Maritime Commons attended the 2015 Offshore Technology Conference to provide you with a wrap-up of what was covered by the U.S. Coast Guard and the Bureau of Safety and Environmental Enforcement, or BSEE.
The assistant commandant for U.S. Coast Guard prevention policy, Rear Adm. Paul Thomas, and BSEE director, Brian Salerno, shared the stage on a speaking panel to provide their regulatory stance and joint agency initiatives for offshore safety. The panel was moderated by Charlie Williams, executive director for the Center for Offshore Safety – an industry sponsored organization focused exclusively on offshore safety on the U.S. Outer Continental Shelf
For those of you who were unable to attend, Maritime Commons is providing a condensed version of Thomas and Salerno’s remarks in a six-part series. These remarks are not ‘as delivered’ but provide a condensed version of the panel highlights in the ‘panel-conversational’ style.
Progress since Deepwater Horizon
Delivered by Brian Salerno:
The Coast Guard and BSEE both operate in the same space; we each have responsibilities for safety and environmental protection on the Outer Continental Shelf, and we are interacting with the same industry. It makes sense then that we strive for consistency at the federal level as we address a number of common issues. This is what makes the relationship between BSEE and the Coast Guard such a vital one. Neither organization wants to put industry in the position of having to de-conflict inconsistent requirements coming from two regulators. We want to assure consistency and compatibility of federal requirements up front, in all areas where our regulatory jurisdictions overlap.
Salerno highlighted a number of big changes within BSEE over the past 5 years:
• Well control
• Safety and Environmental Management Systems, or SEMS
• Changes internally within BSEE
• Strengthening the way we handle permits and evaluate new technology
• Leveraging industry standards as regulators
• Emergency response and capabilities
• Spill containment
• New focus on safety culture
Of all of these, I would say the most significant change, and one that we should all feel proud of, is the concentrated focus on safety culture that has developed over the past five years. It has been an important and strategic shift which has challenged us within the government to think differently about how we regulate. It has had an equally profound effect within the industry.
The next quantum leap toward a higher level of safety will be in the area of human factors, and specifically in the role of people as part of a complex, highly technical work process; this involves company commitment to safety at the senior leadership level, translated all the way down to the deck-plates where work is performed on scene.
I think of safety culture as what people do when no one is looking over their shoulder. As I go around and visit, I see evidence of this taking root in individual companies, however, it is still not universal. We have yet to normalize a culture of safety throughout the entire industry; we still have quite a ways to go.
Delivered by Rear Adm. Paul Thomas:
A great deal has been accomplished since Deepwater Horizon. After the investigation, our Commandant issued a Final Action Memo with over 50 items identified to close gaps, particularly in our prevention mission.
Since that time, we’ve closed about half of those gaps and we’re making progress on the remaining half. Those gaps really cross our entire spectrum of things we do in the Coast Guard. The way we do prevention is to work with industry to develop standards that make sense, put people and processes in place to ensure compliance with those standards, and conduct investigations into accidents and violations that allow us to improve on the standards and the compliance processes. The gaps that were identified in Deepwater Horizon span all those prevention pieces.
Thomas identified areas of progress for the Coast Guard over the past five years:
• Working with BSEE to improve our casualty reporting
• A number of proposed regulations
• Published training for mariners on the Outer Continental Shelf
• Working on a dynamic positioning regulation (currently open for comment on the docket)
• Final rules on explosion protection
• Looking at cross competencies and developing training and standards of qualification
• Build an industry-led school on mobile offshore drilling unit inspections
• Updated Coast Guard Marine Safety Manuals
• Reorganized so that mobile offshore drilling units, or MODUs, in the Gulf of Mexico fall under one Officer in Charge, Marine Inspections
• Strengthened the relationship between BSEE and the Coast Guard in operations, investigations and training
What we are driving to is ‘one Gulf, one standard.’ We want to make sure that both U.S. flag and foreign flag operators are all coming under the same standard.
I think the Coast Guard’s shift to a single Officer in Charge, Marine Inspections for mobile offshore drilling units is going to be very beneficial to the industry in terms of consistency. From a BSEE perspective, I think it will only increase the quality of the interaction between the Coast Guard and BSEE. It provides a single point of contact for our BSEE regional director on topics of mutual concern.
As you know, BSEE underwent a significant reorganization as well, going from the Minerals Management Service to the Bureau of Ocean Energy Management, Regulation and Enforcement, and subsequently BOEMRE was further divided up into BOEM and BSEE. That is a lot of churn over a five year period. However, I think it has provided a lot of clarity in how we jointly, with the USCG, approach areas of overlapping concern on the Outer Continental Shelf. The coordination has become much closer than ever before.
I think one of the real gold standards of interagency coordination occurs during hurricane response, when we track offshore facility status including evacuations. This information was historically collected by MMS and shared with the Coast Guard so that rescue resources would be prepared and ready if they were needed. This tradition has carried on with BSEE and I think it’s a tremendous example of interagency coordination. It now carries over to other areas of mutual interest such as our inspection and joint investigation responsibilities.
Salerno and Thomas want to continue the question. You can send your questions to them on Twitter using the #BSEEUSCG or write them here, on Maritime Commons.
In addition to this post, be sure to read the other posts from the 2015 Offshore Technology Conference.
Part 1: Progress since Deepwater Horizon
Part 2: Subsea containment issues
Part 3: Future challenges and opportunities
Part 4: Complexity of operations and cyber
Part 5: Risk-based operations
Part 6: Continuing the offshore safety discussion
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.