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 address other challenges to include cyber, well intervention and future focus areas.
Question: Can you talk about well intervention regulation?
It’s not all that different from other operations that are currently happening. We have memorandums of understanding that parse out our agency responsibilities and in what areas we have joint responsibility. These same rules apply to well intervention. That’s why it’s so critical that we talk about this at the National Offshore Safety Advisory Committee. We’ll be working directly with Director Salerno on that and BSEE will add a great deal of value.
From my perspective, there’s still some work to be done in this area. Well intervention does fall under BSEE regulations; however, when these activities are performed from a vessel, the proper regulatory activities must be organized and coordinated. That’s important to both of us. Analyzing the gaps and mapping out a coordinated and consistent way forward is key for both of our agencies.
Question: Do you think scenario-based training is valuable in areas such as cyber, as well?
Scenario-based training is an important framework for this process. With regard to cyber, the scenarios aren’t that different from the physical scenarios we face. We just have to think about it in the same ways. As an example, we have procedures in place to build up, tear down and restart pumps, but not necessarily those same procedures for the software that runs the pump; it’s not a huge leap to determine what could go wrong.
Question: Are there going to be more efforts to categorize wells by their potential impacts (based on the size) if a spill were to occur? Are regulatory agencies scaling their response planning to the different sizes, specifically?
Answer provided by the Coast Guard’s Office of Marine and Environmental Response:
The Coast Guard works with the Dept. of the Interior to ensure vessels and facilities are properly regulated and implement sufficient response requirements in accordance with their planned operations. Often times, the operations include both Coast Guard and BSEE/BOEM requirements (vessel/ facility inspection requirements, oil spill response planning, and source control to name a few). Therefore, the Coast Guard and BSEE coordinate together to carefully review response plans to ensure operators and response organizations can sufficiently mitigate any impacts to the environment as a result from offshore operations.
Question: What are the most important things to you and your agencies?
The collection and sharing of safety related data is the piece that is of most interest to us right now. The real issue is in coming up with the right data sharing protocols so that everyone feels comfortable participating and sharing information for the benefit of the industry as a whole. Still a lot of work to do here but I think we’re on the right path. I encourage continued involvement by industry.
My real focus and area of concern is how we come out of this downturn of operations. We have literally hundreds of service vessels laid up right now and the last thing that we want to be is the speed bump to recovery. I think we’ll need your help to identify when the uptake happens and help us prioritize to get you back to work as soon as possible. We’re going to work that issue through our partnerships, groups like COS, and all stakeholders, to suggest ways that we can manage this.
I’d just like to encourage the discussion to continue. If you have a question, send it our way. You can tweet, comment on our blog, or any other method. We are trying to be as transparent as possible in this entire process. If you send us a question, we will provide you with an answer.
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.
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.