energy Management (BOEM) authority for the Renewable Energy Program (Federal Register 2011).13
According to the regulations, one of BOEM’s responsibilities is to ensure that “renewable energy activities on the OCS and activities involving … marine-related purposes are conducted in a safe and environmentally sound manner.” A lessee or operator is required to design projects and to “conduct all activities in a manner that ensures safety and will not cause undue harm.” Among key reports operators are required to submit, along with supporting documentation as stipulated in 30 CFR 585, is a description of a safety management system (SMS) (see Box 1-1).
The regulations specify in detail what should be included in most of the reports [e.g., the construction and operations plan (COP) and the fabrication and installation report] and how the reports and documents will be reviewed and approved by BOEM.14 Thus far, however, this is not true for the SMS report.
BOEM reviews the description of the SMS submitted with the COP only for completeness of information.15 In addition, the regulations as written in §585.810 provide limited detail as to what an SMS should include and do not direct operators to specific standards or guidelines.
14 For some reports, an approved third party, a “certified verification agent,” independently assesses and certifies to BOEM that the facility is designed on the basis of sound practices and that components are installed according to acceptable practices.
15 If BOEM judges project activities “complex or significant” for an approved site assessment plan (SAP), COP, and general activities plan (GAP), the lessee must submit a description of the SMS as required by §585.810. BOEM reviews submitted documents for all necessary information by performing what it calls a “completeness review” (see BOEMRE 2011).
30 CFR 585, Subpart H—Environmental and Safety Management, Inspections, and Facility Assessments for Activities Conducted Under SAPs, COPs and GAPs
§585.800 How must I conduct my activities to comply with safety and environmental requirements?
(a) You must conduct all activities on your lease or grant under this part in a manner that conforms with your responsibilities in §585.105(a), and using:
(1) Trained personnel; and
(2) Technologies, precautions, and techniques that will not cause undue harm or damage to natural resources, including their physical, atmospheric, and biological components.
(b) You must certify compliance with those terms and conditions identified in your approved SAP, COP, or GAP, as required under §585.615(c), 585.633(b), or 585.653(c).
§585.810 What must I include in my Safety Management System?
You must submit a description of the Safety Management System you will use with your COP (provided under §585.627(d)) and, when required by this part, your SAP (as provided in §585.614(b)) or GAP (as provided in §585.651).
You must describe:
(a) How you will ensure the safety of personnel or anyone on or near your facilities;
(b) Remote monitoring, control, and shut down capabilities;
(c) Emergency response procedures;
(d) Fire suppression equipment, if needed;
(e) How and when you will test your Safety Management System; and
(f) How you will ensure personnel who operate your facilities are properly trained.
§585.811 When must I follow my Safety Management System?
Your Safety Management System must be fully functional when you begin activities described in your approved COP, SAP, or GAP. You must conduct all activities described in your approved COP, SAP, or GAP in accordance with the Safety Management System you described, as required by §585.810.
The U.S. federal government has regulated the offshore oil and gas industry for decades but has no experience with offshore wind facilities. Europe has less than a 20-year history of regulating offshore wind, and U.S. regulations for offshore wind, including those for worker health and safety, are just now emerging (Musial and Ram 2010). As discussed in Chapter 3, the coverage of existing U.S. health and safety regulations and issues of jurisdictional boundaries within the United States are complex. The Occupational Safety and Health Administration (OSHA) normally has jurisdiction for all for worker health and safety regulations in the United States, including the OCS, unless another federal agency preempts OSHA by enforcing different regulations. BOEM’s intention to enforce health and safety regulations for wind energy through its SMS requirement has preempted OSHA, but only for activities on the OCS, generally beyond 3 nautical miles (see Figure 1-3). However, OSHA and approved state regulations will oversee activities in state waters within 3 nautical miles and on the Great Lakes.
BOEM officials believe that current regulations for the health and safety of offshore wind workers are “vague” but state that BOEM intends to “enhance them” on the basis of “best practices” from other
FIGURE 1-3 Jurisdictional boundaries in offshore waters. Illustration not to scale. (SOURCE: Primer on Ocean Jurisdictions: Drawing Lines in the Water, http://www.oceancommission.gov/documents/full_color_rpt/03a_primer.pdf.)
sources.16 Indeed, in many instances, other industries have rules, standards, and guidelines covering worker health and safety that are likely relevant to regulating offshore wind operations on the U.S. OCS. These regulations and standards are discussed further in Chapters 3, 4, and 5 but include some of the following:
• The Bureau of Safety and Environmental Enforcement (BSEE) conducts safety inspections of offshore oil and gas platforms for the U.S. Coast Guard (USCG) and has recently implemented safety and environmental management system (SEMS) requirements for the oil and gas industry.
16 “Regulating Worker Safety in Renewable Energy Operations on the OCS,” presentation to the committee by Robert LaBelle, BOEM, November 30, 2011.
• USCG oversees and regulates all inspected vessels and worker health and safety on oil and gas platforms, but the regulations that are promulgated for this setting may be unique to oil and gas operations.
• As mentioned earlier, OSHA or approved state regulations cover all workplace health and safety activities unless preempted by another federal agency. OSHA regulations are enforced for land-based wind farm operations and would be applied to wind farms in state waters. BOEM could adapt or adopt these regulations for offshore wind farms on the OCS, but they may be inadequate for BOEM’s needs or for the unique marine environment.
• Organizations and associations, both domestic and international, have developed standards and guidelines for worker health and safety on offshore wind farms. They are in use by other countries and companies, but BOEM would need to adapt them to serve as regulations in the United States.
In an effort to meet its mandate for enhancing safety regulations, the former Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE) received the results of a study from the Marine Board of the National Research Council in April 2011 that focused on the structural safety of offshore wind turbines (TRB 2011). In August 2011, BOEMRE approached the Marine Board again to request an assessment of BOEMRE’s approach for regulating the health and safety of wind farm workers on the OCS. The charge of the committee is shown in Box 1-2.
As discussed with the sponsor at the first meeting, the study’s objective includes the examination of rules for worker health and safety on the OCS during each phase of wind farm development, from construction to decommissioning. In addition, the committee believed that it should consider the role of design and human factors engineering (HFE) in mitigating hazards, and this matter was accepted as part of the committee’s charge after its first meeting. The committee recognizes that aspects of offshore wind farm operations occurring in state waters and the Great Lakes, although relevant to those on the OCS, are outside the scope of its charge and not within the enforcement jurisdiction of DOI. However,
Statement of Task: Committee on Worker Safety on Offshore Wind Farms
This study will assess the role of, and appropriate responsibilities for, regulating worker health and safety for wind farms on the Outer Continental Shelf (OCS). The study will examine the construction, operations and maintenance, and decommission of wind farms, and will consider the role of wind turbine design in mitigating workplace hazards. Starting with how oil and gas worker health and safety is regulated by the Bureau of Safety and Environmental Enforcement (BSEE) and the Bureau of Ocean Energy Management (BOEM),1 as well as by other authorities having jurisdiction, the study will focus on the gaps or overlapping areas in the current regulations for worker health and safety for wind farms on the OCS. It will examine the impact on BOEM and BSEE’s worker health and safety program in the absence of U.S. Coast Guard involvement and any potential implications of working with the Federal Energy Regulatory Commission and various electrical grid operators. The study will also examine the potential role of the Occupational Safety and Health Administration in regulating worker health and safety for wind farms on the OCS.
The study will identify workplace risks involved with wind farms, such as working in proximity to high-power electrical devices on offshore substations, extensive use of elevators for wind turbines in a highly corrosive environment, accessing turbine blades for repair via helicopter, crane operations during construction, and use of CO2 fire suppression systems in potentially manned areas. The study will identify gaps in current regulations and recommend additional areas of workplace health and safety regulation deemed necessary.
Specific tasks for the study include:
1. Identification of unique risks to the health and safety of workers on wind farms, as compared to oil and gas operations on the OCS.
2. Identification of any gaps or overlaps in jurisdictional authority.
3. Evaluation of the adequacy of existing BOEM and BSEE worker health and safety regulations and recommendations on how to enhance regulations for worker health and safety on wind farms on the OCS.
1 On October 1, 2011, the Department of the Interior reorganized the Bureau of Ocean Energy Management, Regulation, and Enforcement and established two new, independent bureaus—BSEE and BOEM. http://www.doi.gov/news/pressreleases/Interior-Department-Completes-Reorganization-ofthe-Former-MMS.cfm.
the committee believes that stakeholders on both sides of jurisdictional lines can benefit from developing a more consistent policy and coordinating efforts toward that goal.
The committee’s charge is concerned with issues of occupational health and safety during the development of wind farms but does not include issues pertaining to the siting, leasing, or permitting process. The study does not examine environmental hazards such as effects on wildlife and the seabed, since they fall under the National Environmental Policy Act. Furthermore, the study does not discuss the economics of wind farms, including such topics as financing and overall costs of commissioning and operating, nor does it discuss any particular tax incentives.
The committee considers the role of design and HFE in protecting worker health and safety, but hazards resulting from structural failure are not part of its charge. They were addressed in a previous study (see TRB 2011).
Although construction on proposed offshore wind projects has not started, the committee recognizes DOI’s urgent need to develop more explicit rules governing worker health and safety. In approaching its task, the committee recognizes BSEE’s SEMS (goal-based) approach to safety, which is implicit in its requirement for SMSs, and the value of aligning its regulatory oversight of worker health and safety within this framework. In Chapter 5, the committee evaluates the SMS framework required by 30 CFR 585.810 and reviews the relevant elements of other SMSs (for example, see API 2004, ANSI and AIHA 2012, and BSI 2007).
To meet DOI’s objective of developing renewable energy on the OCS in a “safe and environmentally sound manner,” the committee believes that any enhanced framework requires a careful balance: it needs enough detail to ensure consistency and equity but also enough flexibility to avoid an overly prescriptive “one-size-fits-all” approach. This balance is most likely to be achieved through a process that brings many stakeholders to the table for thorough discussion and negotiation.
To fulfill its charge, the committee met five times over a 1-year period and was briefed by stakeholders. To address its first task, the committee reviewed the offshore wind farm environment and identified hazards unique to offshore wind farms. Next, the committee compared hazards of offshore wind farms with those of the offshore oil and gas industry. For its second task, the committee examined the jurisdictional authority of relevant federal agencies and the regulatory approaches offered by each and determined whether gaps or overlaps of jurisdiction exist. For its third task, the committee evaluated the current regulatory framework and provided options for enhancing regulations for worker health and safety on wind farms on the OCS.
Over its first four meetings, the committee received briefings from representatives of federal agencies about jurisdictional responsibility and existing regulations for worker safety on the OCS. The committee also heard what other stakeholders, including industry associations, wind turbine manufacturers, marine construction companies, and classification societies, are doing to promote offshore worker health and safety and how HFE is used in the design and operation of oil and gas facilities in the Gulf of Mexico.
Chapter 2 briefly discusses wind turbines and wind farm development (both onshore and offshore). Hazards involved with each phase of the process are introduced, and hazards that are unique to offshore operations are identified. Hazards and risks associated with offshore oil and gas operations and relevant to offshore wind development are also discussed. Chapter 3 reviews regulations for worker health and safety and federal jurisdiction on the OCS and then discusses how the relevant agencies interact. That chapter also examines standards and guidance from relevant domestic and international sources. Chapter 4 further describes the hazards of offshore wind farms introduced in Chapter 2 and maps them to relevant regulations, standards, and best practices. Chapter 5 evaluates the regulatory framework and discusses options for addressing potential gaps. Chapter 6 states the committee’s conclusions, key findings, and recommendations for enhancing regulations for worker health and safety on wind farms located on the OCS.
|AIHA||American Industrial Hygiene Association|
|ANSI||American National Standards Institute|
|API||American Petroleum Institute|
|BOEMRE||Bureau of Ocean Energy Management, Regulation, and Enforcement|
|BSI||British Standards Institute|
|EWEA||European Wind Energy Association|
|GWEC||Global Wind Energy Council|
|NREL||National Renewable Energy Laboratory|
|TRB||Transportation Research Board|
ANSI and AIHA. 2012. Occupational Health and Safety Management Systems. ANSI/ AIHA/ASSE Z10-2012. Falls Church, Va.
API. 2004. Recommended Practice for Development of a Safety and Environment Management Program for Offshore Operations and Facilities, 3rd ed. API RP 75. Washington, D.C.
BOEMRE. 2011. Process Guide: Offshore Renewable Energy Installations, and Annexes 1–4, Version 1.0. July 27.
BSI. 2007. Occupational Health and Safety Management. BS OHSAS 18001. London.
EWEA. 2012. The European Offshore Wind Industry Key 2011 Trends and Statistics. Jan. 2012. http://www.ewea.org/fileadmin/files/library/publications/statistics/EWEA_stats_offshore_2011_02.pdf. Accessed Feb. 7, 2013.
EWEA. 2013. The European Offshore Wind Industry: Key Trends and Statistics 2012. Jan. 2013. http://www.ewea.org/fileadmin/files/library/publications/statistics/European_offshore_statistics_2012. Accessed Feb. 7, 2013.
Federal Register. 2009. Renewable Energy and Alternate Uses of Existing Facilities on the Outer Continental Shelf; Final Rule. Vol. 74, No. 81, April 29, pp. 19638–19871.
Federal Register. 2011. Reorganization of Title 30: Bureaus of Safety and Environmental Enforcement and Ocean Energy Management. Vol. 76, No. 201, Oct. 18, pp. 64432–64780.
GWEC. 2013. Global Wind Statistics 2012. Feb. 11. http://www.gwec.net/wp-content/uploads/2013/02/GWEC-PRstats-2012_english.pdf. Accessed Feb. 11, 2013.
Musial, W., and B. Ram. 2010. Large-Scale Offshore Wind Power in the United States: Assessment of Opportunities and Barriers. Report TP-500-40745. National Renewable Energy Laboratory, Golden, Colo.
NREL. 2012. Strengthening America’s Energy Security with Offshore Wind. April. http://www.nrel.gov/docs/fy12osti/49222.pdf. Accessed March 1, 2013.
TRB. 2011. Special Report 305: Structural Integrity of Offshore Wind Turbines: Oversight of Design, Fabrication, and Installation. Transportation Research Board of the National Academies, Washington, D.C. http://www.trb.org/Publications/Blurbs/165263.aspx.