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PREPUBLICATION COPYâUncorrected Proofs TRANSPORTATION RESEARCH BOARD SPECIAL REPORT 338 Modernizing the U.S. Offshore Oil and Gas Inspection Program for Increased Agility and Safety Vigilance Committee for a Review and Update of the Bureau of Safety and Environmental Enforcement Offshore Oil and Gas Operations Inspection Program A Consensus Study Report of
PREPUBLICATION COPYâUncorrected Proofs Transportation Research Board Special Report 338 Subscriber Categories: Marine transportation; policy Transportation Research Board publications are available by ordering individual publications directly from the TRB Business Office, through the Internet at www.TRB.org or nationalacademies.org/trb, or by annual subscription through organizational or individual affiliation with TRB. Affiliates and library subscribers are eligible for substantial discounts. For further information, contact the Transportation Research Board Business Office, 500 Fifth Street, NW, Washington, DC 20001 (telephone 202-334-3213; fax 202-334-2519; or e-mail TRBsales@nas.edu). Copyright 2021 by the National Academy of Sciences. All rights reserved. Printed in the United States of America This publication was reviewed by a group other than the authors according to the procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the National Academy of Medicine. This study was sponsored by the Bureau of Safety and Environmental Enforcement, U.S. Department of the Interior. International Standard Book Number-13: International Standard Book Number-10: Digital Object Identifier: Library of Congress Control Number:
PREPUBLICATION COPYâUncorrected Proofs The National Academy of Sciences was established in 1863 by an Act of Congress, signed by President Lincoln, as a private, nongovernmental institution to advise the nation on issues related to science and technology. Members are elected by their peers for outstanding contributions to research. Dr. Marcia McNutt is president. The National Academy of Engineering was established in 1964 under the charter of the National Academy of Sciences to bring the practices of engineering to advising the nation. Members are elected by their peers for extraordinary contributions to engineering. Dr. John L. Anderson is president. The National Academy of Medicine (formerly the Institute of Medicine) was established in 1970 under the charter of the National Academy of Sciences to advise the nation on medical and health issues. Members are elected by their peers for distinguished contributions to medicine and health. Dr. Victor J. Dzau is president. The three Academies work together as the National Academies of Sciences, Engineering, and Medicine to provide independent, objective analysis and advice to the nation and conduct other activities to solve complex problems and inform public policy decisions. The National Academies also encourage education and research, recognize outstanding contributions to knowledge, and increase public understanding in matters of science, engineering, and medicine. Learn more about the National Academies of Sciences, Engineering, and Medicine at www.nationalacademies.org. The Transportation Research Board is one of seven major programs of the National Academies of Sciences, Engineering, and Medicine. The mission of the Transportation Research Board is to provide leadership in transportation improvements and innovation through trusted, timely, impartial, and evidence-based information exchange, research, and advice regarding all modes of transportation. The Boardâs varied activities annually engage about 8,000 engineers, scientists, and other transportation researchers and practitioners from the public and private sectors and academia, all of whom contribute their expertise in the public interest. The program is supported by state departments of transportation, federal agencies including the component administrations of the U.S. Department of Transportation, and other organizations and individuals interested in the development of transportation. Learn more about the Transportation Research Board at www.TRB.org.
PREPUBLICATION COPYâUncorrected Proofs iv Consensus Study Reports published by the National Academies of Sciences, Engineering, and Medicine document the evidence-based consensus on the studyâs statement of task by an authoring committee of experts. Reports typically include findings, conclusions, and recommendations based on information gathered by the committee and the committeeâs deliberations. Each report has been subjected to a rigorous and independent peer-review process and it represents the position of the National Academies on the statement of task. Proceedings published by the National Academies of Sciences, Engineering, and Medicine chronicle the presentations and discussions at a workshop, symposium, or other event convened by the National Academies. The statements and opinions contained in proceedings are those of the participants and are not endorsed by other participants, the planning committee, or the National Academies. For information about other products and activities of the National Academies, please visit www.nationalacademies.org/about/whatwedo.
PREPUBLICATION COPYâUncorrected Proofs v COMMITTEE FOR A REVIEW AND UPDATE OF THE BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT OFFSHORE OIL AND GAS OPERATIONS INSPECTION PROGRAM Gregory S. Parnell, University of Arkansas, Fayetteville, Chair Lori S. Bennear, Duke University, Durham, North Carolina Claudine S. Bradley, Canada Energy Regulator, Calgary, Alberta Paul G. Bradley, Health and Safety Executive UK, Executive Aberdeen, United Kingdom Cary Coglianese, University of Pennsylvania Law School, Philadelphia James S. Dyer, The University of Texas at Austin Lois N. Epstein, The Wilderness Society, Anchorage, Alaska RADM Thomas H. Gilmour (U.S. Coast Guard retired), Independent Consultant, Eugene, Oregon Richard A. Sears, Stanford University, Stanford, California Robert Sheppard, Spire Engineering Services LLC, Houston, Texas Manuel Terranova, Peaxy, Inc., San Jose, California James M. Tien, University of Miami, Coral Gables, Florida Peter K. Velez, Peter Velez Engineering, LLC, Houston, Texas Transportation Research Board Staff Mark S. Hutchins, Study Director, Consensus and Advisory Studies Thomas R. Menzies, Jr., Director, Consensus and Advisory Studies Micah D. Himmel, Senior Program Officer, Consensus and Advisory Studies Claudia Sauls, Program Coordinator, Consensus and Advisory Studies Anusha Jayasinghe, Associate Program Officer, Consensus and Advisory Studies
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PREPUBLICATION COPYâUncorrected Proofs vii Preface In May 2017, the Bureau of Safety and Environmental Enforcement (BSEE) requested that the National Academies of Sciences, Engineering, and Medicine (the National Academies), through the Transportation Research Boardâs âMarine Board, review and advise on the agencyâs offshore oil and gas inspection program in the context of the agencyâs other related programs and activities and overall mission to promote offshore safety and environmental protection. To conduct the study, the National Academies appointed a committee of 13 experts in the fields of safety regulation and enforcement in high-hazard industries; regulation studies; offshore oil and gas operations and technology; safety management; and risk analysis and management. Committee members served uncompensated and in the public interest. Their biographical information is provided in the Appendix. The committee held its first meeting in October 2017. In December 2017, BSEE suspended the committeeâs work while implementing a revised risk-based inspection program in the Gulf of Mexico (GOM) region. When the study resumed in October 2018, BSEE asked the committee to provide guidance on the risk-based inspection program as part of its review. The full study charge is provided and discussed in Chapter 1. The committee met six times from December 2018 to March 2020 to gather information relevant to the study and to deliberate on findings and recommendations. The public meetings included multiple briefings from BSEE officials, officials from other government agencies responsible for regulating and overseeing the safety of high-hazard industries; representatives from the oil and gas industry; industry experts on offshore safety management and regulatory compliance; experts on third-party inspections and auditing; and researchers on safety and environmental regulation and inspection program design and implementation. The committee visited BSEEâs GOM region, where it met with leaders of BSEEâs inspection and safety management programs and visited a state-of-the-art operator control center and safety training facility. These briefings, meetings, and field visits were invaluable to informing this report, which represents the consensus effort of the committee. ACKNOWLEDGMENTS The study committee thanks the many individuals and organizations who contributed to its work. From BSEE, the committee was briefed by Lars Herbst, Region Director for GOM; Troy Trosclair, Deputy Regional Supervisor, GOM District Field Operations; Tim McGraw, Senior Inspection Operations Coordinator, GOM Region; James Richard, Well Operations Inspections Coordinator, GOM Region; Theresa Bell, Regional Supervisor, Office of Strategic Operations, Pacific Region; Michael Jordan, Office of Field Operations, Alaska Region; Jason Mathews, Chief, Office of Safety Management; Greg Schneider, Office of Safety Management; Stanislaus Kaczmarek, Chief, Safety and Environmental Management Systems Section; Doug Morris, Chief (retired), Office of Offshore Regulatory Programs; Susan Dwarnick, Chief, Offshore Safety Improvement Branch. McGraw, Bell, Jordan, and Richard also served as BSEEâs main liaisons to the study committee.
PREPUBLICATION COPYâUncorrected Proofs viii From other federal safety regulatory agencies, the committee was briefed by the Pipeline and Hazardous Materials Safety Administrationâs Linda Daugherty, Deputy Associate Administrator for Field Operations and the U.S. Coast Guardâs Jeffrey G. Lantz, Director, Commercial Regulations and Standards; CAPT Matt Edwards, Chief, Office of Commercial Vessel Compliance; and CAPT Russell E. Holmes (retired), Officer in Charge, Marine Inspections 8th District. From the offshore oil and gas industry, the committee was briefed by David Dykes, Chevron; Holly Hopkins, American Petroleum Institute; Greg Southworth, Offshore Operators Committee; Brent Ozenne and Jesse McGraw, Arena Offshore; Eric Hebert, Anadarko; Corey Lege, Talos Energy; Joel Plauche, Fieldwood Energy; and Michael Fairburn, Danyelle Kennedy, Barry Gaston, Paul Mendel, and Clark Yates, Shell. From third-party auditing, inspection, and accreditation and certification organizations, the committee was briefed by Charlie Williams and Curtis Johnson, Center for Offshore Safety; Ken Richardson, EVP Global Offshore, and Luiz Feijo and Gigi Bear, American Bureau of Shipping; Dan Phelps, Offshore Technical Compliance; Allison King, SEMP Check; and Phil Bernard, Compliance Technology Group. From academia, research institutions, consultancies, and offshore safety and conservation organizations, the committee was brief by Michael W. Toffel, Harvard Business School; Wayne B. Gray, Clark University; Mark Cohen, Vanderbilt University; Richard Berk, University of Pennsylvania; Douglas Hubbard, Hubbard Decision Research; Elmer âBudâ Danenberger, Independent Consultant; and Sarah Giltz, Oceana. Mark S. Hutchins managed the study and assisted the committee in the preparation of its report under the guidance of Thomas R. Menzies, Jr., Director, Consensus and Advisory Studies. Micah D. Himmel, Senior Program Officer, Claudia Sauls, Program Coordinator, and Anusha Jayasinghe, Associate Program Officer, provided extensive support to the committee in collecting and analyzing data, arranging meetings, and managing documents. Karen Febey, Senior Report Review Officer, managed the report review process. This Consensus Study Report was reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise. The purpose of this independent review is to provide candid and critical comments that will assist the National Academies in making each published report as sound as possible and to ensure that it meets the institutional standards for quality, objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. The committee thanks the following individuals for their review of this report: James C. Card, U.S. Coast Guard (retired); Christopher Carrigan, The George Washington University; Elmer âBudâ Danenberger, Consultant; Paul S. Fischbeck, Carnegie Mellon University; Kenneth Keegstra (NAS), Michigan State University; Camille Peres, Texas A&M University; Lincoln Stroh, J. Connor Consulting, Inc.; Theofanis G. Theofanous (NAE), University of California, Santa Barbara; and Charlie Williams, Consultant. Although the reviewers listed above provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations of this report, nor did they see the final draft before its release. The review of this report was overseen by the review monitor, M. Elisabeth PatÃ©-Cornell (NAE), Stanford University, and the review coordinator, Chris Hendrickson (NAE), Carnegie Mellon University. They were responsible for making certain that an independent examination of this report was carried out in accordance with the standards of the National Academies and that all review comments were carefully
PREPUBLICATION COPYâUncorrected Proofs ix considered. Responsibility for the final content rests entirely with the authoring committee and the National Academies.
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PREPUBLICATION COPYâUncorrected Proofs xi Contents Summary 1 Introduction Background Study Charge Study Approach Organization of the Report 2 Offshore Oil and Gas Operations and Safety Typical System Components and Technologies for OCS Operations Industry History and Approaches to Offshore Safety Summary 3 Role of the Regulator in Overseeing Offshore Oil and Gas Operations BSEEâs Mission, Organizational Structure, and Budget BSEEâS Regulatory Framework Inspection Mandate, Workforce, and Processes Inspection Strategies, Procedures, and Recent Initiatives Best Practices of Other Offshore Regulators Summary 4 Rationalizing and Enhancing the Inspection Programâs Safety Role A Broader View of Inspection Program Goals and Challenges Systems Thinking for Continual Learning and Improvement Aspirational Goals for BSEEâs Inspection Program 5 Summary Assessment: Findings and Recommendations Opportunities to Be More Outcome-Oriented Opportunities to Be More Data-Informed Take a More Holistic Approach to Risk Opportunities to Be More Discerning of New Technology Opportunities to Be More Adaptable Mapping Findings and Recommendations to the Themes in the Study Charge Appendix: Study Committee Biographical Information
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PREPUBLICATION COPYâUncorrected Proofs xiii Acronyms and Abbreviations AB accreditation body ABS American Bureau of Shipping ACP Alternate Compliance Program AOC acknowledgment of compliance API American Petroleum Institute ASP audit service provider BAH Booz Allen Hamilton BAST Best Available and Safest Technology BID Bureau Interim Directive BOEM Bureau of Ocean Energy Management BOEMRE Bureau of Ocean Energy Management, Regulation, and Enforcement BOP blowout preventer BSEE Bureau of Safety and Environmental Enforcement CAP corrective action plan CER Canada Energy Regulator CFR Code of Federal Regulations C-NLOPB Canada-Newfoundland & Labrador Offshore Petroleum Board CNSOPB Canada-Nova Scotia Offshore Petroleum Board COS Center for Offshore Safety DNV-GL Det Norske VeritasâGermanischer Lloyd DWOP Deepwater Operations Plan EEZ Exclusive Economic Zone FBRI Facility-Based Risk Inspection FOGRMA Federal Oil and Gas Royalty Management Act FY fiscal year GAO Government Accountability Office GOM Gulf of Mexico HWCG Helix Well Containment Group IAEA International Atomic Energy Agency IMO International Maritime Organization INC Incident of Noncompliance IOL increased oversight list IPD Interim Policy Document ISM International Safety Management ISO International Organization for Standardization
PREPUBLICATION COPYâUncorrected Proofs xiv KPI key performance indicator MBI Marine Board of Investigation MMS Minerals Management Service MOA memorandum of agreement MODU mobile offshore drilling unit MWCC Marine Well Containment Company NAE National Academy of Engineering NASA National Aeronautics and Space Administration NRC National Research Council NTL Notice to Lessees NVIC Navigation and Vessel Inspection Circular OCS Outer Continental Shelf OCSLA Outer Continental Shelf Lands Act OSM Office of Safety Management PBRI Performance-Based Risk Inspection PHMSA Pipeline and Hazardous Materials Safety Administration PINC Potential Incident of Noncompliance PSA Petroleum Safety Authority (Norway) RAC Risk Analysis Committee RBI risk-based inspection RO recognized organization RP Recommended Practice SEMS Safety and Environmental Management Systems SMS safety management system SPEAR Safety Performance Enhanced by Analytical Review UK HSE United Kingdom Health and Safety Executive USCG U.S. Coast Guard USDOI U.S. Department of the Interior USEPA U.S. Environmental Protection Agency