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. The below questions and answers focus on joint coordination and data sharing.
Question: How focused are your agencies on collaboration and working together?
It’s important to us that the federal government is being consistent and is asking the same things of industry in a consistent way. We have regular opportunities to meet – Rear Adm. Thomas and I meet on a quarterly basis. Here in the Gulf of Mexico, our regional directors work to coordinate on a myriad of operational issues and we’ve developed a number of memorandums of understanding to address joint training, inspections and investigations. We work together to prevent accidents and incidents offshore and are focused on coordinating more effectively; the Coast Guard has the lead role, but BSEE plays a tremendous supporting role.
Our senior staffs are well integrated and I know that’s the case in the field as well. The Coast Guard and BSEE place an emphasis of our federal advisory committees having joint attendance and participation. That’s a really important of collaboration to have the leading regulatory agencies sitting down together with key stakeholders to address the challenges that we all face.
Question: Do you think there needs to be more progress and collaboration with regard to data sharing? How important is data sharing to the future of safety management systems?
I think it’s vitally important. Data sharing can truly raise the bar on safety. There are a lot of companies that collect information, use that information and improve their processes; however, this tends to happen only within the boundaries of individual companies.
We want to make it palpable to share safety-related information that could benefit the entire industry. We need to identify the most salient data elements, collect those and share them. But we also need to protect the source, because it’s very that there are concerns about proprietary information and legal exposure, so we want to make sure it can be done in a secure way. We want to extract the important safety information that can help everybody.
We want individual companies to be successful and safe, but we also want industry to be safe. We understand that offshore accidents are bad for the individual company, but they are also bad for industry. We want to prevent accidents on an industry-wide basis, and data sharing is the key. We need to address problems that may be affecting everyone, and so that before a big event happens.
Safety culture is not something that can be regulated. Regulations can provide incentives or structure, but safety culture has to come from within. And that means not only focusing on individual operations, but also on industry-wide operations. Data sharing is key at building a safety culture. I applaud COS for collecting data, sanitizing it and distributing it so that everybody can improve their safety culture. That’s the only way to build safety culture – not with regulations.
Question: This ties in with the data we’ve been talking about, but what about incentivizing good behavior as well as regulating or punishing bad behavior?
Incentivizing good behavior is one of the things we struggle with. You can’t mandate safety culture and you can’t direct how people think but if you can incentivize, that’s a pretty powerful tool. What are the incentives from the standpoint of sharing data? If you’re community-minded and think in terms of not only how you help your own company, by collecting an analyzing data, but helping your entire industry, I think there are benefits to that. That’s the meaning of it…although it’s a bit more abstract.
On a more concrete level, as we start looking at things like risk-based inspections, the fact that is considered is not only how committed a company is to sharing information, but also how committed the company is to sharing information across industry. It’s not the only factor, but I think it’s something that can be looked at.
There are a few levels of incentives to consider; if you’re not intrinsically incentivized when it comes to safety and environmental stewardship then you’re probably falling behind to start with; that’s the first level. The second level is the business-to-business incentives, which are much better than regulatory incentives. If you don’t require the same level of quality from your suppliers and partners that you demand of yourself, then you’re probably also falling behind.
Regulatory incentives can play a role, but they are the least effective. We look to recognize good safety and environmental performance by reducing our oversight of those operators and focusing on those who do not demonstrate the same level of commitment.
Question: Recently, I attended a talk by NASA and they were talking about their most successful techniques as they apply to the oil and gas industry, and would ask BSEE and NASA to share some of those risk assessment processes and resources. Is there a potential for this?
We did sign an agreement with NASA and, essentially, it allows us to work with them and make use of their probabilistic risk assessment. It’s hard to believe some of the work that’s been done by NASA as they deal with the space program and make decisions on the use of technology for which there are no standards. There are no standards to send a spaceship to Mars, so they have to make decisions based on risk assessments. How do they do that? Going to Mars is obviously not the same as drilling a deep well with environmental challenges, but I recognize that you don’t always have standards to rely on.
You have to make decisions based on innovative engineering. How do we apply risk assessment tools to these types of scenarios? We have a technology center that’s set up in Houston. It’s intent is to be a supportive mechanism to field engineers and chase technology. There is a lot we can learn, organizationally, from NASA, and that’s the reason behind this agreement. It’s very difficult to keep up with the pace of innovation. This is how we stay connected to industry and use some of the most advanced risk assessment tools in this emerging technology.
The problem is that probabilistic methods are very useful for determining design and construction standards of complex systems, but they are not useful for managing risk associated with operation of those systems or the human factor; that is not probabilistic problem. Even if we get to the point where we have our standards developed for how we build things we have to remain focused on the operational risk – and that’s where industry comes in.
Question: Are you thinking about joining inspections?
We are and in fact we have conducted a number of joint inspections. Results and effectiveness can depend on the vessel and type of inspection that we’re doing. But if nothing else, it’s great for our people to learn from each other and look at systems where we have joint responsibilities. Doing it at the same time and combining efforts saves time for both industry and the regulators.
We are looking for a way to share this information between BSEE and the Coast Guard to come up with a shared module of information. Maybe a system comes under Coast Guard jurisdiction but has an effect on BSEE jurisdiction or vice versa; we want to share that kind of information to improve our awareness.
Question: Could you say a few words about the environmental response aspect?
We have two focus areas at the headquarters level. One of them is the prevention aspect and the other is response. Of course an effective response starts with effective preparedness, and effective preparedness starts with effective plans and exercises. We are aligned in how we review joint response plans. The Coast Guard uses BSEE facilities with response technologies to develop new ways to look at worst case discharges and we also run joint exercises.
Beyond interagency, we do exercises internationally as well. We are currently working very closely with Mexico, running joint exercises there, and actively doing exercises with Canada and in the Arctic. We are also very close to getting details worked out with Cuba. So it’s a robust process that is not only interagency but also international
We hope the actual response itself is something we never have to get to but we do all of this to ensure we are ready if the time comes that we need to be.
A big part of this is robust coordination, not only between just the Coast Guard and BSEE but also the broader community involved. A part of this response community is called the International Committee on Regulatory Research and Development (ICRARD) with a whole range of federal agencies playing a contributory role which include BSEE, Coast Guard, EPA, NOAA and ACOE. Most of the response organizations have an interest in advancing technology and they participate as well. There is a level of coordination that is kind of behind the curtain but it’s quite extraordinary. The Coast Guard always has the pre-designated role as federal on scene coordinator but BSEE has a responsibility to improve offshore vessel response well. That level of coordination is constant; we hope we never have to employ it but the preparedness function is one we take very seriously.
Question: Can you tell us about the BSEE oil spill test facility?
The BSEE test facility is located in New Jersey and is the largest oil spill test tank in the country; it’s used by state and federal responders. Though it was offline about six months ago for upgrades, it’s back in full use. Last time I was there, people from Alaska were there testing equipment and training people. It provides an environment where it’s ok to spill oil in the water for the purposes of training and testing. It provides the opportunity for a lot of industry cooperation as well. Industry comes to test out new ideas and new concepts and conduct research, development and testing it. It’s getting a lot of use and that’s a good thing.
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.
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