Commercial Vessel Compliance

9/27/2016: 2016 Center for Offshore Safety Forum – Risk-based inspections and safety management

Assistant Commandant for Prevention Policy Rear Adm. Paul Thomas recently joined Bureau of Safety and Environmental Enforcement (BSEE) Director Brian Salerno at the fourth annual Center for Offshore Safety (COS) Forum in Houston.

The panel was moderated by Charlie Williams, executive director for the COS – an industry sponsored organization focused exclusively on offshore safety on the U.S. Outer Continental Shelf.

For those of you 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 questions and answers from the panel related to risk-based inspections and effective safety management.

Williams: There are all kinds of ways at looking at what risk is. Directionally, what do you think risk-based is going to mean in the future?

Thomas: When you talk about risk-based, it’s all of those things. It’s where are you operating and when are you operating. You’re probably higher risk if you’ve just come into the Gulf and you’re just starting to operate. From our standpoint, you may be higher risk if we’ve never seen you before. Certainly, if I look at a BSEE audit report, and I see a large number of non-conformities associated with the SEMS, I can make an assumption that there might be problems associated with the systems that I’m concerned about.

All of that is part of the overall risk picture, and the more robust the database we’re looking at, the better picture we have of risk, not only on a unit by unit basis but also across the Gulf. We’ll look at COS data, we’ll look at all of that, and that’s what risk-based is all about. It’s also about understanding quickly if the operation is high risk or not. If it’s not, I don’t have to dig as deeply. If I’m starting to see risk indicators at the surface, then I might have to look at the safety management system.

Salerno: We are very interested and committed to pursuing risk-based methodologies in how we conduct business in the future. We have initiated a pilot program that I would call somewhat exploratory in nature in terms of determining what are the right and most meaningful elements that we can build into a risk-based inspection regime. We’ve had a couple of inspections already that were prepared for us by a national laboratory and it brings in a lot of different variables – complexity, past history and a number of other things – that are just indicators. As we’ve gone through the model, we’ve taken a pause on how we will proceed with the pilot and probably will make some adjustments on the pilot based on what we’ve learned on the first few.

The companies that have participated in that were extremely helpful to us and helped us refine our thinking as to how we go forward. The bottom line is – I see this as the future. It’s a resource issue for us, at it’s very base level, but it also makes sense. We want to focus our efforts where they will do the most good. We also want to recognize that when people are doing things right, we don’t need to spend as much time inspecting them.

There are a couple of things that really need to come together there. I think when we talked about maturity in SEMS, I think that will be a very important component of any future risk-based calculation. If a company is doing it right, if they are identifying gaps and then building that into a corrective action plan on their own, that’s a sign of a really healthy system. But we need the methodology to gauge that.

Williams: Regarding collecting indicators, collecting data and collecting data on barriers, are we headed in the right direction? Should we be doing more there and is that where you’d like to see us going, focusing on barriers? Is measuring barriers a good place to measure culture and SEMS/SMS?

Salerno: I applaud your efforts on doing that. I think it’s vitally important. It’s of great interest to us in BSEE. Barrier management is at the core of what we’re really interested in. That’s where safety is being managed in its most meaningful ways. We’re looking for further development on that and incorporating that into our inspection activities, refining them and using them as part of risk-based inspections. I think what you’re doing is useful and it’s necessary.

Thomas: I agree. I’ve actually taken some of your work and applied it in other areas. Measuring barriers, understanding them and assigning ownership for barriers is very critical. I think that same model will work in the cyber world, and that’s where we’re trying to apply it today. There are a number of barriers both before and after a cyber incident that belong to specific individuals that you can define, measure and assign accountability for. That’s really what this is all about, as well.

Williams: Is there anything you wanted to share about things you’ve learned so far in the second round of SEMS audits?

Salerno: It’s all preliminary, since we haven’t fully gone through all of them or analyzed them. The first impression is that the quality this time around is better than the last time, which stands to reason – there’s more experience with it. Additional procedures were put in place and tightening up on audit procedures, which I think are having a beneficial effect. That said, within the range of the pool of the audit results that have come in there is a lot of variation – some are higher quality than others, and I think that’s normal.

If there is anything that emerges from a preliminary standpoint it’s things like management of change. It may really emerge as a focus area for the future. It’s not really clear how well that’s being implemented in all cases, but that’s just one example. But again, these are learning opportunities and that’s why the information sharing is so important. If we can gather meaningful information from these audits and share it, the idea is a rising tide will lift all boats – we’ll all get better.

Question from the audience: How closely do you both look at the Learning From Incident data that’s published by COS and with that new requirement for the surface safety systems, do you see more things coming down the road sort of like that? As you both look at previous incidents, are you going to use that as direction to develop updated or stricter guidelines on how we run our businesses?

Salerno: In general terms, we are interested in all that kind of data. If there’s learning from incidents that has been developed by COS and other industry groups, we’re vitally interested in that and we do look at it and we take all of that into account. We feel that we get better and more effective as regulators the more we pay attention to what you’re seeing and the lessons that you’re learning. It helps us refine our process and procedures. We’re always tuned in to that.

Regarding Best Available and Safest Technologies (BAST), that was a topic of some concern within the industry when the production safety system rule was first proposed. Over the course of the last three years, there was a tremendous amount of outreach to industry groups, trying to refine what that process would look like. I think we’ve come to some agreement to where it would make sense and how it would be used. We’re now considering a couple of candidate projects to test that model out and see how well it works. I think it will work pretty well, but that’s an opportunity for us to get engaged and maybe refine that process if it needs it.

Williams: It seems that with the technology office in Houston now, and that being close to the OEMs and the operators, that also may help with some of the concerns about BAST.

Salerno: Exactly, and that’s one of the reasons why the technology center is in Houston. It’s for that easy access to the companies, to research and development centers and to academic institutions where a lot of this can be studied in a cooperative way.

Question from the audience: Is there going to be additional follow up to the outcomes of the Society of Petroleum Engineers (SPE) Summit?

Salerno: I think the summit was very successful and there’s been a lot of follow-on work, with COS as a key participant in this. The idea is to refine how we collect information collectively and information that we need to share. How do we make it safe to do that? So that people have the confidence that information collected will be used for the right purposes? But also that we are collecting the right information?

I think both COS and SPE have done a tremendous amount of good work in refining the data elements that are most meaningful, so when people start reporting them, we can compare apples to apples and we can start looking at trends and gaps that are actionable. That’s proceeding, and it’s ongoing. We’re all feel very positive about effort and the direction it’s taking.

Question from the audience: It seems to me it’s just a very short leap to use other industries that were at the SPE Summit to help us look at data. It’s interesting to me that it was the culture of other industries that’s really behind how they use the data. I’d also like to get your perspective of different groups, such as the FAA. Is there any learnings of them or of the airline industry that we may want to bring here?

Salerno: Absolutely there is. A couple of weeks ago I had lunch with the National Chairman of the Transportation Safety Board. One of the things he mentioned is that the airline industry was really in the same position that we are in, in this industry. A lot of people were very reluctant to share information – a lot of people are in competition with each other – and there’s always that fear of how that information will be used.

They finally figured out that they have this shared interest in safety, and that it made absolutely no sense to compete on safety. A plane falls out of the sky, and it doesn’t matter what airline it is – the entire public is afraid to fly. They all lose when that happens. So there was a shared interest in elevating safety for all of them. They will compete bitterly in other areas, but they can’t compete on safety. And I think that’s sort of where we’re at, but we’re not starting from scratch.

Sharing information, the work that we’re doing with COS and SPE to really understand system reliability and where there might be problems, ideally getting to leading indicators so we can spot things before they become indicators – that’s where we want to be at. If we can cooperate and get to that level, and do this in a non-regulatory, but in a cooperative, way. None of us want an incident. We all lose when there’s an incident. Even regulators lose when there’s an incident. We’re all in this together to some extent. We all rise and fall on the safety performance on this industry. One of the key things they did in aviation is remove the fear from reporting. They have an anonymous reporting program, and they recognize that was essential. All the planes are using air traffic control, they are all using ground control, they all have to coordinate with each other and if there are problems with a system that they all rely upon, they need to fix it. But the only way they could get at that is if they were free to report without it really blowing back at them. It took some effort – it’s not easy – but they realized that there was a public good to be served by that, and they were able to put that into place. That’s what we can do with near miss reporting in the offshore industry as well. We just have to have the courage to use it.

Thomas and Salerno want to continue this discussion on Maritime Commons. If you want to follow up with any questions or thoughts, leave them in the comments below or tweet them to @maritimecommons using #BSEEUSCG.

In addition to this post, please be sure to view the entire series from the 2016 Center for Offshore Safety Forum.

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.

Leave a Reply