Last week, Maritime Commons attended the 2014 Offshore Technology Conference. For those of you who couldn’t make the event, here is a wrap-up of what was covered, during two panels, in which the assistant commandant for Coast Guard prevention policy, Rear Adm. Joseph Servidio, and Bureau of Safety and Environmental Enforcement director, Brian Salerno, shared the stage to provide a common vision on regulations and joint initiatives to ensure offshore safety.
Asst Comdt for Prevention Policy, Rear Adm. Joseph Servidio and Director of the Bureau of Safety and Environmental Enforcement, Brian Salerno at the 2014 Offshore Technology Conference. Photo courtesy of BSEE.
Complexity of drilling offshore
While producing oil is a complex process, producing it from thousands of feet underwater and from miles offshore introduces an even wider array of complications. These complications accentuate inherent safety risks that the energy industry takes to harvest these resources while the end user rarely considers the risk when using fuel, or petroleum based products, brought in from the Outer Continental Shelf in their regular everyday activities.
The Coast Guard and BSEE are working together, and as joint regulators of the offshore industry, they have the common goal to help ensure the safety of the crews that work on the Outer Continental Shelf, as well as to protect the marine environment.
The Coast Guard inspects offshore rigs, platforms and vessels for regulatory safety compliance with fire fighting, lifesaving and hull integrity systems while BSEE regulates the exploration, development and production of natural oil and gas. Since all of these systems are contained within the confines of any given rig or facility, all of these systems must be interdependent upon each other if the highest order of safety is to be achieved. Therefore, both agencies must work together to understand each other’s role, optimize the government’s resources and to ensure those risks that lie at the various seams of the systems interdependency are adequately addressed. To assist in the mission, the Coast Guard and BSEE also work closely with the Center for Offshore Safety, an industry organization focused on safety and safety management systems.
Rather than work on regulations after the fact, using lagging indicators, the Coast Guard and BSEE are working to develop leading indicators and create regulations with more performance-based options that will adequately endure the ever changing technology advances that develop much more rapidly than current regulations. The emphasis for both agencies at the conference was on safety management systems and their role in developing a safety culture within a company, as these needs play a vital role in keeping offshore workers and the environment safe.
“We need to get in front of these issues as opposed to right now, where we are responding to some of them. Progress has been made but I really do think a lot more needs to be done. I am concerned on how some companies view and implement a safety management system…I see growing risks in offshore energy and exploration as systems are more complex and interdependent,” Servidio said.
Safety culture offshore
Servidio and Salerno expressed that having safety management systems was not enough to mitigate risk in the complex offshore environment. They emphasized the need for a safety culture.
“We can’t regulate an attitude, we can’t regulate a commitment,” said Salerno.
The Coast Guard and BSEE jointly shared that they were seeing cases where safety management systems were in place on paper, but not being actively practiced.
“We just did a comprehensive report on the issues associated with the KULLUK grounding. The issue, from what we saw, was the linkage between the exploration aspect and the marine aspect. We need to get better at how we manage those risks, and who is managing them. People weren’t reporting what they should have been reporting. We saw a need for better risk management and we are taking action, along with BSEE, to ensure that we have better risk management in place,” said Servidio.
Servidio further explained that while the regulatory agencies cannot force a safety culture, they can provide management structures and improve the accountability with respect to compliance with these safety management systems. The Coast Guard and BSEE will be the ones to set a minimum standard and hold operators accountable.
“All of us are in this together; we need the ability to adequately address the growing risk in the offshore environment that is getting more and more complex every day and we each have roles to play,” Servidio said. “We will be providing oversight if compliance is a continual and persistent problem.”
Servidio stressed the importance of leadership within the drilling industry. While the Coast Guard and BSEE were united in their shared emphasis on the need for safety culture, they both emphasized that it would take industry leadership to create a culture where safety management systems are not just pieces of paper but put into actual practice, and where operators feel safe to speak up.
Both Salerno and Servidio commented on their shared commitment, between their agencies, to work in partnership with industry to improve safety standards.
“Our job as regulators is to keep pace as the industry advances. That brings up a fundamental question of how we can collaborate with industry in a meaningful way. Oil produced offshore passes through a lot of phases and so the regulatory process should encompass all of this. This is a priority for us as regulators. We are both up here together, conveying a consistent message, sharing information and having a consistent role in our inspection and investigative activities,” said Salerno.
USCG & BSEE working together
Servidio and Salerno speaking together at the 2014 Offshore Technology Conference was an outward demonstration of the partnership of Coast Guard and BSEE on offshore safety. During the conference, the Coast Guard and BSEE identified some specific goals and actions they were taking. Examples of the Coast Guard and BSEE working together included joint quarterly meetings with senior leaders in Washington, holding regular meetings on regional levels, conducting joint training with their inspectors, and sharing data to identify performance trends.
Salerno explained that the quarterly national-level meetings and regular regional meetings have resulted in formal agreements to limit confusion and eliminate the need for multiple regulators to visit facilities separately. The shared intent of this action is to lessen the burden on industry and make the inspections less cumbersome.
“We want to provide federal consistency. BSEE and the Coast Guard will work closely together in addressing risks and areas of concern, close gaps and seams, and put out harmonized requirements,” Servidio said.
The agencies also anticipate that data sharing will help identify those companies who have recurring performance issues.
“We will go forward targeting those companies that have a far more than average number of deficiencies. We expect things can happen but you shouldn’t have repetitive conditions that keep happening if your safety management system is working right. Historically, we have each had our silos and now we are working together. We have a team of people working on how BSEE and the Coast Guard can work best together and put all of our capabilities on those operators who need more attention. The focus is going to be more on targeting and providing additional oversight and enforcement on those that aren’t getting it and we are seeing some significant improvements,” said Servidio.
Servidio and Salerno concluded in their comments with shared sentiment that working together on offshore safety is where their missions are going to be focused.
“Our speaking together is an outward reflection of us working together. We have some concerns with some in the industry with managing risk. Together, in a unified fashion, we will address safety concerns on the Outer Continental Shelf. We will provide greater oversight, compliance and action when required,” said Servidio.
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.
