Environmental Engineering Reference
In-Depth Information
Authorized CVA List
When the CVA process was introduced to the offshore oil and gas indus-
try, the authorized list approach was used. Preapproved CVA organiza-
tions were identified, and an operator could select one from the list
without further approvals or reviews. This had the advantage of clarity and
timeliness for the operators and freed regulators from reviewing qualifica-
tions for each project that required a CVA.
However, the authorized list must be kept current, since personnel
available at the time of approval may not be available when the projects get
under way. Periodic auditing of the list is required to ensure that it repre-
sents qualified organizations. Furthermore, the list creates a barrier to par-
ticipation for individuals and organizations that are not on the list,
although they may be qualified.
To implement an authorized list effectively there should be
•
A regular review of the authorized organizations,
•
A process for removal from the list,
•
A regular opportunity to add new organizations to the list, and
•
An auditing process to ensure that personnel performing CVA duties
are those whose qualifications were cited to get on the list.
An authorized list can be advantageous, although it may be just as bur-
densome for the regulator, given the work required to maintain the list and
ensure that it is used properly.
The committee heard from a former director of the MMS Office of
Structural and Technical Support, who described how the oil and gas CVA
process was implemented. He expressed the opinion that the maintenance
of an approved list was impractical given how personnel moved from com-
pany to company and the inability of MMS to monitor effectively the
expertise of the companies on the list. This led to the abandonment of the
list and the move to project-specific approvals of CVAs.
1
The difficulty in
maintaining an approved list would be similar for the offshore wind indus-
try. This difficulty, coupled with the successful use of project-specific
approvals for the oil and gas CVA process, makes project-specific lists the
preferred approach for CVA approval.
1
Presentation by Thomas Laurendine to the committee, August 10, 2010.
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