standardized and then incorporated or referenced by government regulations. In its recent regulations, MMS had referenced about 80 of the approximately 240 standards developed by API that are related to exploration and development.48 It is not apparent to the committee that MMS had sufficient in-house expertise and technical capabilities to independently evaluate the adequacy of the technological standards and practices that industry developed for deepwater drilling.


Furthermore, MMS standards and regulations are often developed through a multiyear consensus process in response to past events or trends. MMS had been working for at least 9 years on a draft regulation concerning secondary control systems for BOP stacks used in deepwater drilling operations.49 Reliance on a retrospective approach to standards development necessarily lags behind the rapid development of new technologies for deepwater drilling. The committee will be looking with interest at new standards and regulations being developed for deepwater exploration and will assess their potential for promoting the use of the safest available technologies and practices.

Independent Review of Critical Safety Equipment and Well Completion Steps

Some components that are critical to the safety of oil drilling operations are not required to be independently certified by a third party (such as a classification society) or by the relevant regulatory agency. MMS did not directly oversee the initial and subsequent certifications of BOPs. Instead, the operator was to self-certify the BOP.50 Also, MMS was not directly involved in overseeing critical steps in the well completion process. For example, little guidance was provided for conducting and interpreting negative-pressure tests of well integrity. The committee will consider approaches for ensuring that independent review is provided for critical equipment and practices associated with deepwater exploration.

VIII.
COMPLETING THE COMMITTEE’S STUDY

In carrying out the remainder of its study, the committee will continue to gather information (via site visits, invited presentations, and requests for documents and data) to address issues discussed in this report as well as other issues relevant to its scope of work. The committee will track the forensic analysis of the recovered BOP and other analyses being carried out for MBI. The committee will examine the new regulations and other initiatives (of governmental and private organizations) being developed for deepwater exploration in the U.S. Outer Continental Shelf Region. In addition, the

48

U.S. Department of the Interior Outer Continental Shelf Safety Oversight Board Report to Secretary of the Interior Ken Salazar. September 1, 2010. http://www.doi.gov/news/pressreleases/loader.cfm?csModule=security/getfile&PageID=43677.

49

MBI hearing, May 12, 2010, testimony of Michael Saucier, Regional Supervisor for Field Operations in the Gulf of Mexico Region, MMS.

50

MBI hearing, May 12, 2010, testimony of Michael Saucier, Regional Supervisor for Field Operations in the Gulf of Mexico Region, MMS.



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