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
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.