Taking SEMS to the Next Level
By: Stan Kaczmarek, Chief of SEMS Section, Office of Offshore Regulatory Programs
August 10, 2015 - On July 29, I spoke on behalf of BSEE at the Ocean Energy Safety Institute-sponsored forum “Taking SEMS to the Next Level” in Houston, Texas. The forum provided a valuable opportunity for discussion between the industry, regulators, and academia of major issues related to SEMS implementation, adoption, and future prospects.
SEMS, an acronym for the Safety and Environmental Management System, is a performance-focused tool for integrating and managing various aspects of offshore operations including human behavior, organizational structure, leadership, and processes and procedures. The SEMS program, which originated in 2010, grew out of BSEE regulations aimed at improving operators’ awareness of hazards in the offshore environment and creating operating systems to mitigate those hazards by managing risk. SEMS helps both BSEE and the offshore energy industry to continuously improve safety and environmental performance by allowing assessment of these
systems to see what is working and what is not.
SEMS had been structured such that its various requirements were phased in over time, and we have only recently reached a point where all operators are expected to have developed and implemented a management system that addresses all aspects of the SEMS regulations. BSEE has encouraged companies to design and deploy management systems that both satisfy the legal requirements of SEMS and are a good fit for their own corporate culture and operating environment. Now that the regulated community has had time to define these management systems and acquire experience operating within their confines, BSEE looks forward to shifting its focus from program confirmation to program evaluation.
July’s SEMS forum brought together several offshore energy stakeholder groups to consider ways to increase the program’s effectiveness. In order to capture recommendations from these stakeholders, OESI is developing a questionnaire where interested parties can comment on such issues as standards, risk, equipment, and rule application. Once the survey closes is completed and circulated, they will review, summarize, and report on the results in hopes of identifying ways to “take SEMS to the next level.” Both the OESI and BSEE look forward to reviewing your comments.
By: Rachael Lipinski, Office of Offshore Regulatory Programs
August 4, 2015 - How are offshore operations vulnerable to cyber attacks? That’s what BSEE’s Office of Offshore Regulatory Programs (OORP) is exploring to better understand and develop cyber risk management practices offshore. Where possible, BSEE is working with partners, including the U.S. Coast Guard, to address this quickly emerging offshore risk.
At the Offshore Technology Conference in May 2015, BSEE Director Salerno joined forces with Coast Guard Rear Admiral Thomas to address joint issues of safety offshore, including maritime cyber security. The transcript of their remarks can be found here. After this meeting, BSEE and Coast Guard representatives attended a Maritime Cyber Summit to collaborate further on how to identify offshore cyber risks and risk management strategies. BSEE and Coast Guard have continued the dialogue in cyber risks and risk management strategies and you can find more information on this coordination here and here.
Additionally, BSEE is working to identify offshore cyber incidents that have occurred as well as exercises involving cyber issues that have taken place. In one instance, a drilling rig was overwhelmed by malicious computer software. The malware spread throughout the rig’s computers controlling its safety equipment and the rig was shut down for almost three weeks while technicians worked to clear the malware.
In identifying these prior incidents and exercises, BSEE is using the Coast Guard Cyber Strategy terminology, interpreting cyber to include not only intentional hacking incidents, but also software compatibility, general malware, and manual backup systems for cyber equipment failures. Identifying prior incidents poses a number of challenges—BSEE does not currently have a secure reporting method for cyber incidents, and companies are hesitant to provide non-required information to regulators. Reporting through a non-secure reporting system can inadvertently publicize weaknesses that might invite cyberattacks. Further, BSEE is coordinating with third-party verification companies to learn more about what they audit when a company opts for additional verification on cyber security systems, including software quality and compatibility.
Offshore cyber risks develop quickly and are constantly changing—BSEE is researching the subject in order to inform future decision making on cyber risk management. Cyber is a topic for the continuing OESI survey—which can be found here. The survey is currently open and will remain open until August 15. Question 7 covers cyber offshore.
By: Allyson Anderson, Associate Director of Strategic Engagement
July 27, 2015 - In mid-July Director Salerno and BSEE’s Chief of Offshore Regulatory Programs Doug Morris spoke at a conference on lifting safety to reiterate the importance of decreasing incident rates and preventing worker injuries. You can find the full text of Director Salerno’s speech, which includes the sobering story found below, here.
In April of 2011 at approximately 3:30 a.m., on a platform located in the West Cameron oil and gas field off the coast of Louisiana, plugging and abandonment operations were taking place as part of decommissioning an oil rig
Workers were using large equipment including a power swivel skid, casing jack, and crane on the rig’s main deck. As the crane moved the power swivel skid from atop the well a roustabout acting as a rigger, who was helping to control the heavy load, lost his footing and either stepped or was dragged by the moving load into an opening on the deck. He fell through the opening and landed approximately 30 feet below on the production deck. Tragically, he did not survive the fall. Confusion over the emergency plan also delayed calls for medevac assistance for the fallen worker.
This sad story stands as a stark example of the need for improved safety in the use of cranes on offshore oil rigs, and unfortunately it is not unique. As we noted in our inaugural BSEE Annual Report, between 2007 and 2014 lifting incidents were the second most prevalent cause of operations-related fatalities on the outer continental shelf (OCS), accounting for 16 percent of the total during that time. There were also many non-fatal lifting incidents reported – an average of 167 per year, and that number has been steadily rising since 2010. BSEE stands firmly committed to making necessary safety improvements and reducing risk offshore.
To that end, we recently announced a proposed rule to implement accepted industry best practices and update our regulations regarding the safety of cranes mounted on fixed platforms on the OCS. The proposed rule addresses issues including the loading of cranes, their service life, braking systems, and personnel safety. It is available in its entirety here.
I believe that if we work together, we as regulators, industry operators, equipment manufacturers, and members of academia can continue to improve safety on the OCS.
By: Doug Morris, Chief, Office of Offshore Regulatory Programs
April 7, 2015 - The BSEE will be publishing a proposed
rule for comment this month that is designed to significantly reduce the
likelihood of a catastrophic well control event during drilling-related
operations. This rule will address many of the recommendations that
were made in numerous Deepwater Horizon investigations
related to blowout preventers and also to adopt a variety of new
industry best practices related to maintaining control of a well that
were developed after the 2010 tragedy. These requirements will increase
the performance and reliability of barrier systems that prevent the
release of hydrocarbons. This rule will also propose requirements that
incorporate BSEE’s long-term regulatory risk mitigation initiatives
involving the improved maintenance and repair of critical safety
equipment, increased data collection on the reliability of safety
equipment, third party verification of equipment performance, and
establishing remote monitoring capabilities offshore.
Many of these risk mitigation principles
were also included in the recent proposed rule on production safety
systems. This rulemaking significantly upgrades the safety requirements
for the 2400 facilities that are used to collect, treat, and transmit
oil and gas this is produced on the Outer Continental Shelf. The agency
believes that this rulemaking, when final, will result in improved
safety for the thousands of workers that operate these facilities on a
daily basis and improved environmental protection.
At BSEE we have been focusing on a holistic approach to risk identification and reduction through the policies and rules that we have proposed and will propose in the near future. We have identified other higher risk activities that are not directly related to drilling or production, which include aviation safety and lifting/crane safety. Last year, we issued an advanced notice of proposed rulemaking on aviation safety. Later this year we will be publishing a proposed rule rulemaking on crane safety. We will also seek your input and guidance on any potential improvement to the current requirements on safety management systems. These rules along with new initiatives, such as the near-miss reporting program, represent a proactive approach by the bureau aimed at increasing safety across all operations on the Outer Continental Shelf. We hope that you will join us in our quest to reduce risk offshore – and I invite you to comment on the proposed rules when they are published.
Kevin Karl, Senior Advisor to the Region Director, Gulf of Mexico
March 23, 2015 - Earlier this month I traveled to Mexico City to give a presentation at the Mexico Oil & Gas Summit on what has become known as the Transboundary Agreement, or as it is more formally titled, “Agreement between the United States of America and the United Mexican States Concerning Transboundary Hydrocarbon Reservoirs in the Gulf of Mexico.” The Agreement is designed to enhance North American energy security and support the U.S. and Mexico’s shared duty to exercise responsible stewardship of the Gulf of Mexico. It came about as the result of a meeting between U.S. President Obama and Mexican President Calderon in June 2010, followed by lengthy negotiations between the United States and Mexican governments.
The outcome of the negotiations was an agreement that established a legal framework for the exploration and exploitation of transboundary hydrocarbon reservoirs that may exist along the maritime boundary between the United States and Mexico in the Gulf of Mexico. The Agreement, which became effective in July 2014, pertains to only the Gulf of Mexico and any such reservoir must be beyond nine nautical miles from the U.S coastline as Texas State jurisdiction is not included as part of this Agreement.
The framework developed will be used to achieve safe, efficient, equitable and environmentally responsible exploitation of transboundary hydrocarbon reservoirs. This is done primarily by promoting the “unitization” process between U.S. lessees and the Mexican national oil company, Petróleos Mexicanos (Pemex), and/or private companies. The Agreement was modeled after the BSEE voluntary unitization “domestic” program and is the primary driver of the Agreement. In addition to the approval of unitization, BSEE is also responsible for many other aspects of the Agreement including data exchange, approval of permits, safety and environmental enforcement, offshore inspections, allocation of production, metering of production, and transboundary reservoir determinations. This Agreement does not impact laws and regulations governing operations, that is, operations on the U.S. side must comply with U.S. laws and regulations and operations on the Mexican side must comply with Mexican law. The Agreement does allow for joint inspections of operations within a BSEE/Mexico approved unit.
Any drilling in Mexican jurisdiction near the U.S./Mexico boundary could have a direct impact to BSEE. The Agreement creates a new level of certainty for U.S. and Mexican firms operating in the Gulf border regions and makes additional areas accessible for exploration and production activities, resulting in additional revenue flow to the Federal government. In addition, the moratorium located within the Western Gap (1.4 mile buffer on each side of the delimitation line) was terminated when this Agreement became effective.
Lastly, by Secretarial Order No. 3333, the Secretary designated the Department of the Interior as the “Executive Agency” and assigned the responsibility to BSEE and BOEM, by function, to carry out the Executive Agency’s duties under the Agreement. At the same time, Mexico underwent extensive energy reform that resulted in the creation of Mexico’s new National Safety, Energy and Environmental Agency We will continue to work with this new agency to facilitate the safe and efficient exploration and exploitation of hydrocarbon resources along the maritime boundary.
|Takeelia Scott Gaillard
BSEE Budget Office
Takeelia Scott Gaillard, BSEE Budget Office
February 13, 2015 - The Bureau of Safety and Environmental Enforcement (BSEE) develops a budget each February for the next fiscal year, which starts October 1. Our budget - published in what we call the Greenbook - defines our goals and objectives and the funding necessary to accomplish them. The BSEE budget is rolled up into the budget for the Department of the Interior and then with the rest of the Executive Branch and submitted to Congress for its review and approval.
What is surprising to most people that don’t work in the budget world is how long it takes to formulate a budget request. For our 2016 request, we started the process in April 2014 when we began reaching out to programs for their budget needs. What followed, was ten months of discussions with BSEE programs, the Department of Interior, and the Office of Management and Budget. Once final decisions were made, we then had to develop our Congressional Justification, also known as our Greenbook. Most years, including this year, the bulk of work on the Greenbook is completed in January. This time of year is commonly referred to as “budget season”, and is always the busiest time of year. Though most of the focus on budget submissions is on increase or decrease proposals, the Greenbook includes funding, staffing, and performance information for every BSEE program.
Though there is a great deal of time and effort that goes into the publication of the Greenbook, the budget formulation process is actually just getting started. The next step is discussing the budget request with members of Congress though hearings with the appropriations committees and briefings with Congressional staffers. This process will continue for another nine months, into the fall of 2015, at which time Congress will act on the 2016 request. By that time, we will be busy working on the 2017 budget!
More information on our 2016 budget request can be found here.
BSEE, Coast Guard Sign Memorandum, Discuss 2015 Strategic Objectives
September 26, 2014 - Today's posting is courtesy of the U.S. Coast Guard's Maritime Commons Blog.
On Sept. 19, the Bureau of Safety and Environmental Enforcement (BSEE) and U.S. Coast Guard gathered top agency officials to outline joint goals in regulating offshore activities and signed a joint memorandum of agreement outlining their respective roles in regulating of fixed facilities on the Outer Continental Shelf. BSEE Director Brian Salerno and Rear Adm. Paul Thomas, assistant commandant for prevention policy, signed the agreement.
"The offshore oil and gas industry continues to redefine what is possible. With that progress there is risk. BSEE is partnering with the Coast Guard to reduce that risk and foster a culture of safety among all involved in offshore operations so that it becomes part of the way business is conducted,” said Salerno.
“We are sitting on the edge of an enormous opportunity for the U.S. with domestic energy production, but with that opportunity is risk. I see the Outer Continental Shelf as a high-risk area with cutting-edge operations. Our partnership on this is a priority,” said Thomas.
The intent of the meeting was to develop joint strategic efforts for BSEE and the Coast Guard along with specific goals for the year ahead to harmonize the efforts of the two principle agencies responsible for offshore drilling operations.
During the meeting, Salerno and Thomas signed joint memorandum of agreement OCS-09 Fixed Outer Continental Shelf Facilities. The memorandum identifies responsibilities of BSEE and the Coast Guard for inspection and oversight of specified systems and sub-systems on fixed OCS facilities.
Both BSEE and the Coast Guard have dedicated representatives on two workgroups to develop and present new concepts, ideas and initiatives to leadership to address prevention and response aspects of offshore drilling.
Another key participant in the meeting, Mary Landry, director of incident management and preparedness policy for the Coast Guard, discussed the need to plan for worst case scenarios and to focus on the collaborative work already being shared between the two regulatory agencies. These efforts include:
- Joint review of response plans.
- Joint work on addressing worst case discharge scenarios
- Developing digital systems for sharing of information and oil spill response plans
“We need to anticipate risk rather than to address failure,” said Landry.
Four additional initiatives for 2015 were also discussed:
- Coordinate regulatory development efforts and preparedness planning standards to better serve the Outer Continental Shelf industry
- Clarify inspection responsibilities to eliminate redundancies for floating Outer Continental Shelf facilities.
- Coordinate public engagement to maximize appropriate representation at industry and agency events.
- Develop systematic information sharing protocols regarding casualty analysis, inspection results and worst-case spill response preparedness.
Read more about the agreement HERE.
By: Allyson Anderson, Associate Director of Strategic Engagement
September 9, 2014 - Today, the offshore oil and gas industry is expanding into frontier areas that seemed unimaginable just a few years ago. Areas such as deepwater, high pressure and high temperature reservoirs, and the Arctic carry great potential for providing energy to the Nation, but also carry unique risks as these new environments require new technologies and processes. To safely develop and produce from the reservoirs in those areas, BSEE is leveraging the resources of our interagency partners and working with others to conduct important research related to new and emerging technologies as well as operations in those frontier areas to further our efforts to reduce risks across all offshore operations.
This year we are funding $23 million in research projects on emerging technologies, and that funding is being leveraged through collaboration with our federal partners. We are doing a number of projects in coordination with the Department of Energy (DOE) at the Argonne National Lab to include qualification testing for high-pressure high-temperature environments, and testing protocols for determining Best Available and Safest Technology. We are also collaborating with the DOE on research at the National Energy Technology Lab. This November we expect to complete a study that further examines the formation and stability of gas hydrates under deepwater conditions and their interaction with hydrocarbons and dispersants. All of this research is critical to our understanding of new frontier environments and the technologies needed to operate in those areas.
In addition to the research we are doing on emerging technologies, we are investing nearly $15 million this year in our Oil Spill Response Research program. Much of this research is being conducted at the state of the art Ohmsett facility, which is the premier testing facility for offshore response technology and a world-class training site for oil spill response personnel. Ohmsett provides the Bureau a unique training environment that simulates real-world conditions in a safe and contained environment. This capacity was fully demonstrated during our Ice Month event in which various oil spill recovery technologies were tested in ice conditions similar to the Arctic using crude oil from Arctic production. Research at Ohmsett is further enhanced by our partnerships with other members of our federal family. For example, we are working with the U.S. Army Research Development and Engineering Command on enhanced oil spill detection sensors in low-light environments. This research will help ensure we have the most advanced methods and technology for oil spill detection, containment, treatment, recovery and cleanup.
For more information on our research and collaboration, visit our Research and Training section.
By: Allyson Anderson Associate Director of Strategic Engagement
August 18, 2014 - Every day the employees of BSEE work to reduce risk on the OCS, and we spend a lot of time thinking about ways to assess and manage risk. Last week I was given a tragic reminder that risk is inherent in our personal lives as well, when a women riding a moped on my street was struck and killed by a truck driver. While the exact cause of the accident will be under investigation for a while, it is clear that for some reason the driver failed to see the woman on the moped. Whatever the cause turns out to be, this accident and the memorial that has formed at the end of my street is a daily reminder to me that we can all focus more when we are driving and be deliberate about our safety, for the sake of the people around us and ourselves.
Every day tens of millions of people get behind the wheel of a car heading to and from work with distractions aplenty, whether its a phone ringing in the passenger seat, a quick text at a traffic light, or something as simple as turning to look at a child in the back seat. It is in that split second when attention is diverted that so many near misses and, sadly, some fatal hits occur. Nobody thinks it can happen to them, but it can and does.
While I, like many others, have heard that many thousands of people die annually in distraction-affected crashes, having it happen so close to home has made me realize just how dangerous it can be. It’s easy to think that the risk of distracted driving doesn’t apply to you, or that you can defy the odds, but the truth is that distracted drivers are endangering everyone around them. This is especially true now that schools are starting back up, with more people are on the road and kids standing at bus stops.
Texting is by far the most alarming distraction because it involves manual, visual, and cognitive distraction simultaneously. When someone sends or reads a text it takes their eyes off the road for 5 seconds. At 55 mph, that's the equivalent of driving the length of a football field while blindfolded. Just think about how extraordinarily dangerous that is.
The dangers of distracted driving are an example of what can happen when we lose focus on what is important. When we are not concentrating on the job at hand, there can be dire consequences. This is especially true in the offshore oil and gas industry. Much like distracted driving, it can be easy to take safety for granted, but it can also be alarmingly dangerous to do so. It’s important to remember that whether on the job, or at home with your family, safety success depends on knowing the risks around you, and ensuring you are focused, deliberate, and concentrating on reducing those risks.
To learn more about the dangers associated with distracted driving visit www.distraction.gov.
By: Michael Prendergast- Deputy Director of the Gulf of Mexico Region and Lake Jackson Hurricane Response Team Lead
July 30, 2014 - Hurricane season is underway and will run through November, and the Bureau of Safety and Environmental Enforcement has long standing policies and procedures in place to minimize the disruption of the production of energy for the Nation. This year there are as many as 13 storms predicted, 6 of which could spin into hurricanes. Hurricanes are common here along the Gulf Coast and when severe weather surges into the Gulf of Mexico oil and gas production facilities and drilling rigs are at high risk. The typical storm packs winds ranging from 39 to 110 mph. Major storms form less frequently, but they can pack winds ranging from 111 mph to greater than 157 mph. Major storms can also increase wave heights offshore in the Gulf of Mexico to greater than 80 feet causing severe damage and destruction to platforms and drilling rigs. In order to maintain safety of personnel and the environment offshore facilities evacuate and shut-in production before a storm enters the Gulf of Mexico. Also, drilling crews secure wells that are drilling and the crews are either evacuated from drilling rigs that are secured or moored to the ocean floor or the marine and drilling crews move deepwater rigs that are mobile out of the path of the storm until it is safe to return.
The BSEE Gulf Region Hurricane Response Team is activated in New Orleans, LA with a mirror team in Lake Jackson, TX. The mirror team gives us the ability to continue our response if the New Orleans team has to evacuate. In times of mandatory evacuation the New Orleans team moves to Houston since the city is less likely to be impacted by hurricane surge due to its higher elevation. The hurricane response team is responsible for reviewing and accepting operators’ daily curtailment reports, recording personnel evacuations from all platforms and rigs with evacuations, recording deepwater drilling rigs that have moved off location, monitoring shut-in statistics, and recording damage reports to platforms and rigs from post hurricane assessments. We report this information daily until the storm subsides.
We also monitor for any pollution that happens as a result of the storm. Our inspectors within the affected District areas conduct flyovers to get a visual assessment of each structure in the path of the storm surge. If you’d like to know more about BSEE hurricane response efforts and the responsibilities of each member of our response team visit our page that covers hurricane season http://www.bsee.gov/Hurricane/
Safety Culture Lessons from the GM Ignition Switch Internal Investigation
By: Michael Farber, Senior Advisor to the Director
July 15, 2014 - General Motors (GM) recently released the findings of its internal investigation into the various failures that led to 12 fatalities and many injuries resulting from collisions caused by faulty ignitions switches in a number of its models. The company found that the ignition switches failed to keep the cars powered in certain circumstances, but they initially did not understand that this failure would prevent airbags from deploying. The internal investigation determined that there were at least 54 frontal-impact collisions in which airbags did not deploy as a result of the faulty ignition switches. GM used the faulty switches for 11 years without issuing any type of recall.
GM’s experience provides a window into how companies of any size and sophistication can lapse into systemic problems that can result in tragic consequences. Lessons learned from the GM experience can be applied to offshore oil and gas operations, as well as any other industry where lives are at stake every day. These lessons include:
- Test what you think you know. Workers should continuously test their own conclusions. According to GM’s internal investigation, for at least two years after the ignition switch defect was identified, numerous GM teams (composed of engineers and other professionals) saw the problems as one of customer convenience and not safety. These GM employees did not treat the problem with urgency because they did not consider the safety implications of the failure, notwithstanding the fact that internal documents and outside studies linked the ignition switch failure to airbag non-deployment.
Offshore Lesson: Maintaining control of a well requires constant attention to various pressure readings and testing and re-evaluation of such readings to ensure that you know what is happening with the well. Offshore workers should test what they think they know to avoid loss of well control incidents. Companies that experience a loss of well control should thoroughly investigate, regardless of whether or not the incident resulted in death, injury, harm to the environment, or damage to the rig.
- Conduct thorough and disciplined incident investigations. Serious incidents deserve close analysis of all potential causes and consequences. The internal investigation determined that GM’s own investigations into airbag non-deployments were “neither diligent nor incisive.” In addition, investigators failed to take basic investigative steps - such as attempting to take apart and reconstruct both faulty and properly functioning switches. As a result, for years, GM was not able to determine the cause of the non-deployments.
Offshore Lesson: As part of a robust safety culture, companies should thoroughly investigate all serious incidents (including incidents in which serious consequences were avoided) and should evaluate all potential causes of the incident to avoid the chances of recurrence. This often should include equipment testing that requires an investment of time and resources.
- Set timetables; demand action. Without timelines and deliverables, investigations and other important tasks will not be completed in a timely way. The internal investigation found that GM officials did not act with a sense of urgency and failed to set timetables and demand action. The various investigations of non-deployment of airbags were delayed, and information was not shared between GM components. As the report noted, “everyone had responsibility to fix the problem, nobody took responsibility.”
Offshore Lesson: Offshore companies must work to ensure the timely conduct of incident investigations and clear lines of communication on recommendations that result from these investigations. A robust safety culture requires that companies, even for incidents where severe consequences are avoided, demand changes where problematic, unsafe conduct is revealed.
- When in doubt, “wake the captain.” Much as the captain of a sea-going vessel should be informed of problems that might imperil the vessel and crew, company executives should be alerted to safety issues with potentially grave consequences. The internal investigation found that GM personnel repeatedly failed to raise the growing concerns about the faulty switches with those at the top of the company. This resulted in the problems persisting for years after they were first identified.
Offshore Lesson: If incident investigations reveal significant safety problems, company officials should be promptly briefed and should initiate follow-up actions. Keeping unsafe operating problems “in the field” can have catastrophic consequences. If company leaders are informed, and those companies are committed to a robust safety culture, they can bring all necessary resources to bear on solving the problem.
Companies operating offshore should closely review reports like the GM report for lessons on the establishment and maintenance of a strong safety culture. Perhaps more importantly, companies should be vigilant in thoroughly investigating all of their own incidents with actual or potentially serious consequences and in finding ways to share pertinent information learned with others across the industry. Information sharing to address operational risks is an important feature of a well-developed safety culture,as highlighted in a recent speech by Brian Salerno, Director of the Bureau of Safety and Environmental Enforcement (BSEE).
BSEE is leading efforts to promote the continued development of robust safety cultures in companies that operate offshore. You can find the June 2013 policy statement from the Director of BSEE regarding safety culture here.
June is Safety Month
By: Rose Capers-Webb, BSEE, Safety and Occupational Health Manager
June 27, 2014 - The National Safety Council designated the month of June as National Safety Month. This year’s theme is "Safety: It takes all of us". The month is coming to a close but its important to always remember that whether at work or at home with your family, safety success depends on all of us working together to spot unsafe conditions early, evaluating their risk, and removing or controlling the risk before harm is done. At BSEE "Safety Month” is every month and it’s nice to have national attention on the subject, it gives us an opportunity to join with others to focus on safety issues that have the potential to touch everyone in the offshore community.
This year BSEE scheduled several activities throughout the month that built on the weekly topics. These were the type of activities everyone in the offshore community could utilize to build awareness around important safety issues. The month was kicked off with a safety word game competition between program areas in addition to various weekly activities. Week 1 focused on building awareness for prescription drug abuse, employees were provided with information on the hazards of prescription drug abuse. In addition, employees had an opportunity to participate in an eight hour First Aid, CPR, and AED certification training.
Week 2 focused on the prevention of slips, trips and falls. In addition to awareness information on prevention of injuries from these hazards, employees were also provided with an opportunity to participate in sponsored physical fitness activities designed to support the body core and help with balance and coordination.
The focus for week three, “Be Aware of Your Surroundings”, placed the focus on employee work areas and the recognition of hazards in the work area that can cause injury. Focus was also placed on the vulnerability of children and the need to teach children situational awareness and general awareness of their environment.
Week 4 was focused on Distracted Driving. Employees received information on the issues and the hazards created as a result of driving while distracted. Employees also had an opportunity to participate in online defensive driving course.
The focus on safety does not go away at the end of the month. Throughout the year we should remain committed to the safety of those around us and to ensuring that there is a safe and healthful work environment for all.
Speaking Up When You See Something Unsafe Offshore
By: Michael Farber, Senior Advisor to the Director
June 17, 2014 - The tragic loss of life and environmental catastrophe that followed the blowout in 2010 at the Macondo well brought into focus the importance of empowering offshore workers to raise concerns regarding potential unsafe operations and/or violations of law. It is critical that offshore operators and contractors create a safety culture that empowers and encourages workers to speak up when they see potential problems.
A good example of how to handle worker complaints about unsafe operations came, in the aftermath of the Macondo disaster, from an unlikely source - a company that recently pled guilty to violations that occurred during offshore operations. That company, Helmerich & Payne (H&P),
is a contractor that provides drilling services on platforms operating in the Gulf of Mexico. In May 2010, an H&P worker, on a platform located in Mississippi Canyon (the same lease area where the Macondo well is located), reported the falsification of certain documents reflecting the results of pressure testing of the blowout preventer (BOP) system to his superiors within the company.
H&P’s management, within 24 hours of the complaint, informed the operator of the platform about the allegations; and, after discerning the validity of the complaint, the operator and H&P reported the violations to the Mineral Management Service (the predecessor agency to BSEE). The company reported that an employee had deliberately falsified tests that would have showed that choke manifold valves (a component of the BOP system) would have leaked. MMS inspectors promptly inspected the facility and confirmed that certain pressure test documents had been falsified and that a number of blowout preventer system components were not properly functioning.
Valid pressure tests are critical to ensuring that blowout preventer systems can function to save lives and protect the environment in the event of a loss of well control. H&P’s decisive action in this matter may very well have saved lives and protected the environment from another catastrophic blowout. This type of response to worker complaints about unsafe operations should be a crucial component of any management system that is geared to identify and mitigate risks during offshore operations. In this case, the company properly placed worker safety above all other concerns –
including the potential consequences of disclosing illegal behavior among its workforce.
Contractors that are retained by operators provide the overwhelming majority of workers on offshore facilities. It is critical that operators and contractors work together seamlessly to address and mitigate safety and environmental risks. A number of recent incidents involved conduct of contractor personnel. BSEE will continue to be vigilant in investigating both operator and contractor roles in incidents and will work to identify and deter unsafe work practices. Responses like the one carried out by H&P will help BSEE fulfill this important mission.
By: Susan Green, Deputy Regional Supervisor, Field Operations, Gulf of Mexico Region
April 22, 2014 - In 2005 hurricanes Katrina and Rita pounded offshore oil and gas infrastructure in the Gulf of Mexico, toppling platforms, damaging wells and tangling pipelines. A little while later, hurricanes Gustav and Ike caused their own havoc on offshore infrastructure. While all offshore oil and gas facilities pose a risk during a hurricane, idle structures carry the unnecessary risk of pollution and damage to the ecosystem.
I recently had the opportunity to participate in the 6th Annual Decommissioning Summit in Houston, Texas with other BSEE staff members where I spoke about this topic and others. I presented an overview of decommissioning – past, present, and future from the BSEE perspective during the general session. I shared with conference attendees BSEE's view that inactive facilities and structures should not be left to litter the Gulf of Mexico and reminded operators in attendance of their obligation to dismantle and responsibly dispose of infrastructure if not used during the past five years or at the end of a lease term.
From the first signature on a lease, offshore operators know that they will have to one day clean up the area and decommission the facilities and structures placed on the leased area. This requirement is not new, in fact I have located “Section 6,” which deals with decommissioning, in leases dating back to 1954. This shows that early operators in federal waters agreed in their lease terms to one day remove their equipment and structures from the lease area.
I'm seeing progress toward industry meeting its commitment. In October 2010, there were 3,233 wells and 617 structures that were in need of decommissioning. As of January 2014, industry has decommissioned 1,924 wells and 373 structures from the original counts. I'm encouraged by this and remain committed to continuing to work with industry to provide for the most effective and efficient way for operators to meet their lease obligations and maintain safe operations offshore for both personnel and the environment.
For more information on decommissioning, you can view my full presentation from the 2014 Decommissioning Summit here.
By: James Sinclair, Marine Ecologist
April 8, 2014 - As the temperature rises and the school year winds to a close, many of us will be making our way to beaches across the country for summer vacations. If you live along the Gulf coast you might be headed to places such as Pensacola Beach in Florida, Orange Beach in Alabama, Grand Isle in Louisiana or Padre Island National Seashore in Texas. What you don't want to see while your there is trash washing up along the shore.
BSEE and our partners such as EPA and NOAA are working hard to reduce the amount of debris you see in the water. Together, we are part of an Interagency Marine Debris Coordinating Committee that is tackling this issue for the government. We are actively coordinating activities and making recommendations on innovative methods of reducing the amount of debris in the water. Not only does this marine trash pose a threat to your beach experience, it also harms marine life, increases the cost of beach and park maintenance, and causes costly repairs for boaters. The committee is currently drafting a report to Congress highlighting research priorities, monitoring techniques, educational programs, and regulatory actions.
This effort is well in line with BSEE's ongoing work to protect the environment and participating in this interagency committee is a way to leverage the valuable resources within our agencies to support that goal. While federal and international laws prohibit the disposal of trash and debris into a marine environment, the bureau’s Marine Trash and Debris program focuses on those laws by creating education and regulation to minimize environmental damage to the Outer Continental Shelf.
BSEE requires that all offshore operators use safe practices to prevent debris (such as labeling and securing loose items), display marine trash and debris placards on facilities, and manifest and send all trash to shore. In addition, all personnel working on offshore facilities must attend training programs about the proper management and disposal of trash and debris. Trash and debris inspections are conducted randomly each year.
The bureau’s program emphasizes the personal responsibility of offshore workers to help reduce the litter problem and control unintended loss of property such as empty buckets and hard hats as well as small trash items and packaging materials that can be lost in the marine environment. Education remains the key to prevention and is a major focus for the bureau.
By: David Smith, Chief of Public Affairs
March 31, 2014 - In an effort to provide greater transparency into the offshore energy regulatory program, we are working hard to make information and data more readily available to our stakeholders and expand our communication toolbox.
This week, we are bringing the conversation on reducing risks offshore to Twitter. We will use Twitter to alert followers to new postings regarding happenings on the U.S. Outer Continental Shelf, regulatory policies and decisions, and agency actions. Our Twitter feed will complement our use of this blog, the Director’s Corner, and our YouTube channel, and will link back to our Bureau website, http://www.bsee.gov.
Follow us at @BSEEgov to learn more about our efforts to reduce risks across offshore oil and natural gas operations on the U.S. Outer Continental Shelf.
By: Andre King, Office of Offshore Regulatory Programs
March 13, 2014 - Today I want to talk about a tool that will allow us to collect the type of information that has the potential to help prevent future catastrophic incidents offshore that endanger lives and the environment. Historically, it has only been after a thorough investigation that we have been able to closely examine the series of events that contributed to major safety incidents. BSEE has used this information to find ways to prevent them from happening in the future, but we can only garner so much information from an investigation. That is why we are working to put in place a program that will allow us to identify leading indicators and potentially stop these incidents before they ever occur.
We are in the process of developing a system that will allow the offshore oil and gas industry to voluntarily report near misses. Data from these reports will be analyzed by a third party and provided to BSEE, enabling us to work with the offshore oil and gas industry as a whole to identify important trends and enhance safety across all operations.
An important aspect of this program is that the identity of individuals and companies who submit reports will be completely confidential and protected under the Confidential information Protection and Statistical Efficiency Act. This will be accomplished by working with the Bureau of Transportation Statistics, who will collect near miss reports and analyze the data. Individuals and companies making reports will be legally protected from disclosure and from release under the Freedom of Information Act. What this means for the offshore oil and gas industry is that BSEE will not have access to identifying information and will not use these reports for enforcement actions. What we will receive, as will the oil and gas industry, is the aggregated data and analysis for safety purposes. Together, we can look at this information and use it to identify leading and lagging indicators to help prevent future incidents.
Some individual operators already have similar systems in place for their companies, but there is not yet a system for sharing that information or lessons learned. The system we are developing will provide an opportunity for BSEE and the oil and gas industry to collectively discuss important near miss data to improve safety offshore. We have already begun meeting with operators to discuss this system and are collecting their input. We will also be holding a series of public workshops in late April both in Houston and Los Angeles. As we get closer we will announce the exact dates and locations for these public workshops.
The near miss reporting system has the potential to help save lives and protect the environment. However, the tool is only as good as the information provided. We will need offshore workers to feel empowered to voluntarily report near misses and be active participants in creating a robust safety culture. I hope that you will join us in supporting the development of this important system.
By: Scott Mabry, Associate Director for Administration
March 4, 2014- Last week there was a House Committee on Natural Resources oversight hearing on the human capital challenges in the management of Federal oil and gas resources. Ned Farquhar, Deputy Assistant Secretary for Land and Minerals Management, was on hand to represent the Department of the Interior. During the hearing, Deputy Assistant Secretary Farquhar discussed the many actions BSEE has taken to address the Bureaus long-term hiring and retention challenges. I wanted to use this week’s blog entry to expand on the efforts we have made, and to reiterate our commitment to hiring and retaining a highly skilled, qualified and diverse workforce dedicated to accomplishing BSEE’s mission to promote safety, protect the environment, and conserve resources offshore through vigorous regulatory oversight and enforcement.
At BSEE, there are several hurdles we face when competing with the private sector to attract and retain top talent. Chief among these is the pay gap between what we pay our workforce, and what they can earn in industry. As mentioned by Frank Rusco, of the Government Accountability Office, during last week’s hearing, federal salaries for petroleum engineers from 2002 through 2012 remained steady, ranging from $90,000 to $100,000 per year while during that same period, salaries for petroleum engineers in the private sector climbed from $120,000 to over $160,000. This pay gap is not insignificant, and BSEE has had to be creative to overcome it.
One tool that has been extremely helpful in our efforts to recruit and retain staff, and overcome a portion of the pay gap, is our ability to offer a special salary rate to geologists, geophysicists, and petroleum engineers in our Gulf of Mexico Region. While salaries, with the special rates applied, still fall considerably short of industry, the differential offered is often the factor that sways the career choice of the women and men we need to fulfill our mission responsibilities.
In addition to the special pay rates, BSEE has deployed numerous other tools to meet its hiring challenges. For example, we have successfully used student loan repayments, recruitment bonuses, and relocation bonuses in preparing packages that best provide incentives for each new hire. Each of these programs has been crucial in the Bureaus efforts to attract and retain highly qualified staff. Though we will never be able to match the private sector dollar for dollar, we are using the tools available to us to attract the talented workforce critical to accomplish the Bureau’s important mission.
Despite the challenges we face, BSEE has been successful in its recruitment efforts. In 2012, BSEE hired 166 total staff with 79 of these hires coming from critical and hard to fill job series to include engineers, geologist, geophysicist, and inspectors. In 2013, the bureau hired 178 total staff with 67 of these hires coming from the critical job series. We still have much work to do to meet our staffing objectives, but we are focused on maximizing our hiring activities and making progress. New efforts, such as our pursuit of partnerships with industry representatives to identify and recruit senior, highly technical and skilled staff following their career in industry, and the creation of new development opportunities for current employees within the bureau are promising.
BSEE recognizes that long-term human resource challenges will continue to require the full use of the available hiring and retention incentives at our disposal. However, in addition to these important incentives, we are committed to providing a rewarding and challenging work environment for those special individuals who choose to work at BSEE. Each of our employees provides a valuable service to our nation, and our goal is to create an environment where each person can meet their full potential and are proud to be part of an organization that is focused on the safety of workers offshore and the environment we protect.
By: Michael Tolbert, Gulf of Mexico Region Branch Supervisor- Oil Spill Response Division
February 25, 2014-
Making sure that every oil and gas operator in the Gulf of Mexico is prepared to respond to the unexpected is a huge part of BSEE’s commitment to safety and environmental protection. One of the ways the bureau tests the readiness of these operators is through unannounced spill drills.
These drills are hypothetical situations created to have participants exercise their own Oil Spill Response Plan (OSRP). OSRPs are required by BSEE from every operator on the Outer Continental Shelf and must describe in detail what actions and resources are available should a spill occur. A focal point during the drill is making sure all response parties are notified as outlined in the OSRP. This includes involved federal, state, and local agencies. The next step in the notification process is contacting the necessary trained personnel for contracted spill response equipment and materials, and assessing the time needed to deploy those resources.
Operators are selected to participate in an unannounced drill based on the number of oil producing facilities, the volume of oil production, and proximity to sensitive areas. With an eye to the operator’s current activities, a location is chosen and a spill scenario is developed. Simulated weather conditions provided to the operator during the drill are used to produce a hypothetical trajectory of the spill.
By: Doug Morris, BSEE Chief of Offshore Regulatory Programs
February 18, 2014- One of the ways to ensure safety and reduce risk in Outer Continental Shelf (OCS) areas is through the use of available critical technologies that have been determined to be the best available and safest. The best available and safest technologies (BAST) requirement encourages innovation and continuous improvement and guarantees development in the safest, most responsible manner.
At BSEE, we are aware that there are many questions within the offshore community about our approach to BAST. In fact, BAST was the subject of numerous comments submitted in response to our Proposed Production Safety Rule. Currently BSEE is in the process of developing a BAST process that is transparent and data driven with participation by all interested parties. We will do this in the near future in conjunction with the newly established Ocean Energy Safety Institute (OESI). We expect industry to be active participants in the work of OESI, and specifically we want industry to assist in defining BAST for any given technology. It is important to note that the designation of technology as BAST will not automatically render existing technology as obsolete, or require replacement.
The questions surrounding BAST should not diminish its importance in safe and responsible energy development. We look forward to industry’s participation in a BAST program that will ensure safe and responsible energy development.
Note from Gulf Region Petroleum Engineer Lance Labiche, Chief--District Operations Support Section
February 7, 2014- In recent years BSEE has strengthened its response role for both deepwater and shallow water well control incidents. We developed and fine-tuned our technical expertise in the areas of source control and emergency response. Our engineers and inspectors are now regarded as the world wide leaders in these fields.
Most recently BSEE was called on to respond to a shallow gas diverter incident on a jack-up rig drilling in the shallow waters of the Gulf of Mexico. We were able to quickly pull together a team of our best engineers and were able to provide the technical expertise, leadership and oversight that are required to effectively respond to a well control incident of this nature.
In this particular response, BSEE served as the leader of a coordinated response which also included representatives from the U. S. Coast Guard. We stayed in constant communication with the responsible party and all other involved parties.
A large part of BSEE's role in this response involved the review, and approval of all procedures employed in attempts to bring the well under control in a safe manner. In order to accomplish this, BSEE coordinated numerous daily meetings, conducted multiple internal risk assessments of proposed procedures, and ensured that stakeholders were briefed in a timely manner. Ultimately, the leadership and technical expertise of the BSEE incident response personnel helped to resolve a potentially dangerous situation in a safe and timely manner.
Note from Alaska Region Director Mark Fesmire
January 28, 2014- The Arctic is one of the most distinctive environments in the world for offshore energy development. From seasonal ice coverage and floating ice, to subsistence whale hunts, the challenges posed in the Arctic are unlike any we face elsewhere. The Alaska Native communities living there are closely connected to the Arctic culturally, socially and economically. It is imperative that offshore exploration in the Arctic be harmonized with the needs of Alaskan communities, including traditional subsistence use. The coastal communities are on the front lines of offshore exploration, and we need to coordinate and communicate with them to ensure all operations are done safely and responsibly.
The need for enhanced communication and coordination is why the Alaska Region created the new position of Tribal and Community Liaison. This new position will be a member of my senior management team and work directly with me to ensure BSEE is responsive to the concerns and interests of Alaskan communities. We previously coordinated with communities through the BOEM Tribal Liaison, but I felt it was critical to have a person on my leadership team working directly with Alaska's organizations, Tribal Governments, coastal communities and community based organizations. The Liaison will be in regular contact with the Alaskan communities, keeping them apprised of activities offshore, and in turn keeping the Alaska Region Office aware of issues that may impact offshore development.
We are currently in the process of accepting applications for this new position, and look forward to having our new Liaison on board in the next few months.
By: John McCarroll, BSEE Lake Jackson District Manager Region
July 2, 2013
The BSEE Lake Jackson District Office, located in Lake Jackson, Texas, recently held a safety meeting to discuss the new safety culture policy. During the meeting we also played a video of the finding from the "Piper Alpha" facility incident that occurred in the North Sea on July 6, 1988 in which 167 employees of Occidental lost their lives. It has been almost 25 years since this tragedy occurred but it still is a chilling reminder of how important it is to have a safety culture within the entire organization. The Lake Jackson District employees held a question and answer session at the end of the meeting to discuss the new "9 Characteristics" of the BSEE safety culture.
The Characteristics are:
- Leadership Commitment to Safety Values and Actions
- Hazard Identification and Risk Management
- Personal Accountability
- Work Processes
- Continuous Improvement
- Environment for Raising Concerns
- Effective Safety and Environmental Communication
- Respectful Work Environment
- Inquiring Attitude
Empowerment, Responsibility and a focus on Awareness permeates in the “9 Characteristics of a Robust Safety Culture”.
The Lake Jackson District's safety program meeting was very successful in making our employees aware of their responsibilities for safety at work and at home.