The Bureau of Safety and Environmental Enforcement (BSEE) asked the National Academies of Sciences, Engineering, and Medicine (the National Academies) to convene an expert committee to evaluate its offshore oil and gas inspection program and to advise on ways that the program could be improved and augmented. Given the expectation, based on interpretations of the Outer Continental Shelf Lands Act, that inspections are to be conducted on each offshore facility at least once per year, BSEE faces many challenges as it seeks to fulfill its stated mission “to promote safety, protect the environment, and conserve resources through vigorous regulatory oversight.”1 The challenges include keeping up with rapidly advancing and changing exploration and production technologies, the growing number of more varied, complex, and difficult to access facilities operating in deeper water and on the seafloor, and an aging population of legacy platforms mostly operating in shallow water. While BSEE has introduced several initiatives to meet these challenges, it faces many constraints and will need to make frequent strategic choices to innovate and evolve its inspection program to keep pace with this continually changing offshore energy landscape and avoid hampering its long-term effectiveness.
The many important choices that await BSEE are reflected in the series of nearly two dozen questions posed in the study charge, which are presented in full in Chapter 1. The questions, which are grouped into six themes, are far-ranging, including some that are highly specific to certain BSEE inspection program features and initiatives and others that ask about
the program’s performance and direction more generally. BSEE asks, for instance, for advice on whether the inspection program is meeting its mission, placing enough emphasis on safety management and process safety, and making appropriate use of technological capabilities such as remote and real-time monitoring of offshore facilities and systems. BSEE also asks for advice on how the inspection program could be improved by focusing more on higher-risk facilities and activities, for understanding and learning from the Safety and Environmental Management Systems (SEMS) that operators are required to develop and implement, and on making better use of external parties for inspection support functions. The committee is also asked to consider the oversight and inspection practices and approaches employed by safety regulators from other sectors and countries and for advice on whether some of these approaches are candidates for adoption by BSEE.
In reflecting on themes and questions in the study charge, and after discussions with BSEE following briefings on its strategic plans and initiatives, the committee came to view the subject matter of the questions as being indicative of BSEE’s ambitions, or “aspirational goals,” for its inspection program. In particular, the committee perceived an interest by BSEE in obtaining insight and advice for making its inspection program more
- Outcome-oriented by focusing more directly and proactively on reducing the occurrence and severity of incidents and recognizing that measures of total inspections and compliance with individual regulations may not be indicative of mission progress;
- Data-informed by marshaling and leveraging information obtained from SEMS audits, incident and near-miss reports, remote monitoring data, equipment failure reports, inspection results, and other data sources to guide outcome-oriented inspection policies, programs, and procedures and measure their effectiveness in reducing incidents and their severity;
- Holistic in the treatment of risk by considering the varied causes and contributors to incidents and the system-level means that can be employed for reducing them, including the consideration of environmental, technology, organizational, process, and human behavior–related risk factors;
- Discerning of the opportunities and challenges associated with new technologies, such as by being attuned to the promise of new technological capabilities for improved decision support and inspection functions, but clear-eyed about their potential limitations; and
- Adaptable to a changing offshore landscape by recognizing that the nature of risks and means for reducing risks are changing as the
- offshore industry changes, requiring an inspection program that has increased agility and more varied capabilities.
With these five aspirational goals in mind, the committee reviewed the challenges facing BSEE’s inspection program; its shortcomings and achievements; and opportunities that are becoming available for it to become increasingly more efficient, agile, and integral to the agency’s broader interest in promoting a strong safety culture in the offshore industry. The findings and recommendations from the review are summarized next. They address each of the five aspirational goals, which the committee believes should guide BSEE’s strategic priorities. Following this summary, the study’s findings and recommendations are discussed in Box S-1, specifically in the context of the six themes posed by BSEE in the study charge.
Finding 1: To meet the expectation that every offshore facility be inspected at least once annually, BSEE inspectors are scheduled to visit approximately 1,700 to 1,800 facilities per year. The need to devote this inspection “input” places a premium on inspection speed, which is achieved in part by inspectors following a “checklist-like” process for verifying that individual components and equipment are in regulatory compliance. The “output” of inspections tends be measured in the number of components inspected and violations detected. In focusing on these inputs and outputs, inspectors
often have limited time to observe operations at the system level or to engage with facility personnel to learn about and improve safety processes and assess the safety culture of the operator. The emphasis placed on inspecting all offshore facilities also limits BSEE’s ability to focus on enhancing safety outcomes through more thorough and targeted inspections of activities and facilities that are identified as presenting a higher risk of workplace safety incidents and events having severe safety and environmental consequences.
Recommendation 1: Because the prevention of both workplace safety incidents and catastrophic events is central to its mission, BSEE should ensure that its inspections are focused on achieving this outcome, supported by a sophisticated and continually refined and validated risk modeling capability for effective, outcome-oriented targeting of inspection resources. BSEE’s existing Risk-Based Inspection programs do not make clear distinctions about when modeling is intended to inform inspections aimed at preventing workplace safety incidents versus incidents having catastrophic safety and environmental outcomes. Moreover, BSEE’s Risk-Based Inspection programs remain a supplemental element of the overall inspection program, and the models that support them have not been the subject of continual evaluation, improvement, and validation. Risk identification, modeling, and analytic capabilities, including capabilities for identifying emerging risks and risks associated with system, organizational, and human factors, should be a fundamental and continually maintained and enhanced capability of the agency to inform inspection decision making.
Finding 2: Although BSEE has taken steps to become more data-informed in the deployment of inspection resources, such as through its Risk-Based Inspection program, considerable opportunity remains for the agency to improve the consistency, timeliness, and completeness of its Incident of Noncompliance records, incident reports, and other databases (possibly to include data gleaned from SEMS audits) to make them more useful for internal and external reviews that can improve the efficiency and effectiveness of traditional inspections and SEMS oversight functions. Opportunities for the latter include determining which new and different data could yield more value and be more analyzable to inform better safety management practices by offshore operators.
Recommendation 2: To further its goal of increasing data transparency and facilitating internal and external use, BSEE should invest in more advanced and creative data collection, analytic and visualization tools, and infrastructure; corresponding data management, analysis, and evaluation capabilities
among its personnel; and an outward-facing, online data system that can be navigated with ease and kept current across all fields for the purpose of encouraging and facilitating safety analyses.
HOLISTIC TREATMENT OF RISK
Finding 3: While BSEE has made continual improvements to its SEMS oversight program and taken some limited steps to assess operator safety culture in its facility inspection protocols, the focus of the inspection program remains centered on physical components and equipment and on identifying and seeking to correct the proximate causes of noncompliance and equipment failures. Insufficient attention is given to human system integration and the role of human factors and organizational systems in ensuring safe operations, implementing SEMS programs, and developing a safety culture.
Recommendation 3: BSEE should take purposeful steps to reposition and reshape its inspection and SEMS audit and oversight programs so that they learn from one another and work in concert to improve regulatory compliance; strengthen safety management planning, execution, and effectiveness; and exhort, support, and sustain the conscious efforts of operators to build and maintain a strong safety culture. Although BSEE has taken initiatives to improve both its inspection and SEMS audit programs, they continue to function along separate tracks, each aimed at improving safety in their own way but with limited regard for how they can communicate, collaborate, and inform one another to support continual improvement, including the fostering of strong organizational safety cultures. Although BSEE’s mission to promote offshore safety and environmental protection should not change by such a reorientation, the tools it possesses for achieving its mission would become more varied, comprehensive, and robust.
DISCERNING OF NEW TECHNOLOGY
Finding 4: The offshore oil and gas industry has been characterized by rapid technological change, particularly in recent years. New technologies are in use and being introduced that, among other things, improve offshore connectivity and enable remote sensing and monitoring of facility conditions and operations, including facilities located on the seafloor. These developments are providing many new opportunities for BSEE to enhance and improve the effectiveness and efficiency of its inspection program. Although the agency is monitoring these industry developments, it has limited ability to capitalize on them, in part because it lacks the personnel having the requisite technical expertise and industry backgrounds to take fuller advantage of the industry’s technological advancements.
Recommendation 4: BSEE should articulate a vision for how advances in offshore technology can be leveraged to fulfill its safety oversight and inspection functions, where they will need to be leveraged, and how they can improve the performance and meet the demands of the inspection and SEMS programs. BSEE should collaborate with industry on the expertise and management processes that will be required to pilot and then implement new strategies that make effective use of technological advancements. Consideration should be given to how the Best Available and Safest Technology process can be used to encourage the development and introduction of technologies that can improve offshore oil and gas safety and environmental management and performance while also providing BSEE with the capabilities needed to fulfill its safety oversight and inspection functions.
Finding 5: BSEE has undertaken many initiatives over the past decade to improve the effectiveness and efficiency of its inspection program; however, the fast-changing offshore energy operational landscape is making it increasingly important for BSEE to make adaptability a principal trait of its operations as well as its organizational structure and culture. Numerous factors, including some that BSEE has little control over, hinder the agency’s ability to adapt to a changing offshore industry. However, BSEE must adapt or risk becoming an outmoded and less effectual safety regulator.
Recommendation 5: To make adaptability a fundamental characteristic of its safety assurance approach, BSEE should give priority to increasing its organizational agility, the absence of which has become an impediment to keeping pace with the fast-evolving offshore oil and gas industry. This impediment is likely to become even more problematic as the industry’s technological sophistication and capabilities, operating methods, and scale and location of drilling and production activity change. An important starting point will be for BSEE to develop and institute an internal management system, similar to that of the U.S. Coast Guard, that establishes agency-level priorities and that guides and supports the full complement of needed adjustments in resources and personnel competencies and deployments to further those priorities (e.g., by ensuring that its districts and associated inspector workloads and distances traveled reflect the location of offshore facilities and their risk profiles and by making timely corrections and adjustments when they do not). BSEE must overcome the mindset that traditional approaches should be preserved in the face of change—such as the judicious use of third-party inspections to augment its program, the use of technology to supplement and substitute for some on-site inspections, and the creative makeup and deployments of ad hoc inspector teams. Without
necessary changes, BSEE’s agility and adaptive capacity could be severely constrained along with its ability to keep pace with the industry’s changing risk profile.
Although much of the study committee’s work was conducted prior to 2020, the study was completed in the midst of the COVID-19 pandemic and its far-reaching implications on the offshore oil and gas industry. Sharp declines in the demand for oil adversely affected offshore production while operators had to activate special emergency response protocols and precautions against the spread of the virus to ensure that their workforces remained safe. BSEE also had to make significant adjustments while maintaining continuity of its own operations, including instituting protocols to ensure the health and safety of its inspection personnel. A September 2020 review by the Inspector General of the U.S. Department of the Interior found that BSEE successfully implemented measures to protect its workforce from the transmission of the virus while also being able to fulfill its annual inspection plan, which included inspectors remotely witnessing operator blowout preventer tests.2
BSEE’s agility in the face of the COVID-19 pandemic—also observed at other times, such as in the aftermath of hurricanes—is emblematic of the agency’s adaptive capability, while also being indicative of the importance of the agency having this capacity. This study’s charge was framed in terms of BSEE’s aspirational goals for its inspection program, which are fundamentally about ensuring that the program is able to keep pace with, and indeed become more anticipatory of, changing circumstances and conditions. The committee believes that its recommendations, if pursued, will make BSEE’s inspection program become even more agile, versatile, and effective to the safety of the offshore oil and gas industry.
2 See Office of Inspector General, U.S. Department of the Interior. 2020. The Bureau of Safety and Environmental Enforcement’s Safety Inspection Program COVID-19 Response. CARES Act Flash Report No. 2020-CR-047. https://www.doioig.gov/sites/doioig.gov/files/DOIOIGCaresAct_BSEEInspectionsCOVID-19_092120.pdf.