|BSEE Director, Brian Salerno
April 13, 2015 - Today Secretary Sally Jewell announced one of the most significant safety and environmental protection reforms in our history. The proposed Well Control rule will increase equipment reliability and build upon enhanced industry standards for blowout preventers and, in a comprehensive way, address the multiple systems and processes critical to well control operations. This is a significant rulemaking that will impact operations across the entire offshore oil and gas industry.
As industry evolves and develops new technology, it is important that BSEE evolves with them. Part of that evolution is updating our regulations to ensure industry is using best engineering practices, as well as innovative technology and techniques to increase overall safety. This proposed rule, which has been four years in the making, addresses many of the recommendations related to well-control equipment made in the wake of the Deepwater Horizon tragedy. The blowout, explosion, and resulting oil spill that occurred on that fateful day of April 20, 2010 resulted in the loss of eleven hardworking men on the Deepwater Horizon and one of the biggest environmental catastrophes of our time. The proposed rule aims to ensure that an event like the Deepwater Horizon never happens again.
While the blowout preventer was a point of failure in the Deepwater Horizon tragedy, a number of barriers failed as well, and it was the combination of failures that ultimately resulted in the loss of well control and the explosion. Therefore, as BSEE undertook this rulemaking, we diligently worked to ensure it would address well control in a more comprehensive way.
The proposed rule focuses on blowout preventer requirements, well design, well control, casing, cementing, real-time monitoring, and subsea containment. It will protect lives and the environment by requiring more stringent design requirements for critical equipment, rigorous testing, and continuous oversight.
We reviewed 368 recommendations that came out of investigations into Deepwater Horizon, and worked with industry, academia, and other stakeholders to implement the best ideas on the prevention of well-control incidents and blowouts. It was important to us that we had stakeholder involvement, and that we drew from the knowledge and skillsets within the industry, as we proceed with the development of the proposal. We have prepared a page on our website that provides an inclusive list of those reports, supporting documentation, as well as the industry standards that are being incorporated into the proposed rule.
The result of all this hard work is a proposal for common sense regulations that are properly aimed at the safety of personnel and the protection of the environment. Now that we have released the proposed rule, stakeholder involvement is more important than ever. The proposed rule is open for a 60-day public comment period, and we look forward to reviewing the input of all stakeholders.
More information on the proposed rule can be found HERE .
- BSEE Director, Brian Salerno
|February 13, 2015 - Last week the President released his 2016 budget proposal for the
Bureau of Safety and Environmental Enforcement (BSEE). The President’s
2016 request fully reflects the Administration’s Blueprint for a Secure
Energy Future by ensuring that development of the Nation’s vast offshore
energy resources is conducted in a safe and environmentally responsible
manner. Funds will be used to recruit expert engineers, scientists,
inspectors and oil spill prevention specialists to support the
development of risk-based approaches to oversight and compliance on the
Outer Continental Shelf
The fiscal year 2016 budget request for
BSEE is $204.7 million, a $46,000 increase over the 2015 enacted level.
The Administration’s proposal would provide critically needed resources
to further strengthen BSEE’s regulatory and oversight capabilities for
oil and gas development on the U.S. Outer Continental Shelf, as the
Administration works to responsibly expand domestic energy production
through the President’s all-of-the-above energy strategy.
The 2016 budget request includes an
increase of $1.7 million to support the evaluation of new and emerging
technologies and develop associated safety and oversight protocols
through the Engineering Technology Assessment Center. The increased
funding will add greater depth and capacity to the BSEE, so that as
industry continues to innovate and develop new capabilities, the BSEE
will be able to keep pace. The Center provides a Bureau-wide focal
point for emerging technology evaluation. The 2016 request also
includes a program increase of $750,000 for the Renewable Energy
Inspection Program. The funding will support the development of
regulations, inspection guidelines, procedures, and criteria for
inspections of offshore renewable energy facilities so that the
appropriate regulatory structure will be in place to protect the safety
of these facilities as well as the environment.
The 2016 budget will continue to build a
robust culture of safety, with a strong focus on risk reduction. The
Bureau will bolster its capacity for analyzing data gained through
incident reporting requirements, near-miss reporting, and real-time
monitoring. The Bureau will also continue to work with industry to
better understand their safety processes, so that BSEE can mitigate and
reduce risk. Through these initiatives and others, BSEE will continue
to ensure that offshore development occurs in a safe and environmentally
- BSEE Director, Brian Salerno
August 27, 2014 - Over the past few months we have lost some rising talent at BSEE to higher paying jobs within industry. While industry will certainly benefit from their experience and understanding of what the regulator is looking for, these are painful losses that underscore one of our biggest challenges going forward, recruiting and retaining top talent.
BSEE is, and will remain, a great organization in which to work; one that instills pride in all of its employees. We have a noble mission that is focused on safety, protecting both life and the environment on the Outer Continental Shelf. I have found that the BSEE team is filled with people who are motivated by the high calling of public service; of knowing that the work they do every day is helping to improve safety while contributing to the energy security of our country.
I have said in some of my recent speeches that BSEE should be the best first and last job in an offshore professional career, but it can also be a great place to spend an entire career. We offer great training in technical and other skills with a focus on enhancing the qualifications and capabilities of our team to enforce compliance with environmental laws and regulations, promote safety, and encourage proper stewardship and conservation of our nation’s offshore resources. We believe in a satisfying work experience, and offer advancement opportunities so that our employees can build on their skills and knowledge to be leaders in their field.
Like industry, BSEE is facing the "Great Crew Change." That means more advanced positions are opening up all the time--making this a great time for current and potential BSEE employees who desire professional growth and career advancement. To come on board, is to join an organization that is dedicated to advancing talent from within. With a wide range of training, mentorship and development opportunities, our employees can quickly build a multi-faceted career. As they spend more time within BSEE and develop more professional responsibilities, they may decide to take on new roles and responsibilities. That's something we not only support, but we encourage. Every BSEE employee has the potential to become a leader.
While it is obvious that BSEE isn't able to compete with industry when it comes to salary, we are looking at compensation, and other ways for BSEE to be more competitive. Congress has temporarily approved special higher salary rates through September 30, 2015 for grades GS-5 through GS-15 for Petroleum Engineers, Geologists, and Geophysicists within the BSEE Gulf of Mexico Region. We are working closely with the Department and the Office of Personnel Management to make those special rates permanent. We are also working to include structural engineers and inspectors in those job series included in the special pay. Additionally, we are evaluating the level of the special pay to determine if the current rates are sufficient, or if we need more.
In addition to special pay we are also exploring and using other pay incentives such as recruitment incentives and retention incentives similar to those recently approved for our inspectors. While pay is a very significant factor in the overall compensation package, it is also important to remember that there are many other benefits afforded to the federal workforce, which in the end, makes the overall compensation and benefit package extremely competitive. At a time when most in the private sector have eliminated retirement benefits, each member of our workforce is covered by a very competitive retirement program to include a defined retirement plan and the Thrift Savings Program (TSP) which provides up to 5% matching funds. They are also provided with generous leave time that increases the longer you stay in government, flexible schedules, and health and life insurance benefits that rival or exceed the private sector.
While we are making every effort to attract top talent now, we are also looking towards the future through our youth initiative. BSEE is partnering with a number of STEM programs to bring “offshore” to the classroom through a Science and Technology Challenge. By engaging with youth through technology, we hope to introduce them to the meaningful work they may aspire to as they make their career choices. While today’s youth are undoubtedly the future of BSEE, we are also interested in recruiting experts from industry who are looking to “give back” at the end of their career. These are people who have years of experience and technical know-how, but aren’t quite ready to retire yet. We want them to join BSEE and use their talents in public service.
I encourage you to visit our recruiting page to learn more about our efforts. You can also visit our LinkedIn page where we often highlight job vacancies and further discuss career opportunities at BSEE.
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.
March 24, 2014- Earlier this month President Obama released his Fiscal Year 2015 Budget, which provides the funding necessary for BSEE to provide effective oversight of oil and gas development on the U.S. Outer Continental Shelf (OCS), promote compliance with Federal regulations, and lead the offshore oil and gas industry toward a culture of safety and environmental protection. The President’s request will enhance our ability to keep pace with a dynamic industry as operators continue to pursue new and emerging technologies that enable them to develop our nation’s energy resources in deeper water and frontier areas.
The 2015 BSEE budget fully supports the President’s “All of the Above” strategy to expand domestic energy production by ensuring development of the Nation’s vast offshore energy resources is conducted in a safe and environmentally responsible manner. Funds will be used to support and recruit expert engineers, scientists, and oil spill planning, prevention and response specialists to support the development of strong scientific information and the timely and thorough review of permits.
The 2015 request furthers our strategic goals through a program increase of $905,000 to support enhanced review of emerging technologies by technical experts, and expanding project funding used to validate technology, test protocols and analyze economic feasibility. Funding in the budget request will also be used to recruit expert engineers to support the efficient review of applications to perform various offshore operations and for the continued development of ePermitting, which will provide greater transparency and efficiency, and give greater predictability to operators. The 2015 request will allow BSEE to continue to strengthen our regulatory and oversight capability on the OCS by increasing the capacity in multiple disciplines to adequately staff regulatory, safety management, structural and technical support, and oil spill prevention, preparedness and response programs. The development of robust scientific information and the timely and thorough review of exploratory and production permits are critical components of BSEE’s oversight responsibilities.
In 2015, we will continue to build a robust culture of safety, with a strong focus on risk reduction. Every decision and every action will be taken with the workers and the environment in mind. Risks to both will be appropriately balanced and mitigated. We will bolster our capacity for analyzing data gained through incident reporting requirements, near-miss reporting, and real-time monitoring. We will also work with industry to better understand their safety processes, so that in turn we can mitigate and enhance risk reduction. Through these initiatives and others, we will continue to ensure that offshore development occurs in a safe and environmentally responsible way.
BSEE 2015 Budget
March 12, 2014- This week I would like to share a few thoughts on the evolution of offshore safety culture, how it is transforming the way we regulate, and what it portends for the future.
Traditionally, the approach regulators took was to establish specific requirements, and then inspect for compliance. In response, industry, knowing what the regulators were going to check, prepared for the inspection much like a student studies for a test. The result was that companies became very skilled at passing inspections, but this didn’t necessarily mean a culture of safety existed.
For one thing, the traditional approach told regulators nothing about how a company really conducts its business, how employees and managers behave when no one is looking. Once the inspectors left there was no way to gauge whether safety was part of a normal routine.
For years we all saw this cyclical rhythm of compliance, then a gradual tapering off between inspections. This did not serve the interests of safety well, and it gave a false sense of security to upper management in many companies.
It also resulted in a misplaced burden of responsibility. Who ultimately is responsible for maintaining safety? Is it the regulator who periodically spot checks, or the operator who is there every day, and has intimate knowledge of its own people and processes?
We believe it is the operator’s responsibility to ensure safety on their facilities. In order to shift the burden of responsibility to industry we realized we must adjust our governing regulations and compliance verification procedures to reflect more of a performance based approach, rather than a very prescriptive check-list approach.
Last year we published our SEMS II rule, which really cemented this new approach. The goals of SEMS II are continuous improvement of management systems, empowering employees, and promoting a positive safety culture within industry. What is unique about the SEMS II rule is that we at BSEE do not dictate how it is accomplished; it is up to the operators to determine how to best apply the tools to their management systems and processes.
It has been close to a year since the SEMS II regulations were published, and the results to date have been a mixed bag. Some companies are very committed, and some don't get it. This doesn't mean the concept is wrong, but it does mean we need to better adjust our oversight and align our regulatory practices to reinforce safety conscious behavior and discourage complacent behavior.
For example, a company that has identified a defect and is taking corrective action under its own plan should be given credit for doing the right thing.
Conversely, those who pay lip service to safety should expect greater attention...more visits, greater scrutiny. This is ultimately a risk based inspection approach, predicated on the idea that companies which have taken the responsibility for creating a culture of safety will have greater flexibility in managing their safety operations.
At BSEE we are working towards a safety environment that goes beyond simple compliance with regulations and toward the adoption, by everyone, of a meaningful safety culture that permeates all offshore activities. Every decision and every action must be taken with the workers and the
environment in mind and risks to both must be appropriately balanced and mitigated.
February 25, 2014
Last week I was in Bellingham, Washington, where I visited Shell's Arctic Challenger vessel along with Alaska Region Director, Mark Fesmire, and senior leaders from the Coast Guard and the American Bureau of Shipping. The Arctic Challenger is the vessel Shell has designated for its containment system should it pursue and receive the green light for drilling operations offshore Alaska.
During my visit, I was struck again by the challenges the unique Arctic environment poses for companies and nations who work to develop the energy potential of the region. The visit underscores the need to move forward with draft regulations specific to the Arctic and reaffirms BSEE’s commitment to ensuring that any energy development that happens on the Outer Continental Shelf – whether it’s the Gulf of Mexico or offshore Alaska – is conducted safely and responsibly.
Safely and responsibly developing our domestic energy resources is extremely important to our nation's economy and security. Alaska remains a critical component of our energy portfolio, and we will continue to work with industry, stakeholders and our international partners to develop technologies, systems and processes that reduce risk and provide greater protection for workers and the environment.
February 18, 2014
The recent well control incident in the Gulf of Mexico has once again reminded us that risk is ever present, across all operations. While we are still working with the operator to understand the specific contributing factors to this incident, one lesson that generally holds true is that whether operating in new frontier areas like deepwater or the Arctic, or in well-established areas in the Gulf of Mexico and Pacific, risk management must be a part of everything we do. To reduce risk, we must first identify and quantify risk, and we can do that through improved barrier analysis and data collection.
We are bolstering our capacity for analyzing data gained through incident reporting requirements, near miss reporting, and real time monitoring. To truly realize the potential for this type of analysis we will be depending on the industry to share lessons learned and best practices.
One tool we will soon make available to the industry is the near miss reporting system. This completely anonymous system, which is being developed by the Bureau of Transportation Statistics, will enable offshore workers to report near misses in a way that protects their identity. BSEE will only receive aggregated data and analysis, and that will help us identify leading and lagging indicators. This tool has the potential to help prevent catastrophic incidents that endanger lives and the environment. However the tool is only as good as the information provided. We will need offshore workers to feel empowered to report near misses and be active participants in creating a robust safety culture.
Over the coming weeks, we will be meeting with industry representatives to discuss this tool and receive their feedback regarding the conceptual system. We must also complete several administrative steps regarding data collection before we can move forward with a working model.
The protection of offshore workers and the environment is the overarching purpose of BSEE, but most importantly it must be a top priority, and must become second-nature, for everyone across the offshore industry. We will continue to work with industry to cultivate a robust safety culture which takes a comprehensive look at risk and the barriers to prevent accidents.
February 6, 2014
This week I traveled to California to meet with our team in the Pacific Region, and witness first hand the work BSEE is doing to ensure energy development in the Pacific is done safely and responsibly. Each of our regions has unique challenges in delivering our mission, and in California resource conservation is of paramount concern. From the proximity of platforms to the shore, to aging infrastructure, to a nearby Marine Sanctuary, to the presence of Vandenberg Air Force Base, the conditions in the Pacific are unlike any of our other regions.
We often associate risk with the new frontier areas, rather than well-established areas such as the Pacific, but risk is ever present, across all operations. One of the ways our Pacific staff manages risk is through close coordination and communication with our Federal partners. Our partners in conservation include the Bureau of Ocean Energy Management, the Air Force, NOAA, the National Park Service, the Department of Transportation, the US Coast Guard, and the Environmental Protection Agency.
Two of the highlights of this trip were visiting Vandenberg Air Force Base and NOAA’s Channel Islands Marine Sanctuary office located on the campus of the University of California Santa Barbara. During these visits we discussed the region’s unique collaboration opportunities, and the continued need to work together to ensure the safety of offshore workers and protection of the marine and coastal environment. We are able to combine resources to better address issues such as facility security, emergency management response, data collection and education. Our Pacific Region staff is working smarter by working together and leveraging resources. Through careful collaboration and coordination our Pacific Region is reducing risk and ensuring safety.
January 31, 2014
This week BSEE hosted the 2014 Domestic and International Standards Workshop in New Orleans. Despite a rare winter storm that closed down much of the city, close to 300 representatives from government, industry, international regulators, and standards development organizations attended the Workshop. This impressive turnout underscores the important role standards play in ensuring safe and responsible energy development.
Proper standards are extremely important to both industry and BSEE. The regulatory process is not always agile enough to keep pace with the latest innovations. Therefore, we rely upon industry standards as an adjunct to our regulations to ensure that energy development on the OCS is safe for workers and the environment. This is especially true in new and challenging environments. Complex systems are needed to operate in these new environments, and with these systems come the risk of complex failures.
Even so, we need to ask ourselves if we are doing enough in the development of new standards, or do we need to up our game. There are two areas in particular where I think we need to see improvements. The first is in the timeliness of standards. Just as BSEE is working to make the regulatory process more efficient, we need to find a way to make the industry standards process more timely. Standards that are able to keep pace with innovation will make industry safer.
The second area we need to improve is the level of rigor in standards. Consensus standards generally contain many compromises but are these minimum standards really enough in light of the complex risk scenarios? This is especially true in high temperature and high pressure areas, deep water, and the Arctic. I know many companies are already doing much more than the minimum and I believe industry standards should reflect this. One way to add rigor is to incorporate recommended barriers that are needed to prevent or mitigate failures. Another way is to ensure that workers are properly trained in operating and working with new technologies, as well as preparing them for possible technology failures. We must ensure workers are not only properly trained in operating the equipment, but also trained in responding to equipment failures.
It is in all of our interests to prevent accidents on the OCS. Safety is a shared concern, we all lose when workers are hurt and the environment is damaged. A failure by one operator impacts the entire industry. Through rigorous and timely standards we can help prevent accidents from happening, and in turn make energy development on the OCS safer for the workers and the environment.
(For more information, click here for the News Brief.)
December 20, 2013
I would like to wish everyone in the offshore community a happy and safe holiday season. The end of the year is an important time for reflection, and looking back at 2013 it was a remarkable year. From the updated SEMS rule to the announcement of the Ocean Energy Safety Institute, we took important strides this year in the development of a safety culture. There were also some significant challenges this year, with multiple well control incidents. These incidents serve as a reminder that risk is ever present, across all operations, and that we must always be vigilant in our safety efforts.
As we look toward 2014 we will continue to build a culture of safety, with a strong focus on risk reduction. We will improve our data collection, so that we can better understand and mitigate risks. The near miss reporting system will be integral to our efforts. This completely anonymous reporting system will allow colleagues to look out for and protect one another. We will also work with industry to better understand their safety processes, so that in turn we can enhance risk reduction. Through these initiatives, and others, we will continue to ensure that offshore development occurs in a safe and environmentally responsible way.
December 12, 2013
Over the past few months I’ve had the opportunity to meet with BSEE staff from many of our programs and regions, and had meaningful conversations about how we can best fulfill our mission. These discussions have helped shape my vision for BSEE moving forward, and define the broad concepts around which I will set organizational priorities for the next few years. There are four key principles that will guide the work we do for the American public: clarity, consistency, predictability, and accountability. These principles are what every citizen, as well as the regulated community, has the right to expect from their government and they provide the standard by which our performance will be measured.
The bureau will build upon the solid foundation provided by the 2012-2015 strategic plan by prioritizing specific projects that will position ourselves for even greater effectiveness in our mission. As we prioritize these projects we will align them with six focus areas: people, safety and environmental stewardship, risk, organization, performance, and transparency.
Our guiding principles and focus areas will ensure all BSEE employees continue to be united behind one common purpose – to ensure that offshore energy development occurs in a safe and environmentally responsible way.
September 10, 2013
Two weeks ago I was sworn in as the new BSEE Director, and I am honored to lead an organization committed to a robust culture of safety. From the new frontier areas in the deepwater of the Gulf of Mexico and the Arctic, to the existing, shallow water operations, I will maintain BSEE’s strong emphasis on safety. However, safety is a shared responsibility, and cannot be fully achieved without the commitment of our stakeholders. One of my highest priorities as the Director is to build and strengthen stakeholder relationships to ensure all operations are safe for both the environment and the people working offshore.
Strong relationships are built on a foundation of trust, and trust must be earned. BSEE will earn the trust of our stakeholders through clarity, consistency, and open pathways of communication. Though they may not always agree with our decisions, BSEE is committed to always listening to our stakeholders, and clearly communicating the outcomes from those conversations.
Trust must be earned both ways, and while I am committed to clarity and consistency, I need a commitment from industry as well. Safety shouldn’t just be a priority on the days BSEE inspectors are on site; safety needs to be a priority 365 days a year. Companies that have a serious commitment to safety are the ones that don’t just meet BSEE regulations, they exceed them because they have made safety a top priority in their decision-making. They communicate regularly with BSEE and make us aware of new technologies and emerging issues so that we can better work together. On the other end of the spectrum, the companies that only focus on safety when a BSEE inspector is present will not earn our confidence, and those companies will be viewed as posing potentially higher risk.
At BSEE we work with industry, but we work for the public. The American people have put their trust in us to ensure that oil and gas development on the OCS is done safely and responsibly, and I look forward to earning that trust.
One of the simplest safety initiatives is having a safety moment to kick off meetings, workshops, and training courses. A safety moment is a brief (one minute) statement by a designated person that reinforces a particular safe precaution or practice.
A must-do safety moment subject is evacuation for alarms whenever the meeting, workshop, or training involves people not already familiar with the facility they are in. The designated person must point out the routes to safely exit the facility when a fire alarm occurs as well as the safe location within the facility if a shelter-in-place emergency occurs. Ideally there should be placards to help illustrate these routes and locations for each BSEE facility. As with any effective communication, diagrams and pictures help people get the message.
Most meetings involve people who are already familiar with the facility. A safety moment should not be repetitive. A safety moment in this case should be a statement about any safety subject that could benefit the attendees. Safety subjects often involve personal protective equipment, transportation safety, process safety, seasonal accident avoidance and the like. Most safety moment topics are simple reminders to use common sense to reduce risk.
As a safety regulatory agency, BSEE must have a culture of safety. That means safety is second nature to us. It means we feel uncomfortable whenever there's a safety lapse. What better way to reinforce our safety culture than by having a simple safety moment before each meeting, workshop, and training course?