Modernizing the U.S. Offshore Oil and Gas Inspection Program for Increased Agility and Safety Vigilance (2021) / Chapter Skim
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to convene an expert committee to evaluate its offshore oil and gas inspection program and to advise on ways that the program could be improved and augmented. Given the expectation, based on interpretations of the Outer Continental Shelf Lands Act, that inspections are to be conducted on 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 and changing exploration and production technologies, the growing number of more varied, complex, and difficult to access facilities operating in deeper water and on the seafloor, and an aging population of legacy platforms mostly operating in shallow water.
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In reflecting on themes and questions in the study charge, and after discussions with BSEE following briefings on its strategic plans and initiatives, the committee came to view the subject matter of the questions as being indicative of BSEE's ambitions, or "aspirational goals," for its inspection program. In particular, the committee perceived an interest by BSEE in obtaining insight and advice for making its inspection program more • Outcome-oriented by focusing more directly and proactively on reducing the occurrence and severity of incidents and recognizing that measures of total inspections and compliance with individual regulations may not be indicative of mission progress; • Data-informed by marshaling and leveraging information obtained from SEMS audits, incident and near-miss reports, remote monitor ing data, equipment failure reports, inspection results, and other data sources to guide outcome-oriented inspection policies, pro grams, and procedures and measure their effectiveness in reducing incidents and their severity; • Holistic in the treatment of risk by considering the varied causes and contributors to incidents and the system-level means that can be employed for reducing them, including the consideration of environmental, technology, organizational, process, and human behavior–related risk factors; • Discerning of the opportunities and challenges associated with new technologies, such as by being attuned to the promise of new tech nological capabilities for improved decision support and inspection functions, but clear-eyed about their potential limitations; and • Adaptable to a changing offshore landscape by recognizing that the nature of risks and means for reducing risks are changing as the
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The committee recognizes that the Bureau of Safety and Environmental Enforce ment (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 environ mental protection.
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In accordance with the recommendations in this report, BSEE should reposition and reshape its inspection and SEMS audit programs so that they are suf ficiently 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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This report recommends that BSEE make adaptability a fundamental character istic of its safety assurance approach and be open to alternative methods for keeping pace with the fast-evolving offshore oil and gas industry. This adapt ability could very well include the judicious use of third-party inspections to aug ment its current program, which are not unusual to government inspection and verification regimes, and indeed are a central feature of the vessel inspection programs of the U.S.
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The longer-term, and potentially more demanding, challenge for BSEE will be in repositioning and reshaping the inspection and SEMS oversight programs so that they work more in concert with one another to improve regulatory compli ance, strengthen safety management, and support strong safety culture in the offshore industry. OUTCOME-ORIENTED Finding 1: To meet the expectation that every offshore facility be inspected at least once annually, BSEE inspectors are scheduled to visit approximately 1,700 to 1,800 facilities per year.
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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 program, considerable opportunity remains for the agency to improve the consistency, timeliness, and completeness of its Incident of Noncompliance records, incident reports, and other databases (possibly to include data gleaned from SEMS audits) to make them more useful for internal and external reviews that can improve the efficiency and effectiveness of traditional inspections and SEMS oversight functions.
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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 their 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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Consideration should be given to how the Best Available and Safest Technology 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. ADAPTABLE Finding 5: BSEE has undertaken many initiatives over the past decade to improve the effectiveness and efficiency of its inspection program; however, the fast-changing offshore energy operational landscape is making it increasingly important for BSEE to make adaptability a principal trait of its operations as well as its organizational structure and culture.
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Department of the Interior found that BSEE successfully implemented measures to protect its workforce from the transmission of the virus while also being able to fulfill its annual inspection plan, which included inspectors remotely witnessing operator blowout preventer tests.2 BSEE's agility in the face of the COVID-19 pandemic -- also observed at other times, such as in the aftermath of hurricanes -- is emblematic of the agency's adaptive capability, while also being indicative of the importance of the agency having this capacity. This study's charge was framed in terms of BSEE's aspirational goals for its inspection program, which are fundamentally about ensuring that the program is able to keep pace with, and indeed become more anticipatory of, changing circumstances and conditions.
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