In May, Capt. Joshua Reynolds with the 8th District Outer Continental Shelf Officer in Charge, Marine Inspection, participated in panels facilitated by the Offshore Operators Committee and Center for Offshore Safety at the 2017 Offshore Technology Conference in Houston. Following is a compilation of his remarks. These remarks are not ‘as delivered’ but provide a condensed version in the ‘panel-conversational’ style.
Good morning. I’d like to thank the Offshore Technology Conference for the opportunity to speak to you today. I’d also like to extend thanks to my fellow panelists.
One of the things I love about my job is the opportunity to collaborate with folks from different backgrounds and perspectives to achieve a common goal. We all share the same goal of safe and secure offshore operations. We all have a role in making that happen.
Since I came into this role two years ago, I’ve always believed that if you share a concern with industry they will bring you a solution on how it should be addressed. A while ago I shared a concern with industry about risk management in the area of well intervention. They essentially came back and said we manage it like we manage other risks, through risk assessments and safety management systems.
I’m a believer in safety management systems. They are flexible and well thought-out. The challenge is to get buy-in at all levels; they should be part of a safety culture. If there’s no safety culture, a safety management system becomes “shelfware” generated by corporate to satisfy a regulation. Regulators can help by expecting safety management systems to be implemented. It helps companies foster buy-in with their employees if the regulators they interface with regularly ask about it and expect it to be followed.
There are three steps to a good safety management system:
1. Step one is to say what you do
2. Step two is to do what you say
3. Step three is to prove it
I think too many of us are stuck at step one. Having a bunch of binders on the shelf that aren’t implemented- what I refer to as a paper tiger- serves no one. I think it’s a good sign when I hear people say they need to reduce paperwork. It’s a sign we’re ready for steps two and three.
The National Academies Report “Strengthening the Safety Culture of the Offshore Oil and Gas Industry” made a key finding about how regulators can contribute to a safety culture. Regulators should move from ensuring compliance, which we typically do by going down a checklist of prescribed regulations, to advocating for a safety culture. We have to understand what a safety culture is and why mere compliance doesn’t get us there.
I believe the regulator can help. Ideally, the regulator should try to maximize its time identifying and restoring safety barriers that have broken down or are missing and minimize its time examining healthy safety barriers. One way to do this is to replace old habits with new habits. Shift from fixed interval inspections scheduled far in advance to variable interval inspections with short notice. Inspections also vary in a simple way- time spent on a prescriptive checklist is replaced with an evaluation of the safety management system related to an uncovered area of non compliance or a casualty.
Casualties and serious deficiencies will be automatic triggers for a regulator to check the safety management system, those related to the top level deficiency as well as another randomly chosen critical system identified in the safety management system. A casualty or serious deficiency is a good indicator safety barriers have broken down; it should take priority over lower priority baseline inspections – checking safety barriers without these indicators. Deep dives into the root causes of casualties gives the regulator a better sense of priority when doing lower priority baseline inspections.
I recently read the term “keystone habit” in a book by the former CEO of Alcoa. The keystone habit suggests that when an ideal, such as safety, is made a top priority by leadership, other positive habits bleed into all aspects of the organization. How does this translate to what we’re talking about today? I believe expanded safety management system inspections cued by casualties and serious deficiencies are a keystone habit that will transform the regulator’s culture from one focused on compliance to one focused on safety culture advocacy. That, coupled with random risk-based inspections, is exactly what we will do.
Earlier this year the Coast Guard and BSEE revised their MOA [memorandum of agreement] to promote consistent oversight of safety and environmental management systems on Outer Continental Shelf facilities and leverage each agency’s authorities and areas of expertise to increase collaboration and information sharing. So, the Coast Guard works through interagency channels to reinforce those barriers when we have an indication they may not be in place. That’s the keystone habit.
We’ve applied the keystone habit quite a bit, even ahead of the MOA. For example, we had to suspend OCS operations 14 times last year. We call this an operational control. We do an initial evaluation of your applicable marine safety barriers under the SEMS framework and hand the results to BSEE. We’ll do the same thing for casualties. The tactics we use are similar to expanded exams under our Port State Control program using the International Safety Management System framework. There’s some good guidance in Navigation and Inspection Circular 04-05 available on line if you’d like more information.
To reiterate, we are not enforcing BSEE’s SEMS. We are performing an evaluation of it in marine areas and sharing our observations with BSEE. We are currently testing a very robust guide to solidify the process for how we refer cases like this to BSEE. We’ve included information BSEE wants to see and they’re looking at how best to do a uniform reach back to the ASP [audit service provider], the operator, or both. We’ve also included how to do a risk assessment to address the types of barriers that are typically present in this environment.
Have questions on this topic? Capt. Reynolds participated in question and answer sessions following his panels and many of his responses can be found in a separate Maritime Commons blog posted here.
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.
Categories: Commercial Vessel Compliance, Offshore, Ports and Facilities, Safety, Uncategorized
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