Captain Joshua Reynolds with the Outer Continental Shelf Officer in Charge, Marine Inspection had the opportunity to provide remarks during the June 2017 General Meeting of the Offshore Operators Committee at Anadarko Petroleum, The Woodlands, Texas.
In his remarks to attendees, Reynolds discussed several examples of how interfacing with the Offshore Operators Committee (OOC) has benefited industry and the Coast Guard and the Bureau of Safety and Environmental Enforcement (BSEE).
He referenced the industry-led Well Intervention Risk Analysis, which was showcased at the Offshore Technology Conference in May. The purpose of the analysis was to raise awareness and increase overall industry understanding of risks associated with well intervention activities. Reynolds cited a dynamic positioning incident from 2015 involving an Offshore Supply Vessel that resulted in a loss of position while conducting a critical Outer Continental Shelf activity.
“I thank all the volunteers who put their time and energy to completing this and we promise to put it to good use,” said Reynolds. “We will review the risk analysis and incorporate its findings into the Coast Guard’s interim risk based inspection approach.”
Reynolds said a second area of OOC interface that benefitted both the regulator and its members was its engagement on means of escape for fixed platforms.
Reynolds said OOC expressed a concern about inconsistent application of compliance with Coast Guard means of escape regulations, which are part of the scope of inspection for platform spot checks by either the Coast Guard, or BSEE on the Coast Guard’s behalf, or both. OOC, the Coast Guard, and BSEE worked together to develop guidance; the guidance was referenced in D8 OCS Policy Letter 01-2017: Means of Escape on Fixed Platforms, signed in May.
Third, Reynolds discussed OOC’s engagement on the issue of oil field waste service. It’s a critical service the oil industry relies upon to operate and interruptions are a major concern. Long standing policy (NVIC 7-84) permits oil field waste to be transported in open hopper barges in lieu of tank barges, subject to certain operational restrictions outlined on the barge’s Certificate of Inspection.
“When the Coast Guard discovered that these operational restrictions were not being adhered to or compliance was difficult to determine, we worked with the service providers to reach an interim solution to provide the intended level of environmental protection so service could continue,” Reynolds said. He added that the Coast Guard plans to update the policy and provide better clarity on the expectations and uniform application across the Marine Inspection zones.
Reynolds reminded attendees that BSEE is the primary contact for offshore operators to report evacuations/shut-ins during hurricane season, which began June 1st. He also encouraged offshore operators to review their evacuation plans and run a table top hurricane exercise to test emergency plans to help the crew maintain vigilance.
“It’s been a little while since we’ve had a major storm in the gulf,” Reynolds said. “I recommend you compare your shut in times against a historical storm in your area, to validate roles both on the facility and at the shore. I’ll ask [inspectors] to emphasize this in upcoming inspections.”
Reynolds also discussed concerns regarding rates of attrition seen in the professional maritime workforce and the need to recruit and train a new generation of mariners to work on OSVs, facilities, and MODUs. Reynolds noted, “We know we have a generational exodus from the offshore oil and gas industries – folks of retirement age are opting out. We know not enough younger folks are coming to replace them.”
Reynolds stressed the importance of incorporating cyber risk management into safety management systems, and then exercising emergency plans. He noted that the Gulf of Mexico Area Maritime Security Committee is working through final logistics planning for its annual cyber themed table top exercise scheduled for Aug. 8th at BSEE’s regional office.
Finally, Reynolds highlighted updates to several Coast Guard/BSEE memorandums of agreements the past year, in an effort to provide consistent and seamless approach by both agencies. In particular, Reynolds discussed MOA OCS-07 on safety management systems and internal protocols developed for the Coast Guard to assist BSEE with SEMS oversight involving marine systems, operations, and training. The first ever joint report was published last month, outlining interagency activity and data sharing.
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.
