This responsibility also encompasses the subsea equipment, including the BOP, used as critical control barriers. As part of the proactive risk management system recommended here, BSEE should ensure that drilling contractors are required to obtain an AoC covering their equipment, personnel, and safety management system. The AoC process is used by Norway’s PSA to decide whether the agency has confidence that drilling activities can be carried out by using a particular mobile offshore drilling unit within the framework of the regulations (PSA, 2011b).
Recommendation 6.22: While the operating company is recognized to have the principal responsibility for compliance with rules and regulations governing offshore operations, BSEE should require the partner companies (as co-lease holders) to have a “see to” responsibility to ensure that the operator conducts activities in such a manner that risk is as low as reasonably practicable.
Summary Recommendation 6.23: BSEE and other regulators should undertake efforts to expand significantly the formal education and training of regulatory personnel engaged in offshore drilling roles to support proper implementation of system safety.
Recommendation 6.24: BSEE should exert every effort to recruit, develop, and retain experienced and capable technical experts with critical domain competencies.
This is especially important in the context of the recently enacted SEMS risk management system and the recognition that drilling on the outer continental shelf will grow in complexity. BSEE should strive to increase its technical competencies across the wide spectrum of expertise involved in offshore oil and gas exploration, including areas such as well design, cementing, BOPs, and remotely operated underwater vehicles.
Summary Recommendation 6.25: BSEE and other regulators should foster an effective safety culture through consistent training, adherence to principles of human factors, system safety, and continued measurement through leading indicators.10