Modernizing the U.S. Offshore Oil and Gas Inspection Program for Increased Agility and Safety Vigilance (2021) / Chapter Skim
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5 Summary Assessment: Findings and Recommendations
5 Summary Assessment: Findings and Recommendations
Pages 131-150
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From page 131... ...
to convene an expert committee to advise on ways that the agency could augment and improve its offshore oil and gas inspection program. Given the expectation that it inspect each offshore facility at least once per year, BSEE faces many challenges as it seeks to fulfill its stated mission "to promote safety, protect the environment, and conserve resources through vigorous regulatory oversight."1 The challenges include keeping up with rapidly advancing offshore exploration and production technologies, the growing number of more varied and complex facilities operating on the seafloor and in deeper water, and an aging population of legacy platforms operating in shallow water.
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From page 132... ...
The emphasis placed on inspecting all offshore facilities also limits BSEE's ability to focus on enhancing safety outcomes through more thorough and targeted inspections of activities and facilities that are identified as presenting a higher risk of workplace safety incidents and events having severe safety and environmental consequences. BSEE's Gulf of Mexico (GOM)
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From page 133... ...
Ideally, however, those inputs and outputs will have a close and identifiable connection to the outcomes of interest, such as by targeting inspections to activities, components, and facilities for which there is a sound basis for ascribing higher potential for incidents and severe incident consequences. In this respect, the RBI program represents an important step for BSEE in migrating its inspection program away from the traditional emphasis on meeting an annual inspection quota that results in many inspections of relatively low-risk facilities (and thus having limited impact in reducing incidents and their severity)
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From page 134... ...
BSEE may want to consider whether a single "one-size-fits-all" model is desirable and whether it might be replaced or supplemented by separate models that focus on the potential for workplace safety and health incidents and the potential for catastrophic safety environmental events. While poor facility or operator performance that leads to workplace health and safety incidents may be correlated with a higher likelihood of catastrophic events, one would expect that the magnitude and types of risks associated with the newer, larger, and more complex deepwater facilities would be modeled differently than those associated with smaller but often older and more lightly manned platforms operating in shallow water.
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From page 135... ...
OPPORTUNITIES TO BE MORE DATA-INFORMED Finding 2: Although BSEE has taken steps to become more data-informed in the deployment of inspection resources, such as through its Risk-Based Inspection programs, considerable opportunity remains for the agency to improve the consistency, timeliness, and completeness of its INC records, incident reports, and other databases (possibly to include data gleaned from SEMS audits) to make them more useful for internal decision making and external reviews that can improve the efficiency and effectiveness of the traditional inspection and SEMS oversight programs.
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From page 136... ...
to perform analyses. Because offshore oil and gas safety can be controversial, such data transparency is important for this reason alone, but it will also allow external parties -- whether offshore operators, academic researchers, or advocacy groups -- to use the data in different ways by applying alternative viewpoints and analytic skills that can result in analyses and conclusions that may otherwise have been missed.
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From page 137... ...
How, if at all, should BSEE employ its regular inspection workforce to verify that operators are complying with SEMS requirements and following their own SEMS programs is a question that BSEE struggles with. BSEE's inspectors lack familiarity with each operator's customized management system and they lack training and certification as safety management system auditors.
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From page 138... ...
The committee was informed, however, that BSEE inspectors are given a short set of questions asking them for post-inspection observations about aspects of a facility's safety management process, apparently as a means of gauging the operator's SEMS implementation and its safety culture. While the questions, which were shown in Box 3-4, could potentially yield some useful insights for follow-up activity, their subjective and cursory nature seem to be more indicative of a lack of confidence by BSEE that traditional inspections can play a meaningful role in assessing the implementation of a SEMS program and its impact.
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From page 139... ...
To augment its role in providing external verification and oversight of regulatory compliance, BSEE might consider how it can help operators find ways to assess and strengthen their organizational safety culture. For example, a 2016 study of inspectors, investigators, and auditors from the oil and gas industry in Canada and the United States (including BSEE)
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From page 140... ...
. The group emphasized, however, that assessment tools should not be incorporated into regulatory compliance verification and enforcement BOX 5-1 North American Working Group on Safety Culture: Attributes Indicative of Organizational Safety Culture Committed Safety Leadership • Direct participation of leaders in the safety system • Leader inquiry, knowledge, and understanding of threats • Leaders taking action to address hazards and deficiencies in the system • Leaders valuing safety efforts and expertise Vigilance • Knowing what is going on through a proactive surveillance process • Understanding safety information through analysis and interpretation • Everyone proactively reporting errors, near-misses, and incidents • Sharing information and interpretation to create collective understand ing of status of safety and anticipated future challenges • Taking action on learning Empowerment and Accountability • Employee participation in safety management activities • Organization-wide safety ownership and communication • Willingness to do what is right regarding safety • Breaking down of organizational silos Resiliency • Recognizing the introduction of new or changing threats in the operat ing environment • Ensuring that employees (at all levels)
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From page 141... ...
Recommendation 3: BSEE should take purposeful steps to reposition and reshape its inspection and SEMS audit and oversight programs so that they learn from one another and work in concert to improve regulatory compliance; strengthen safety management planning, execution, and effectiveness; and exhort, support, and sustain the conscious efforts of operators to build and maintain a strong safety culture. Although BSEE has taken initiatives to improve both its inspection and SEMS audit programs, they continue to function along separate tracks, each aimed at improving safety in its own way but with limited regard for how they can communicate, collaborate, and inform one another to support continual improvement, including the fostering of strong organizational safety cultures.
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From page 142... ...
and an operator on the Norway's continental shelf conducted a pilot program where DNV-GL's onshore personnel remotely inspect the operator's offshore cranes.5 Onshore control centers and remote real-time monitoring (RRTM) facilities offer the opportunity for more inspection activity to be performed without traveling to the platform.
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From page 143... ...
The development of digital twins, combined with robust real-time data required to implement CBM and remote monitoring, will offer more opportunities for using advanced analytics to evaluate physical asset properties and responses to operating conditions. Here too, it will be important for BSEE inspectors to have familiarity with these data analytics and advanced technologies because they will be used increasingly to inform operator decisions about equipment maintenance, replacement, and availability.
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From page 144... ...
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 Best Available and Safest Technology process can used to be 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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From page 145... ...
Recommendation 5: To make adaptability a fundamental characteristic of its safety assurance approach, BSEE should give priority to increasing its organizational agility, the absence of which has become an impediment to keeping pace with the fast-evolving offshore oil and gas industry. This impediment is likely to become even more problematic as the industry's technological sophistication and capabilities, operating methods, and scale and location of drilling and production activity change.
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From page 146... ...
MAPPING FINDINGS AND RECOMMENDATIONS TO THE THEMES IN THE STUDY CHARGE Theme 1: Is BSEE's inspection program effectively meeting its regulatory mission? The committee recognizes that BSEE defines its central mission as being "to promote safety, protect the environment, and conserve resources through vigorous regulatory oversight." The committee encourages BSEE to take a broader view of what constitutes regulatory oversight consistent with its mission to "promote" safety and environmental protection.
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From page 147... ...
In accordance with the recommendations in this report, BSEE should reposition and reshape its inspection and SEMS audit programs so that they are sufficiently coordinated and complementary to help exhort, support, and sustain the conscious efforts of operators to improve their safety management systems and develop and maintain a strong organizational safety culture. The committee acknowledges that fully integrating the two programs would be challenging for BSEE because it would require significant changes to its inspection methods and workforce, at least in the short term.
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From page 148... ...
Although few BSEE inspectors may be qualified to review SEMS plans and their implementation, more communication, collaboration, and cooperation between the inspection and SEMS audit programs can inform the former's continual improvement by understanding how operators respond to audit findings. Theme 5: What is the appropriate role of real-time monitoring and other safety-enhancing technologies for the BSEE inspection program?
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From page 149... ...
To recap, the committee believes that BSEE should evolve its inspection program to make it more outcome-oriented, with a particular focus on ensuring that inspections are informed by a continually improved and refined capacity to target higher-risk facilities and activities and by making investments in more advanced and creative data collection, analytic, and management capabilities. Furthermore, BSEE should articulate a vision for how and where to leverage advances in offshore technology to meet the demands of the inspection and SEMS programs, including making more effective use of the BAST process to encourage the development and introduction of technologies that can improve offshore oil and gas safety and environmental management and performance.
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From page 150... ...
2016. Special Report 322: Application of Remote Real-Time Monitoring to Offshore Oil and Gas Operations.
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