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.
Continuing the discussion
During the panel, Salerno and Thomas took questions from the audience and questions that were live-tweeted using the #BSEEUSCG. This post compiles some of the questions received during the panel.
Question: Given the disconnect between operators, and their SEMS plans, and contractors, how will SEMS 3 tackle that? What will SEMS 3 do?
SEMS III is still a concept; there’s nothing written down yet but I think we need it or something like it. It doesn’t necessarily have to be a regulation, as long as we have a framework for building on what we’ve done already and then take it to the next level. One area we particularly want to address is the harmonization of safety plans between operators and contractors.
Along these same lines, there is also a lot of value in sharing information. There’s a lot of information collected by individual companies that is not required to be reported to BSEE or to the Coast Guard. If it were shared, it would be enormously beneficial to our collective understanding of system risk. That’s the rationale behind this new near-miss reporting system that we just announced – Safe OCS. Companies are collecting a lot of information but it’s very silo’d. It is not shared due to concerns over liability and legal exposure. I understand that.
However, if we were able to address these concerns, and actually identify and analyze trends occurring industry wide, we’d be able to get a better handle on systems reliability and leading indicators. That is the intent behind Safe OCS. It is a confidential system which protects the submitter from his or her identity becoming public information.
Rear Adm. Paul Thomas:
The Coast Guard is going to get back to doing more risk-based inspections. One of the key factors that we’ll look at, in terms of who’s high risk and who’s not, is how well those safety management systems are implemented.
One of the keys, because there are so many players in this industry, is to increase transparency. I’m going to work on increasing transparency so that industry can see what regulators are finding when we’re going on vessels. I think there’s an opportunity for industry to do the same because you are on board more than we are. I would like to see transparency and a strong safety culture throughout this industry.
Question: You were looking at doing something similar to safety management systems for the offshore supply vessels on the Outer Continental Shelf. I understand the Coast Guard is looking at having to give a justification for doing that and it’s been put on hold. Can you give us an update as to when we might see more on that? I’m glad to hear that you’re putting language around the qualification of the assessors that are going to assess the dynamic positioning operators but when it comes to the capability and competence of the folks on the vessels that you’re stepping on, are we going to see something coming for them that is ‘SMS like’?
Rear Adm. Paul Thomas:
Many offshore supply vessels are already certified under International Safety Management, or ISM, code so they have third parties. We published an advance notice of proposed rulemaking asking for comments on this. Our Authorization Act last year basically put a provision in there that said before you proceed with any further rulemaking on SMS for OSVs you need to provide us with a report. We’re working through this right now but I’m hopeful we’ll get there. We want to get comments on this through the rule making process and get to a good solution.
Question: Should there be a rating system to differentiate between those companies that have a safety culture and those that have room for improvement?
Rear Adm. Paul Thomas:
I think we need to think about how we incentivize that. If we see a record of high performance, I don’t need to waste my resources on that. We have lots of places that we need to allocate our resources so it makes sense to save time on those who have proven track records. We’re constantly looking for ways to effectively use our resources.
The Coast Guard and BSEE work closely together and we recognize the impact that we can have on industry and the value this brings to our nation. Our goal is that we do it in a way that doesn’t ‘speed bump’ the economy. I’m asking for your help because I believe that the people who understand the systems the best know the best way to set standards and what those standards should be, so participation in our rulemaking process. We need your input.
A lot of good things have happened but I feel obligated to mention that none of us should declare victory yet. We released a report earlier this week that contained trend information. In many ways the trends are encouraging. In other ways, they point to needed improvements.
The number of fatalities and oil spills is trending down, which is a good thing. However, we still have cases where we’ve lost well control. We average about six of these a year, most of them not severe, but they have the potential to be far worse. We had about 303 injury cases a year, which is down over the long term, but trending back up over the past year, so we shouldn’t get over confident. As we have all seen, it is bad for the entire industry when major incidents occur. Moreover, there are no acceptable losses where human lives are involved. The only acceptable number there is zero.
We still have work to do. We are absolutely safer than we were five years ago because all of the work that has gone into improving standards, enhancing capabilities and the progress with SEMS. We need to build on that and keep the momentum going. You represent an extremely dynamic and innovative industry. You’re never sitting still; you are always developing new solutions for technological challenges. Along with the emerging technology, thought needs to be given to the safety margins, including the human element. I know many of you already do that. Realistically, it requires appropriate standards and potentially regulations as well to set the expected level of safety. We look forward to continuing to work with you, getting your advice and ideas as we move forward.
Note: For more information about injury statistics from last year, view the BSEE Annual Report.
Salerno and Thomas want to continue this discussion on Maritime Commons. If you want to follow up with any thoughts or questions, post them here or to Twitter using the hashtag #BSEEUSCG.
In addition to this post, be sure to read the other three 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.
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