250.619(e)(1) and 250.518(e)(1) – existing inventory

Question: This question relates to existing operator and manufacturer inventory of packers and bridge plugs that do not have documentation of conformance with API spec. 11D1.  Is there a standard way that BSEE would respond and allow product with a manufacturing date prior to the effective date of the rule?

Response: All packers or bridge plugs designated as qualified mechanical barriers are required to be in conformance with API spec. 11D1 and there is no “grandfathering” of equipment that is currently in inventory.