Advancing Understanding of Offshore Oil and Gas Systemic Risk in the U.S. Gulf of Mexico Current State and Safety Reforms Since the Macondo Well–Deepwater Horizon Blowout (2023) / Chapter Skim
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Appendix A: Recommendations from Key Reports
Appendix A: Recommendations from Key Reports
Pages 189-214
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• Chief Counsel, National Commission on the BP Deepwater Hori zon Offshore Oil Spill and Offshore Drilling.
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NATIONAL COMMISSION RECOMMENDATIONS The National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling issued a 400-page report in January 2011 that contains 26 recommendations. These are summarized below, with greater detail provided on ones addressing safety, oil spill responses, and funding for the U.S.
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For new and transferred leases, requiring operators to participate in a new safety institute, or agree to audits, and for leases to require operator assurances of ability to contain and respond to an oil spill and pay compensatory damages; e. Work through the National Academy of Engineering to de velop criteria for high-risk wells and a methodology to assess those risks and develop in-house expertise to perform such risk assessments; f.
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C1. DOI should create a rigorous, transparent, and meaningful oil spill risk analysis and planning process for the development and implementation of better oil spill risk response.
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F3. With regard to financial responsibility from worst-case oil spills, DOI should enhance auditing and evaluation of the risk of offshore drilling activities by operators, drillers, and service companies, and, in collaboration with other entities, engage in oversight to discourage unqualified companies from entering the market for offshore oil and gas exploration.
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GULF OF MEXICO G2. To help ensure adequate funding for safety oversight and environmental review of offshore oil and gas drilling and production on the OCS, Congress should enact a mechanism whereby offshore companies would provide ongoing and regular funding of the agencies regulating offshore oil and gas development.
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c. It is common in the offshore oil industry to focus on increasing efficiency to save rig time and associated costs.
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4. Loss of well control was not noticed for 50 minutes after hydrocarbon flow; the blind shear ram failed to seal the well; and the emergency disconnect of the riser failed to separate the Deepwater Horizon from the well.
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7. The actions, policies, and procedures of the companies involved were inconsistent with a system safety approach and revealed a weak safety culture.
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8. A single federal agency should be designated with responsibility for an integrated system safety approach for offshore safety.
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8. The routine presence of BSEE inspectors on offshore facilities is essential for ensuring compliance with regulations and can provide indicators of SEMS compliance.
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Recommendations 1. BSEE should establish a combination of efforts: compliance inspections, audits, key performance indicators, and a whistleblower program to ensure that SEMS programs are adequate and promote a positive safety culture.
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5. The BSEE audit program should have the following characteristics: operator ownership, audit team independence, auditor training and certification, access to top management and audit reports, a defined audit frequency, and a scheme for audit quality assurance.
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ABS REPORT TO BSEE ON PROCESS SAFETY IMPROVEMENTS, 2015 The assessment commissioned by BSEE revealed opportunities to strengthen the management system approach to preventing major process safety incidents by incorporating additional requirements or guidance within 30 CFR Part 250, Subpart S or within the American Petroleum Institute (API) Recommended Practice (RP)
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SEMS regulations do not require a MODU owner or contractor to develop a SEMS program because that responsibility resides with the leaseholder. It is recommended that BSEE consider referencing IADC guidance for drilling contractors.
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• No effective testing or monitoring of the redundant systems for BOP emergency shutdown switch existed on the Deepwater Horizon. • Size of the drill pipe used on the Deepwater Horizon on almost all days exceeded the BOP blind shear ram design capability.
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The rules: 0 specify activities but not setting of specific goals and risk reduc tion steps to reach them; 0 require causal assessments of incidents but focus on immediate causes rather than safety management system or organizational factors; and 0 do not require that corrective action plans reduce risk to ALARP. • Offshore regulations do not require operators or drilling contrac tors to 0 implement barriers and management systems to reduce risk to ALARP; 0 document efforts to effectively control hazards or demonstrate use of best practice in process safety;
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• API's RP 75 [as of 2016] , which the SEMS rule incorporates by reference, lacks sufficient guidance on 0 human factors requirements for avoiding major accidents and investigation of accidents and near misses; 0 incorporation of hierarchy of control principle for identify ing, establishing, and implementing barriers to avoid major accidents; 0 roles of corporate governance and boards of directors in major accident risk management; 0 workforce involvement and engagement in all aspects of SEMS; 0 leading and lagging indicators of process safety; 0 expanded and defined roles for managing against major ac cident risks between operators and contractors and ones best capable of SEMS implementation and oversight; and 0 incorporation of reducing risk to ALARP in all elements of SEMS.
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by all responsible parties, including contractors, to reduce risk to ALARP level, including, at a minimum, identification, monitoring, documentation, independent verification, corrective action plans, and development of process safety indicators for SCEs.
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11. DOI should revise its offshore safety regulations, including SEMS, to establish a framework with a specific goal of reducing risk of major accidents to ALARP level.
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14. DOI should improve its regulatory reporting program to drive continual improvement by industry through a program that collects, tracks, and analyzes safety performance indicators and • Requires responsible parties to report safety indicator data; • Emphasizes process safety leading indicators for prevention of major accidents; • Uses incident data to identify safety-specific trends, set performance goals, communicate to the public those trends, and allocate BSEE resources accordingly; and • Uses lagging indicators in decision-making processes for leasing and permits to drill.
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GULF OF MEXICO TRB SPECIAL REPORT 321 ON OFFSHORE INDUSTRY SAFETY CULTURE, NASEM (2016) This report provides a framework for understanding and strengthening the safety culture of the offshore oil and gas industry.
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14. The Secretary of DOI and the Commandant of the Coast Guard should seek prominent leaders of the offshore industry to champion the nine characteristics of safety culture in BSEE's definition and facilitate information exchange and experience in strengthening safety culture.
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GULF OF MEXICO TRB SPECIAL REPORT 338 ON BSEE INSPECTIONS PROGRAM, NASEM (2021) Findings 1.
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BSEE should collaborate with industry on the expertise and management processes that will be required to pilot and then implement new strategies that make effective use of technological advancements. Consideration should be given to how the BAST process can be used to encourage the development and introduction of technologies that can improve offshore oil and gas safety and environmental management and performance while also providing BSEE with the capabilities needed to fulfill its safety oversight and inspection functions.
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214 OFFSHORE OIL AND GAS SYSTEMIC RISK IN THE U.S. GULF OF MEXICO change -- such as the judicious use of third-party inspections to augment its program, the use of technology to supplement and substitute for some onsite inspections, and the creative makeup and deployments of ad hoc inspector teams.
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