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H. Safe Drilling Margin

MMS regulations required that “[w]hile drilling, you must maintain the
safe drilling margin identified in the approved APD [Application for Permit to
Drill]. When you cannot maintain this safe margin, you must suspend drilling
operations and remedy the situation.” 410 The safe drilling margin referenced in
the regulation is the difference between the fracture gradient and the mud
weight. The regulation did not define “safe drilling margin,” but typically, the
industry‐accepted safe drilling margin was 0.5 ppg. This drilling margin was
considered sufficient to allow the rig crew to circulate out a kick during the
drilling process.

I. Well Control

30 CFR § 250.401 requires an operator to take necessary precautions to
keep the well under control at all times. This provision identified five specific
well control requirements:

 Use the best available and safest drilling technology to monitor and
evaluate well conditions and to minimize the potential for the well to flow
or kick;
 Have a person onsite during drilling operations who represents the
lessee’s interest and can fulfill the lessee’s responsibilities;
 Ensure that the toolpusher, operator’s representative, or a member of the
drilling crew maintains continuous surveillance on the rig floor from the
beginning of drilling operations until the well is completed or abandoned,
unless the operator has secured the well with BOPs, bridge plugs, cement
plugs, or packers;
 Use personnel trained according to the provisions of Subpart O of 30 CFR
Part 250; and
 Use and maintain equipment and materials necessary to ensure the safety
and protection of personnel, equipment, natural resources, and the
environment.
411

30 CFR Part 250 Subpart O regulations governing well control and
production safety training require operators to establish and implement training
programs that train employees to competently perform their assigned well

410 30 CFR § 250.427(b).
411 30 CFR § 250.401.

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