TRANSPORTATION RESEARCH BOARD
SPECIAL REPORT 338
Modernizing the U.S. Offshore Oil
and Gas Inspection Program for
Increased Agility and Safety Vigilance
Committee for a Review and Update of the Bureau of Safety
and Environmental Enforcement Offshore Oil and
Gas Operations Inspection Program
A Consensus Study Report of
THE NATIONAL ACADEMIES PRESS
Transportation Research Board Special Report 338
Subscriber Categories: Marine transportation; policy
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Copyright 2021 by the National Academy of Sciences. All rights reserved.
Printed in the United States of America
This publication was reviewed by a group other than the authors according to the procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the National Academy of Medicine.
This study was sponsored by the Bureau of Safety and Environmental Enforcement, U.S. Department of the Interior.
International Standard Book Number-13: 978-0-309-37465-1
International Standard Book Number-10: 0-309-37465-0
Digital Object Identifier: https://doi.org/10.17226/26095
Library of Congress Control Number: 2021938598
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COMMITTEE FOR A REVIEW AND UPDATE OF THE BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT OFFSHORE OIL AND GAS OPERATIONS INSPECTION PROGRAM
Gregory S. Parnell, University of Arkansas, Fayetteville, Chair
Lori S. Bennear, Duke University, Durham, North Carolina
Claudine S. Bradley, Canada Energy Regulator, Calgary, Alberta
Paul G. Bradley, Health and Safety Executive, United Kingdom
Cary Coglianese, University of Pennsylvania Carey Law School, Philadelphia
James S. Dyer, The University of Texas at Austin
Lois N. Epstein, The Wilderness Society, Anchorage, Alaska
RADM Thomas H. Gilmour (U.S. Coast Guard retired), Independent Consultant, Eugene, Oregon
Richard A. Sears, Stanford University, Stanford, California
Robert Sheppard, Spire Engineering Services LLC, Houston, Texas
Manuel Terranova, Peaxy, Inc., San Jose, California
James M. Tien (NAE), University of Miami, Coral Gables, Florida
Peter K. Velez, Peter Velez Engineering, LLC, Houston, Texas
Transportation Research Board Staff
Mark S. Hutchins, Study Director, Consensus and Advisory Studies
Thomas R. Menzies, Jr., Director, Consensus and Advisory Studies
Micah D. Himmel, Senior Program Officer, Consensus and Advisory Studies
Claudia Sauls, Program Coordinator, Consensus and Advisory Studies
Anusha Jayasinghe, Associate Program Officer, Consensus and Advisory Studies
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In May 2017, the Bureau of Safety and Environmental Enforcement (BSEE) requested that the National Academies of Sciences, Engineering, and Medicine (the National Academies), through the Transportation Research Board’s Marine Board, review and advise on the agency’s offshore oil and gas inspection program in the context of the agency’s other related programs and activities and overall mission to promote offshore safety and environmental protection. To conduct the study, the National Academies appointed a committee of 13 experts in the fields of safety regulation and enforcement in high-hazard industries; regulation studies; offshore oil and gas operations and technology; safety management; and risk analysis and management. Committee members served uncompensated and in the public interest. Their biographical information is provided in the Appendix.
The committee held its first meeting in October 2017. In December 2017, BSEE suspended the committee’s work while implementing a revised risk-based inspection program in the Gulf of Mexico (GOM) region. When the study resumed in October 2018, BSEE asked the committee to provide guidance on the risk-based inspection program as part of its review. The full study charge is provided and discussed in Chapter 1.
The committee met six times from December 2018 to March 2020 to gather information relevant to the study and to deliberate on findings and recommendations. The public meetings included multiple briefings from BSEE officials; officials from other government agencies responsible for regulating and overseeing the safety of high-hazard industries; representatives from the oil and gas industry; industry experts on offshore safety management and regulatory compliance; experts on third-party inspections
and auditing; and researchers on safety and environmental regulation and inspection program design and implementation. The committee visited BSEE’s GOM region, where it met with leaders of BSEE’s inspection and safety management programs and visited a state-of-the-art operator control center and safety training facility. These briefings, meetings, and field visits were invaluable to informing this report, which represents the consensus effort of the committee.
The study committee thanks the many individuals and organizations who contributed to its work. From BSEE, the committee was briefed by Lars Herbst, Region Director for GOM; Troy Trosclair, Deputy Regional Supervisor, GOM District Field Operations; Tim McGraw, Senior Inspection Operations Coordinator, GOM Region; James Richard, Well Operations Inspections Coordinator, GOM Region; Theresa Bell, Regional Supervisor, Office of Strategic Operations, Pacific Region; Michael Jordan, Office of Field Operations, Alaska Region; Jason Mathews, Chief, Office of Safety Management; Greg Schneider, Office of Safety Management; Stanislaus Kaczmarek, Chief, Safety and Environmental Management Systems Section; Doug Morris, Chief (retired), Office of Offshore Regulatory Programs; and Susan Dwarnick, Chief, Offshore Safety Improvement Branch. McGraw, Bell, Jordan, and Richard also served as BSEE’s main liaisons to the study committee.
From other federal safety regulatory agencies, the committee was briefed by the Pipeline and Hazardous Materials Safety Administration’s Linda Daugherty, Deputy Associate Administrator for Field Operations, and the U.S. Coast Guard’s Jeffrey G. Lantz, Director, Commercial Regulations and Standards; CAPT Matt Edwards, Chief, Office of Commercial Vessel Compliance; and CAPT Russell E. Holmes (retired), Officer in Charge, Marine Inspections 8th District.
From the offshore oil and gas industry, the committee was briefed by David Dykes, Chevron; Holly Hopkins, American Petroleum Institute; Greg Southworth, Offshore Operators Committee; Brent Ozenne and Jesse McGraw, Arena Offshore; Eric Hebert, Anadarko; Corey Lege, Talos Energy; Joel Plauche, Fieldwood Energy; and Michael Fairburn, Danyelle Kennedy, Barry Gaston, Paul Mendel, and Clark Yates, Shell.
From third-party auditing, inspection, and accreditation and certification organizations, the committee was briefed by Charlie Williams and Curtis Johnson, Center for Offshore Safety; Ken Richardson, EVP Global Offshore; Luiz Feijo and Gigi Bear, American Bureau of Shipping; Dan Phelps, Offshore Technical Compliance; Allison King, SEMP Check; and Phil Bernard, Compliance Technology Group.
From academia, research institutions, consultancies, and offshore safety and conservation organizations, the committee was briefed by Michael W. Toffel, Harvard Business School; Wayne B. Gray, Clark University; Mark Cohen, Vanderbilt University; Richard Berk, University of Pennsylvania; Douglas Hubbard, Hubbard Decision Research; Elmer “Bud” Danenberger, Independent Consultant; and Sarah Giltz, Oceana.
Mark S. Hutchins managed the study and assisted the committee in the preparation of its report under the guidance of Thomas R. Menzies, Jr., Director, Consensus and Advisory Studies. Micah D. Himmel, Senior Program Officer; Claudia Sauls, Program Coordinator; and Anusha Jayasinghe, Associate Program Officer, provided extensive support to the committee in collecting and analyzing data, arranging meetings, and managing documents. Karen Febey, Senior Report Review Officer, managed the report review process.
This Consensus Study Report was reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise. The purpose of this independent review is to provide candid and critical comments that will assist the National Academies in making each published report as sound as possible and to ensure that it meets the institutional standards for quality, objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process.
The committee thanks the following individuals for their review of this report: James C. Card, U.S. Coast Guard (retired); Christopher Carrigan, The George Washington University; Elmer “Bud” Danenberger, Independent Consultant; Paul S. Fischbeck, Carnegie Mellon University; Kenneth Keegstra (NAS), Michigan State University; Camille Peres, Texas A&M University; Lincoln Stroh, J. Connor Consulting, Inc.; Theofanis G. Theofanous (NAE), University of California, Santa Barbara; and Charlie Williams, Consultant.
Although the reviewers listed above provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations of this report, nor did they see the final draft before its release. The review of this report was overseen by the review monitor, M. Elisabeth Paté-Cornell (NAE), Stanford University, and the review coordinator, Chris Hendrickson (NAE), Carnegie Mellon University. They were responsible for making certain that an independent examination of this report was carried out in accordance with the standards of the National Academies and that all review comments were carefully considered. Responsibility for the final content rests entirely with the authoring committee and the National Academies.
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|ABS||American Bureau of Shipping|
|ACP||Alternate Compliance Program|
|ANL||Argonne National Laboratory|
|AOC||acknowledgment of compliance|
|API||American Petroleum Institute|
|ASP||audit service provider|
|BAH||Booz Allen Hamilton|
|BAST||Best Available and Safest Technology|
|BID||Bureau Interim Directive|
|BOEM||Bureau of Ocean Energy Management|
|BOEMRE||Bureau of Ocean Energy Management, Regulation, and Enforcement|
|BSEE||Bureau of Safety and Environmental Enforcement|
|CAP||corrective action plan|
|CER||Canada Energy Regulator|
|CFR||Code of Federal Regulations|
|C-NLOPB||Canada-Newfoundland & Labrador Offshore Petroleum Board|
|CNSOPB||Canada-Nova Scotia Offshore Petroleum Board|
|COS||Center for Offshore Safety|
|DART||days away, restricted, and transfer|
|DNV-GL||Det Norske Veritas–Germanischer Lloyd|
|DWOP||Deepwater Operations Plan|
|EEZ||Exclusive Economic Zone|
|FBRI||Facility-Based Risk Inspection|
|FOGRMA||Federal Oil and Gas Royalty Management Act|
|GAO||U.S. Government Accountability Office|
|GOM||Gulf of Mexico|
|HWCG||Helix Well Containment Group|
|IAEA||International Atomic Energy Agency|
|IMO||International Maritime Organization|
|INC||Incident of Noncompliance|
|IOL||increased oversight list|
|IPD||Interim Policy Document|
|ISM||International Safety Management|
|ISO||International Organization for Standardization|
|JSA||Job Safety Analysis|
|KPI||key performance indicator|
|MBI||Marine Board of Investigation|
|MMS||Minerals Management Service|
|MOA||memorandum of agreement|
|MODU||mobile offshore drilling unit|
|MWCC||Marine Well Containment Company|
|NAE||National Academy of Engineering|
|NASA||National Aeronautics and Space Administration|
|NRC||National Research Council|
|NTL||Notice to Lessees|
|NVIC||Navigation and Vessel Inspection Circular|
|OCS||Outer Continental Shelf|
|OCSLA||Outer Continental Shelf Lands Act|
|OSM||Office of Safety Management|
|PBRI||Performance-Based Risk Inspection|
|PHMSA||Pipeline and Hazardous Materials Safety Administration|
|PINC||Potential Incident of Noncompliance|
|PSA||Petroleum Safety Authority (Norway)|
|RAC||Risk Analysis Committee|
|RRTM||remote real-time monitoring|
|SEMS||Safety and Environmental Management Systems|
|SMS||safety management system|
|SPEAR||Safety Performance Enhanced by Analytical Review|
|UK HSE||United Kingdom Health and Safety Executive|
|USCG||U.S. Coast Guard|
|USDOI||U.S. Department of the Interior|
|USEPA||U.S. Environmental Protection Agency|
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