August 19, 2014 - One of the most important aspects of my job as the BSEE Director is meeting and talking with our stakeholders. Whether I am meeting with the industry we regulate, original equipment manufacturers, non-profit organizations, tribes, or members of academia, the opportunity to talk and share ideas is incredibly valuable. I’ve had a number of such opportunities over the past few weeks, including last week’s forum at the Ocean Energy Safety Institute (OESI) on Eliminating Barriers to Data Sharing and Solutions.
The forum once again highlighted the important role OESI can play in getting the offshore industry to come together and define the parameters for what might serve as solutions to common problems. Although OESI was established by BSEE, it is not an extension of the bureau. It is an independent forum for dialogue, shared learning and cooperative research. We operate as one of many participants, others coming from industry and academia.
Last week’s forum had great participation from the industry and academic community, and focused on ways to overcome the barriers that currently inhibit the sharing of valuable safety data. Individual operators are collecting a lot of the data that is needed to properly assess risk within their own operations. I applaud them for doing so! That is a clear sign that these operators are taking safety seriously and are committed to continuous improvement. At the same time, information which could serve the broader interests of the industry is not being shared. Everyone is working in their own silo. The forum explored ways to enhance data sharing and thereby contribute towards greater system reliability through improved awareness.
This is one example of how the OESI can effectively serve as neutral ground for the exploration of issues that are of common concern to industry and regulators. I am hopeful that last week's forum, as well as the previous forum on Risk, will generate a robust discussion on future topics, as well as active participation by a broad range of stakeholders.
I am certain that, if we work together, we can improve safety on the OCS!
August 8, 2014- Over the past few months I have spoken many times about our Safety and Environmental Management System (SEMS) program, which is the cornerstone of our hybrid regulatory approach. Our goal is for the SEMS program to encourage the offshore oil and gas industry to adopt an approach to safety that looks beyond baseline compliance with regulations, towards an underlying safety culture that promotes continuous improvement in safety and environmental performance. SEMS is meant to be a tool through which companies manage the impacts of human behavior, organizational structure, leadership, standards, processes, and procedures – not simply a compilation of required documentation.
As part of the SEMS regulation, companies are required to submit a formal audit which would not only show that they have a SEMS plan, but that it has been implemented and is being used to manage safety processes. The first round of audits taught us a lot about both SEMS and the audit process, and we will be using those lessons learned to improve the program going forward.
Perhaps the biggest takeaway from the first round of audits is that the system maturity and level of SEMS awareness and understanding among operators vary significantly. The companies with long standing safety management systems were able to use the audit as an opportunity to evaluate their internal controls and reinforce their importance to their workforce. For others the first round of audits represented the first time they developed a formal SEMS plan, and for them it was more about fulfilling the requirements than using it as a management tool. The operators with strong SEMS plans were primarily focused on training and safe work practices. The challenge going forward will be the inclusion of more risk analysis in the SEMS plans. It seems as if companies are performing hazard analyses as corrective actions after something has gone wrong, instead of proactively using them as part of their standard operating procedures. The degree of variation in individual operators’ approach to SEMS demonstrates that industry overall is not where it ought to be in terms of process safety. There are clear industry leaders in this area, but overall, we want to emphasize the need for a comparable focus on risk analysis as on worker safety.
Just as there is great variation in companies’ approach to SEMS, great variation also exists in the audit process. This was apparent in the methodology employed, content, format, and scope of activities. There were several reports of companies conducting multiple audits if a noncomformance was found on the first audit. For these companies, the audits were repeated until the noncomformance was corrected or not reflected in the audit. Clearly there is still a perception among operators that reporting a problem will lead to increased scrutiny from BSEE, or a belief that the operator is deficient. The underlying issue we have found is that most operators still view SEMS as a tool to assess compliance, not as a risk reduction tool. We clearly need to continue to engage operators and contractors in discussions on the benefits of performing risk analyses as well as sharing lessons learned for the larger benefit of safety across the Outer Continental Shelf. There were no incidents of noncompliance issued for reporting deficiencies! That is not the intent of the audit process.
As we look toward the 2nd audit service, we will be using these learned lessons to improve the process. A key learning is the round of SEMS audits that will require the use of an accredited third party recognition that we must take into account the maturity of a SEMS program when developing audit protocols and conducting the audit. This will allow us to better assess progress of implementation, and identify those areas that need additional resources or attention. We will also continue to work with the industry and the Center for Offshore Safety on audit protocols and the importance of reporting both best practices and deficiencies.
For more information on our findings from the first round of audits, click here for a program summary of the First Audit Cycle.
July 7, 2014- Earlier this year Secretary Jewell announced an ambitious initiative to inspire millions of young people to PLAY, LEARN, SERVE, AND WORK outdoors. Since Interior first launched this important investment in our country’s future, we at BSEE have been working hard to develop programs that will build awareness and enthusiasm for our mission of ensuring that offshore operations are conducted in a safe and environmentally responsible manner.
One of the first steps we took was a visit to a Science, Technology, Engineering, and Math (STEM) high school in Houston. I was able to meet with both school administrators and students, and share with them the benefits of working in a STEM field. We talked about the excitement of working on the cutting edge of technological innovation, as well as the opportunity to contribute to the responsible development of our Nation’s energy. The energy and intelligence of the students was inspiring and left us all excited about developing opportunities to engage students like this in programs throughout the year.
I am pleased to now announce that as part of the Secretary’s initiative BSEE is putting together a Science and Technology Challenge as a way to bring “offshore” to the classroom. BSEE is already engaged with a number of different schools in promoting STEM programs. We will build on that, deepen those connections, have some fun, and more formally engage youth in technology innovation.
The Challenge will be centered on an identified technological challenge/problem in the area of offshore operations (e.g., oil spill prevention and/or recovery, remotely-operated underwater vehicles for leak detection; etc.). The plan is to allow schools most or all of the academic school year to work on a technological solution to the selected problem and to showcase these solutions near the end of the school year. We hope that the BSEE Technology Challenge will attract participation of a number of different schools nationwide, including those located near our regional and district offices. Our goal is to deepen our involvement with each of these schools, share experiences, and excite and inspire young minds.
As part of this initiative, we will seek to partner with companies who share an interest in engaging the next generation of offshore professionals. In addition, we welcome input from all stakeholders to help us select the technological challenge/problem to be addressed.
June 20, 2014- Last week the offshore community suffered a tragic loss when a helicopter carrying a passenger to a platform crashed into the Gulf of Mexico, taking the lives of both the pilot and the passenger. This followed another incident that occurred at the end of May, when a helicopter departing a rig with six people on board had to make an emergency landing in the water. Thankfully there were no injuries associated with this earlier incident, but it still underscores the risk that must be accounted for and the importance of aviation safety.
According to a Centers for Disease Control and Prevention report released last year, transportation incidents accounted for the majority of fatalities for offshore workers, and of those incidents the vast majority were helicopter crashes. From 2003 to 2010, 49 people in our offshore community lost their lives in helicopter crashes into the Gulf of Mexico. As a community we must do more to prevent these tragic crashes.
One way we can encourage safety and prevent incidents is by speaking up when an unsafe condition exists. A strong safety culture understands the value of reporting issues before they become incidents. Just as workers need to feel empowered to ensure safety during offshore operations, everyone who flies offshore needs to speak up if they see an unsafe condition.
Another way to ensure safety is to be aware of your surroundings. Though the pilot is responsible for the safe operation of the aircraft, each person working in or being transported by an aircraft shares in the responsibility for the safety of the flight. For example, it is critical that all loose equipment (i.e, jackets, helmets, backpacks, etc.) is secured before flight. Loose equipment can become missile hazards inside an aircraft experiencing turbulence or can fall from the aircraft through an unsecured cargo well and threaten aircraft control systems. In 2010 a pilot and two wildlife biologists were killed when a clipboard struck the tail rotor and the aircraft crashed.
Aviation safety must be a priority. Be alert at all times, recognize a safety issue when it is present, and make sure that when you see something, you say something. Reporting a problem to the pilot or aircraft operator is the best way to ensure that we avoid any more tragic incidents.
May 2, 2014 -- Every day the employees of BSEE dedicate themselves to ensuring safe and responsible energy development for the Nation. As a safety bureau everything we do is geared towards creating a culture of safety that ensures offshore workers are able to return home safely to their families. This month we are turning that same focus towards our own lives, as we join the National Safety Council in celebrating June as National Safety Month. The theme for National Safety Month 2014 is “Safety: It takes all of us.” I encourage everyone in the offshore community to take this opportunity to affirm their commitment to the safety of their workplace, their co-workers, and their families.
We are focusing our safety month efforts on four topics all of us are exposed to almost daily, and have the potential to cause serious injury, or even death. The first topic is prescription drug abuse. This is a growing problem in the Unites States. The Centers for Disease Control and Prevention reports there were about 148,000 deaths last year in the US from drug poisoning. Learn more about this public health threat and comprehensive government-wide actions being taken to reduce prescription drug abuse by following this link.
The second focus area is on preventing slips, trips, and falls. Though we put a lot of effort into safety systems to prevent these types of accidents offshore, there is also a risk at home. Six out of ten falls happen at home – adding handrails, maintaining good housekeeping and cleaning spills will help minimize these risks.
The third focus area is being aware of your surroundings. Whether you are at work on a drilling rig, or at home, everyone should be aware of his or her surroundings. For example, knowing the safest exit route in the event of an emergency can save your life and the lives of your family.
The fourth and final topic of safety month is putting an end to distracted driving. We all know the dangers associated with texting and driving, but eating, drinking, using navigational systems can be just as dangerous to you and the people you share the road with.
While safety month activities are important to creating awareness of various safety risks, and developing a strong internal safety culture, this is also a great time to review Safety and Occupational Health Programs. At BSEE, we have taken the opportunity to do so, recently entering into an interagency agreement with the Federal Occupational Health, an agency within the U.S. Department of Health and Human Services, to review and help us make needed improvements to our internal plan.
As we continue our efforts this month, I encourage the entire offshore community to join us in celebrating safety!
May 16, 2014 -- This has been a landmark week for the Offshore Energy Safety Institute. On Monday morning OESI named Jim Pettigrew as its first executive director. Jim has a very impressive resume, with a range of responsibilities in managing technologically complex, High Reliability Organizations, which I believe will lend itself perfectly to the mission of the institute. Monday morning was also the first day of the institute’s inaugural event, a risk forum attended by members of industry, academia, stakeholder groups, and government. I had the pleasure of delivering the opening remarks, and came away very impressed by the turnout and the amount of brainpower in the room. The two day discussion that followed was vitally important to both BSEE and industry.
In my opening remarks I challenged the participants to come away from the forum with a clearer understanding of how to approach a few fundamental questions surrounding risk. I wanted to know if they considered quantification of risk a realistic objective, or is a qualitative assessment of relative risks more realistic. I also asked them to discuss risk models, and whether or not a single risk model is appropriate, or should we be looking at variations on a single model, or even multiple models which are fit for purpose. Finally, I wanted to know how we should account for past performance in assessing risk on a company basis. Should we focus primarily on current state and make our assessments based on where an organization is today, or should we account for company history as an indicator of their commitment to a safety culture in making risk assessments?
These are the questions we are asking ourselves internally at BSEE, and it was great to have a public forum with our stakeholders to gain their input and insights. There is a reason that risk was the topic selected for the inaugural event of the OESI. In many ways, it helped establish the framework for how we approach the other topics which we anticipate for the OESI. We will be looking at topics related to Best Available and Safest Technology, and system reliability in the future, but these topics inevitably come back to how we approach risk. We are going to take what we learned at the forum and use it to inform how we approach the risks associated with the intricate interactions between technology, people, and processes that occur every day on the OCS.
May 2, 2014 -- Earlier this year Secretary of the Interior Sally Jewell formalized an ambitious initiative to inspire millions of young people to PLAY, LEARN, SERVE AND WORK outdoors. For the health of our economy and our nation’s public lands, it’s critical that we work now to establish meaningful and deep connections between young people – from every background and every community – and America’s great outdoors. This is an important investment in our country’s future, and it is important for the offshore community because it can build awareness and enthusiasm for the very important work we do. We need to inspire the next generation to share our enthusiasm for innovation and technology, so that they can be the caretakers of our Nation’s amazing resources.
These young people are our future. I encourage the offshore industry to join BSEE in reaching out to America’s youth, and showing them the exciting potential of a career in engineering and the sciences. My hope is that in the future we will be competing for their talents, just as we compete for talent today. The important thing is to get them interested, and keep them engaged.
The offshore community, on a daily basis, works with complex technologies and undertakes rigorous scientific analyses. The industry should continue to share these types of capabilities with youth, and teach them how exciting it can be to work with cutting edge technology. One way industry can do this is by continuing to identify new Science, Technology, Engineering and Math (STEM) programs, and reaching out to them to develop partnerships. We should all be sharing our experiences, and hopefully exciting young minds in the process.
At BSEE we have already started developing these connections. Next week, BSEE leaders will be working with young people at the Offshore Technology Conference. We will also be identifying leaders in each region and work to design and implement a plan to execute play, learn, serve and work opportunities for youth. This is important work, and I encourage everyone in the offshore community to embrace this great opportunity to connect with future.
April 23, 2014 -- It's been four years since the Deepwater Horizon explosion and resulting oil spill in the Gulf of Mexico. In the years since that tragic day we have seen the most aggressive and comprehensive reforms to offshore oil and gas regulation and oversight in our nation's history. It was out of these reforms that BSEE was born, and though we are still a young agency, we are ensuring that the United States can safely and responsibly develop its domestic energy resources. Specifically, we have strengthened requirements for:
Environmental Preparedness: This includes preparedness in the event of a blowout and worse case discharge. Deepwater operators are now required to have readily available the specialized equipment and systems necessary to control a subsea blowout, such as containment domes and capping stacks.
Well design: We published a drilling safety rule, which requires operators applying for a drilling permit to meet new standards for well-design, casing, and cementing. We are also reviewing comments on a proposed production safety systems rule that would provide the first updates to regulations for production safety systems since the late 1980’s.
Drilling Safety: New rules have been put in place, which strengthened requirements for blowout preventer (BOP) maintenance and testing. Additionally, we expect to publish a comprehensive proposed rule this year that will address the myriad systems and processes involved in well control operations. Our intention with this proposed rule is to account for all aspects of well control operations, of which BOPs are only one component, to help avoid future multiple system failures that resulted in the loss of well control and explosion aboard the Deepwater Horizon.
Safety Culture:We are also working with industry to create a culture of safety that goes beyond simple compliance with regulations and toward the adoption, by everyone, of a meaningful safety culture that permeates all offshore activities. The Safety and Environmental Management Systems (SEMS) II rule, published last year, is an important element in these efforts. The goals of SEMS is to support the continuous improvement of management systems, empowering employees and promoting a positive safety culture within industry.
Ocean Energy Safety Institute: The newly established Institute will provide an open forum for dialogue, shared learning and cooperative research among academia, government, industry, and other stakeholders. The Institute will facilitate research, development, training, and implementation of operational improvements in the areas of offshore drilling safety, environmental protection, blowout containment, and oil spill response.
All of these reforms were put in place to protect workers and the environment. We will continue to focus our energy on enhancing safety, reducing risk, and keeping pace with industry technologies. Through these initiatives and others, we will work to ensure that offshore development occurs in a safe and environmentally responsible manner.
April 16, 2014 -- We all know that in the quest for safety, regulations only get you so far. If we really want safety, we have to do more. We have to foster a culture of safety among all personnel involved in offshore operations so that it becomes part of the way business is conducted. That is the underlying philosophy behind SEMS. For SEMS to achieve its goals of fostering a safety culture, it must remain a reflection of company commitment, over and above regulatory compliance.
We recently completed the first round of SEMS audits and found that the audit information was limited. This is because there were few insights into how effectively an individual company used its SEMS process to identify and correct problems. As we move forward, we know that SEMS II built in some improvements to the audit process, such as third party audits, which could yield better results in the future. Ultimately, I think we need to do more. For one thing, we need need to address the reluctance to be forthcoming with information due to fears about liabilities or perhaps, worries that it might invite increased scrutiny by BSEE. We will be searching for options to increase the amount of information that is shared with the bureau and the rest of industry, while at the same time building in the protections that are needed to remove the barriers to sharing information.
Safety management is of particular importance to BSEE. It also of great concern to the U.S. Coast Guard. Last week I had the opportunity to share the podium with Rear Admiral Joseph Servidio at the Center for Offshore Safety Forum in Houston, and then spend the next day with him in Ingleside, Texas at the Marine Well Containment Company facilities where we were able to view their well containment equipment and discuss important containment procedures and capabilities.
During my time with Rear Admiral Servidio, we discussed our mutual goal of creating greater consistency and clarity in our joint approach to safety management. We are building on the Memorandum of Agreement that BSEE and the U.S. Coast Guard signed last year that focused on safety management systems, with a strong focus on collaboration at both the national and regional levels. As we tackle ongoing topics such as consistency between operators and contractors across all operations, our need for collaboration will only grow. AS BSEE and the U.S. Coast Guard work together to keep the offshore safe- we encourage all of our stakeholders to commit to our shared goal of making it the safest place to work in the world.
April 8, 2014- I am frequently asked about the prospects of oil and gas exploration in the Arctic. Questions come in equal measure from those who are strong proponents of exploration, and those who have serious concerns about the potential for adverse environmental impacts.
The Arctic is a pristine and austere environment which poses unique challenges for energy exploration and production. The potential energy reserves in the Arctic are compelling; and several companies have made substantial investments in their bid to develop these resources. At the same time, preservation of the Arctic environment is also essential to native communities’ cultural and subsistence needs, and for the overall health of a fragile ecosystem. Are these two concerns incompatible? BSEE believes both objectives can be accomplished, with proper planning, safety controls and careful risk management.
BSEE has been working closely with its sister agency, BOEM, to develop a proposed Arctic Drilling Rule. This forthcoming rule will put important safeguards in place for future Arctic drilling operations. We hope to release the proposed rule shortly and open it for public comment, continuing an important dialogue on drilling operations in the Arctic that has already included numerous consultations and public meetings.
In addition to our work on the Arctic Drilling Rule, we also have developed important relationships with our fellow Arctic offshore regulators because we know that an incident in one nation’s waters can quickly affect us all. This dialogue also provides a valuable opportunity to benchmark against best practices in other countries, relating to prevention, preparedness, and response. On this front, BSEE's own Mark Fesmire, David Moore, and Susan Dwarnick have been valuable members of working groups organized under the Arctic Council, specifically focused on prevention, preparedness, and response issues. BSEE is also the lead for many Arctic initiatives contained in the U.S. National Ocean Policy. Overall, we are participating in joint training and exercises, supporting development of international response guidelines, identifying response infrastructure gaps and ways to mitigate them, and conducting field experiments to test technology capabilities. All of this is designed to understand how to allow drilling activity to be conducted more safely, and with the environment in mind.
More specifically, BSEE has been very focused on source control and containment in the Arctic. By ensuring these systems are in place prior to drilling, our intention is to prevent or minimize oil releases in the event of an emergency situation. This is a shift from how we have approached offshore oil and gas development in the past. This approach, however, is consistent with the lessons learned from the Deepwater Horizon tragedy. Additionally, this approach is a key component of risk management as it promotes preparing for emergency situations before the emergency occurs. Such a proactive approach is also consistent with the harsh and isolated conditions that operators are likely to face in the Arctic region.
Most importantly, our goal is to ensure that operators have taken the necessary steps to ensure that drilling operations performed in the Arctic are done safely. This includes proper internal controls and planning, two areas that were highlighted in both the Department of the Interior’s and U.S. Coast Guard's reports on Shell's operations in Alaska.
The stakes are high in the Arctic. While there are significant energy resources, exploring for them requires proper planning, coordination, and a strong focus on safety above all else.
March 31, 2014- I frequently use my Director's Corner blog to talk about issues relating to risk offshore. I have spoken about the importance of instilling a robust safety culture and about putting strong safety systems in place. On Friday afternoon this was put to the test for one company in the Gulf of Mexico. Energy Resources Technology Gulf of Mexico, LLC/Talos reported to BSEE that one of their floating production vessels experienced an electrical black-out and began to drift off station. Personnel on board performed an emergency disconnect of the transfer system buoy and safely shut-in the producing well, minimizing the potential for pollution.
One of the tools I encourage the industry to use to reduce risks is barrier analysis. What barriers do you have in place to prevent incidents from occurring, and what additional barriers come into play when they do occur to mitigate their effects? Friday's incident, in addition to several loss of well control events during the past year, underscore the need for every company operating on the Outer Continental Shelf to ask themselves these questions. While we continue to work with the Coast Guard as they investigate the electrical black-out, we will spend just as much time capturing lessons learned from the barriers that worked Friday to prevent a significant spill from occurring. I challenge everyone across the industry to take a hard look at their own processes with their employees and strengthen the barriers they currently have in place.