Commercial Vessel Compliance

5/9/2016: 2016 Offshore Technology Conference – Senior regulator opening remarks

Maritime Commons attended the 2016 Offshore Technology Conference (OTC) 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 (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 titled, ‘Perspectives Regarding Safety and Safety Management from Senior Regulatory Leadership.’

The panel was moderated by Charlie Williams, executive director for the Center for Offshore Safety (COS) – 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 four-part series. These remarks are not ‘as delivered’ but provide a condensed version of the panel highlights in the ‘panel-conversational’ style. Below are the opening remarks made by Salerno and Thomas at the 2016 Offshore Technology Conference.

Director Brian Salerno:

I really appreciate the chance to participate in this event because, like many of you, I really think it’s in the area of safety management that we stand to realize the most significant improvements in offshore safety. Technical standards are vitally important, but ultimately, it’s the people, and the way they conduct their business… and how they make the decisions, that matter most. We use the phrase – safety culture, but to some extent, that’s kind of an elusive term. We all think we know what we mean by it and believe we can recognize it on sight, but struggle with how to really define it.

I’d suggest that when we use the term ‘safety culture’, we’re really using it as a kind of shorthand, to stand for the many elements of a broader, organizational, culture that places a high value on safe operations. Safety plans, videos, slogans…these are important tools, but they never tell the full story. In order to assess the value a company or any organization places on safe operations, you really have to dig a little bit deeper. We must understand the decision making processes and the extent to which safety is embedded. It is very difficult to measure culture- but there are indicators, such as

  • The use of safety data for continuous process improvement and organizational decision making
  • The extent to which leadership and the workforce is committed
  • A sense of responsibility for the management of safety barriers

 

There are also indicators that COS is developing. This is a problem that we’ve all been working on over the past several years, and BSEE is very interested in looking at these safety indicators.

Safety as a defining characteristic of the prevailing organizational culture is relevant at many levels. It clearly is important at the company on an organizational level. It can also be a characteristic of an entire industry, inclusive of multiple participants who all face similar safety management challenges. And it can, and I believe should, exist at the government level, among regulatory bodies. Government agencies should strive to exhibit the same type of information sharing behavior that we advocate on those we regulate.

So with that said, there are a couple of key themes that will emerge for us, within BSEE, over the coming years…

Data sharing:

We are now engaged in a cooperative effort with industry -specifically with the Society of Petroleum Engineers- and also with COS to identify the most meaningful data sharing elements. We are focused on the ones that will help us broadly inform ourselves on system reliability matters. The intent is to move beyond individual companies conducting self-analysis and move to an industry-wide level of awareness through data sharing.

Regulatory consistency:

While the cooperation between the Coast Guard and BSEE is very strong, we are working in tandem with other regulatory agencies as well. I’ll also extend that to the global realm where we are working with our international counterparts, a very vibrant part of our interagency cooperation.

Risk-informed decision making:

We are also committed to taking a much more structured focus on risk – and using that as a basis for targeting our activities and an aid in decision-making. All of these things are directly tied to SEMS and the work that’s being done by COS (on behalf of the industry) and by us, the regulators. SEMS and safety management, in general, that’s where we can collectively and meaningfully raise the bar. A lot of good work has been done, but as we all know, it’s a journey and not a destination.

Rear Adm. Paul Thomas:

I’m grateful for the opportunity, once again, to have this very important dialogue with an industry that’s critical to our nation’s economy and discuss the challenges that we face to ensure we are able to produce the energy we need in a safe way.

When I sit down with my leadership team, safety on the Outer Continental Shelf (OCS) remains a top priority; despite the fact that there has been a downturn in the price of oil and activity, we are still intensely focused on this area for a number of reasons. One is that we know we have to catch up with you, and so, to a certain extent, we have some breathing room during this downturn – but we are also very focused on ensuring we are ready to keep up with you when business rebounds.

The four themes I’d like to emphasize, not surprisingly, parallel those from BSEE.

Regulatory coordination:

The first thing we’re really focused on is Coast Guard and BSEE coordination and jointness. We’re focused on this at the strategic level in Washington D.C., and the tactical level down here (on the Gulf) where the work gets done. We are committed to ensuring our regulations are complimentary and not contradictory.

Data sharing:

Data sharing is not only important on the industry front but also between regulatory agencies, because we are all better informed when we have the information that we need. Sometimes that data is very similar and sometimes the same information says very different things; oftentimes, when we look at it together it makes much more sense. This allows us to plan, as regulatory agencies, and produce a joint report on performance – as we see it – on the OCS.

Well intervention:

We’re working closely with the National Offshore Safety Advisory Committee and the Offshore Operators Committee because, quite honestly, I’m not sure there is a full understanding of everything that’s happening on the shelf with regard to well intervention. Who’s doing what? How are they doing that? And what are the risks associated with it? What are the appropriate risk mitigation measures that should be associated with those operations, and vessels? And which type of vessel should provide those risk mitigation measures? This will remain a focus area for us and I hope to make great progress over the coming year.

Cyber risk management:

This industry is operating in cyberspace; cyber represents an operational risk that needs to be managed in the same way that physical risks are. I will tell you that across maritime industry, no one is doing that better than the deep-water drilling industry.

I’ve seen really great examples that incorporate cyber risk management into their business practices. We need to keep this in the forefront of our minds because cyber offers a real vulnerability, not just from the security standpoint and the need to guard against potential attacks- but also from a safety perspective as human factors can bring the potential for cyber accidents as well.

As a regulator, I’d like to congratulate those of you who are leading the way in the maritime sector in addressing cyber vulnerabilities within your operations. I’ll be at an International Maritime Organization meeting next week working on cyber guidelines for international shipping; I will be using some of the material that I have seen from this industry as examples as I talk to the international committee.

Safety management systems:

Currently, not everyone on the shelf is required to have a safety management system and that’s a gap the Coast Guard is struggling to address. I would encourage you to read the latest edition of Coast Guard Proceedings magazine; it’s all about safety management systems and how they can be implemented effectively and what the inherent values of those systems are – not just to the organizations that implement them, but also to the industry that faces these issues. It’s especially important on the OCS that it’s not done by individual companies but by a collection of companies, working together, because the weakest link in that chain represents vulnerability for the entire industry.

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 entire series from the 2016 Offshore Technology Conference.
Part 1: Opening remarks
Part 2: Joint coordination and data sharing
Part 3: Safety management systems
Part 4: Finishing up the 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.