the act was passed. The following are among the key definitions and assumptions made by the committee:


•   “Safest” technology is interpreted as technology that can reduce the risks to workers, the public, and the environment to a point that is consistent with the principle of ALARP (as low as reasonably practicable).8

•   In this context, the committee took a total system perspective on safety, encompassing occupational safety, process safety, and the safety of supporting elements such as marine systems, in recognition that emphasis should be afforded to aspects of offshore operations that are unique to the industry.

•   Noting that the majority of the lives lost in the offshore industry were not due to process safety failures,9 the committee interpreted “technology” broadly. In the committee’s view, the term encompasses not only equipment directly involved in drilling and operating wells but also support systems (e.g., marine systems), safety systems (e.g., explosive gas detectors and blind shear rams), control and display systems (e.g., real-time operations centers), and the human factors considerations that are often central to the causes of major disasters such as the Macondo well blowout.10 The safe functioning of offshore operations depends on the culture of the organizations involved, which includes interactions among human, organizational, and technological components.

•   Practicability is interpreted as encompassing the concepts of technology availability and economic feasibility.


OCSLA recognizes the importance of economic factors but fails to give any guidelines for cost–benefit determinations. OCSLA simply states that the Secretary of the Interior shall require the use of BAST “except where the Secretary determines that the incremental benefits are clearly insufficient to justify the incremental costs of utilizing such technologies.”11 In Chapter 3 the committee discusses the considerations to be included in such cost determinations: the expenses associated with both the acquisition and the sustainment (operations and maintenance) of candidate technologies and potential disruptions to drilling operations caused by the introduction of new technologies that can have significant cost implications.

The challenge of implementing BAST is further complicated by the diversity of drilling and production operations within BSEE’s purview. The diversity of operations includes deepwater exploration and development as well as the


8The ALARP principle is becoming generally recognized worldwide. See, for example, Accessed September 25, 2013.

9; Accessed September 25, 2013.

10 Accessed September 25, 2013.

11OCSLA Section 21(b).

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