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12 Beyond ComplianCe and gas industryâoperators, contractors, and subcontractorsâwill be responsible for developing its own strategies for executing this overall plan. Although the regulators set the minimum requirements for operating offshore, the industry needs to go further to decide which safety guidelines should be made mandatory for participants in offshore oil and gas explora- tion and production. Recommended actions to improve Safety Culture A Vision for Appropriate Regulatory Oversight and a Strategic Plan The offshore industry as a whole needs to develop a vision for appropriate regulatory oversight that delineates the respective roles of operators and regulators, as well as a strategic plan for achieving its safety and environ- mental objectives. The vision should include a description of the regula- tory system that can best enable the accomplishment of these objectives, encourage continuous improvement, and enhance safety culture. His- torically, the industry has opposed many regulatory initiatives designed to enhance safety but has not offered a vision for the type of regulatory system it would support. The regulators also have been inconsistent and unclear regarding their regulatory philosophy and strategy, sometimes issuing highly prescriptive requirements and sometimes supporting a more performance-based approach. The offshore industry needs to demonstrate that it can address fun- damental and long-standing concerns related to managing safety offshore. h elix en eR g y s o lu Tio n s g R o u p
Strengthening the Safety Culture of the Offshore Oil and Gas Industry 13 For example, a technologically advanced industry might be expected to have sophisticated incident data collection and analysis capabilities, which still is not the case in the offshore industry. Other concerns, such as the consistency and rigor of industry standards for safe operating practices, also need to be addressed. The industry needs to develop a strategy for safety leadership. While each company is responsible for its own safety performance, the industry as a whole needs to be committed collec- tively to a culture that provides the best opportunity for a safe working environment. ReCommendaTion: industry leaders should encourage collective and collaborative actions to effect change in an industry as fragmented as the offshore oil and gas industry. Although a fundamental responsibility of the regulators is to imple- ment laws, influencing safety culture in positive ways will require them to Bsee
14 Beyond ComplianCe undertake new and different initiatives. Goals for offshore safety culture shared between the industry and regulators would help define new safety culture activities, such as coaching, sharing of lessons learned, and inde- pendent safety culture assessment. Currently, a considerable imbalance favors traditional compliance activities by regulators over activities intend- ed to help strengthen safety culture, and the existing offshore compliance culture reflects this imbalance. If the offshore oil and gas industry is to go beyond compliance, changes in the regulatorsâ policies will be necessary. The industry sees its regulators collectively as âthe government,â but when introducing safety culture initiatives, regulators will need also to assume the role of participants in the effort to establish and maintain a strong safety culture across the industry. Ideally, the overall role of the regulators is to ensure that the operating companies have systems in place to opti- mize safety performance. ReCommendaTion: The offshore oil and gas industry, in concert with federal regulators, should take steps to define the optimal mix of regulations and voluntary activities needed to foster a strong safety cul- ture throughout the industry. The offshore industry should collaborate on a design for a safety sys- tem for all levels of all organizations in the industry and adopt an evi- noaa (3)
dence-based decision-making process that involves reporting of accurate and complete data, analysis of causes and trends, and sharing of the data across the industry and with the regulators. More important, the industry and the regulators should go beyond ideas and possibilities and develop concrete plans for execution. An Independent Industry Safety Organization In 2011, in the aftermath of the Macondo incident, the offshore industry established the Center for Offshore Safety (COS), an industry-sponsored organization affiliated with API and created to focus exclusively on safety on the U.S. Outer Continental Shelf. The mission of COS is to promote the highest level of safety for offshore drilling, completions, and opera- tions through leadership and effective management systems addressing communication, teamwork, and independent third-party auditing and certification. Initially, COS membership was limited to deepwater operators, with contractors and other service providers (such as consultants and engineer- ing firms) as associate members. In early 2015, COS opened its member- ship to all companies operating on the U.S. Outer Continental Shelf. As of May 2016, COS members included 14 operators, 6 drilling contractors, and 10 service or equipment providers. Strengthening the Safety Culture of the Offshore Oil and Gas Industry 15 n iC o la s R u s s ell/g eTTy
16 Beyond ComplianCe COS could be even more effective in encouraging safety management practices across the industry if its members and associate members rep- resented a larger cross-section of the industry. Barriers preventing other companies from joining COS may include the annual cost of membership or the requirement to undergo regular safety management system audits and make the resulting data available. Moreover, while COS is making important contributions to offshore safety, its affiliation with API, which is known for its public advocacy on behalf of the industry, raises questions about COSâs objectivity. API has safety goals in its charter and has developed many standards used in offshore drilling around the world; yet the public perceives its primary mission as supporting and promoting its membersâ interests, not identify- ing weakness and concerns related to safety. As a result, conflicts can be perceived when advocacy and safety issues diverge. In addition, the public does not always trust the sincerity of such industry associations when they state that safety is their first priority in assessing the performance of their members. If COS were independent of API, it would more likely be recog- nized as a safety leader more broadly. In 2011, the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling commented that to be credible, an oil and RiCk loomis/geTTy