Modernizing the U.S. Offshore Oil and Gas Inspection Program for Increased Agility and Safety Vigilance (2021) / Chapter Skim
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4 Rationalizing and Enhancing the Inspection Program's Safety Role
4 Rationalizing and Enhancing the Inspection Program's Safety Role
Pages 111-130
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From page 111... ...
Facilities in shallow water that are typically far less complex and account for a smaller and declining share of offshore production are nevertheless predominant and present their own safety assurance demands and challenges. They are generally older, owned and operated by smaller entities, less technologically sophisticated, and not as intensively monitored as the larger, more heavily staffed deepwater facilities.
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From page 112... ...
Examples of other high-hazard industries and regulatory programs from other sectors and abroad suggest that an inspection program can contribute more broadly to the improvement of the regulated industry's safety and environmental systems by viewing compliance verification and enforcement as only one part of the program's purpose to promote safe behavior and performance. Indeed, the committee assumes that BSEE's aspirations for its inspection program, as reflected in the questions and themes of the study charge, derive from a growing interest in becoming a regulator that can promote safety and environmental protection through many varied and complementary ways.
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From page 113... ...
; • Inform regulated entities about the types of problems they may have with their facilities and operations, including problems that need solving for reasons other than avoidance of regulatory pen alties, such as potential for increased insurance premiums, tort liability, and community pressure; • Model ways in which the regulated entities can identify vulner abilities with their operations and facilities on a regular basis (e.g., through self-audits) , assuming they have other incentives to do so; and • Teach the managers and personnel of regulated entities about the desired outcomes of the regulatory program, not only by using inspection encounters to convey applicable legal obligations, but also to use the encounters for advocating ways that managers and their personnel could do better to achieve the desired outcomes.
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From page 114... ...
For these reasons, inspectors whose only engagements with the regulated entity consist of such periodic and brief encounters are inherently challenged as they try to encourage and reinforce safe behaviors and risk awareness and control. Indeed, an inspection program that is characterized by such brief encounters could very well hinder the ability of an inspection program to play the fuller and more beneficial safety role described above.
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From page 115... ...
Not only must the encounters be leveraged for maximum effect, but they must also be designed so that they avoid having detrimental effects on the regulated entity's general effort to ensure safety through means that are not amenable to physical inspections. Cognizant of the shortcomings of the typical inspection, regulators in a range of domains have been embracing new roles and strategies to effect meaningful change and improved outcomes across their respective jurisdictions.
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From page 116... ...
The tendency to overemphasize rule compliance, however, has been changing in the regulatory field, as evidenced by an increased regulator and industry attention -- first embraced by North Sea offshore regulators and now formalized in industry standards and safety management regulatory designs in North America -- to the importance of identifying and managing risks using strategies such as • Considering alternative regulatory roles beyond traditional en forcement methods; • Increasing reliance on regulatory instruments that focus industry efforts on systemic fixes; • Leveraging industry-wide data and trends to understand deficien cies across the system; • Fostering dialogue among regulators and industry that seeks to im prove understanding of safety system challenges and best practices; and • Developing internal competency relative to human and organi zational factors (e.g., governance models, decision making, risk evaluation, resource allocation, and safety culture)
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From page 117... ...
Accompanied by traditional compliance verification and enforcement strategies, the regulator's efforts to promote organizational learning and improvement will expand its role and potentially make it more effective in furthering its safety assurance mission. The potential for an overemphasis on compliance verification to impair wider safety management and innovation efforts was recognized more than 30 years ago in the UK Cullen Report, which followed the Piper Alpha offshore platform disaster in the North Sea (Cullen 1990)
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From page 118... ...
Pointing to the traditional focus of offshore safety regulations on meeting technical requirements for equipment and other hardware, a 2016 National Academies study committee observed that regulators have tended to hire personnel with engineering expertise, but not always the knowledge or skillsets required to identify and work effectively with industry to address sociotechnical hazards such as those related to human and organizational factors (e.g., safety culture)
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From page 119... ...
The program continues to focus on physical inspections of facilities, and the inspection protocol remains centered on inspectors verifying that a predefined list of regulatory requirements is being met by the operator. The operator's compliance with the requirement of a SEMS program is verified separately by the agency through monitoring and reviewing third-party program audits.
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From page 120... ...
For reasons explained in Chapter 1, the committee viewed the six themes and more than 20 questions in the study charge as being indicative of BSEE's desire to make its inspection program not only more efficient but also more effective to the agency's mission. Looking across the varied themes and questions, the committee perceived an interest by BSEE in suffusing the inspection program with the following qualities: • Being more outcome-oriented by focusing more directly and pro actively on approaches for reducing the occurrence and severity of offshore incidents, and recognizing that measures of total in spections and compliance with individual regulations may not be indicative of mission progress; • Being more data-informed by marshaling and leveraging informa tion obtained from facility inspections, near misses and incidents, SEMS audit reports, equipment failure reports, and other records to identify themes and trends in order to inform regulatory prac tices and priorities and to measure the progress and effectiveness of the inspection program in reducing risk and increasing the trans parency of its inspection methods and focus; • Being more 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 con sideration of environmental, technology, organizational, process, and human behavior–related risk factors;
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From page 121... ...
BSEE's Current Efforts to Become More Outcome-Oriented The monitoring and measuring of a regulatory program's outcomes, as opposed to strictly its inputs and outputs, should be connected as closely as possible to the organization's mission, which in the case of BSEE is to reduce the number and severity of offshore incidents. Inputs are generally expressed as the effort or resources devoted to the organization's activities, such as the number of inspectors or inspections conducted.
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From page 122... ...
Because there is the expectation that all offshore facilities be inspected annually, the total number of facility inspections conducted, and particularly the number in relation to regulated facilities, has an important role in guiding BSEE's inspector deployments. Inspectors visiting facilities work through a standard list of PINCs to meet this expectation.
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From page 123... ...
When the inspection findings indicate a potential safety risk, BSEE will issue industry-wide safety alerts containing recommendations for practices to address the problem.4 In the case of the FBRI, BSEE uses the Argonne National Laboratory (ANL) Risk Model to develop a risk metric for each offshore facility, ranking each by the relative risk of having a severe incident.
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From page 124... ...
that is charged with examining advanced data analysis tools that can be used on its databases to identify current and emerging offshore hazards and to guide its RBI program.9 For example, the SPEAR committee is investigating the use of machine learning and artificial intelligence (AI) techniques to capitalize on existing databases, and is tapping the National Aeronautics and Space Administration's (NASA's)
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From page 125... ...
The focus on individual risk factors facilitates the process of compliance verification, but not necessarily risk reduction. For instance, compliance with a regulatory requirement for a properly functioning safety valve can be readily tested at a point in time, but the testing may not consider the means by which the valve is maintained to ensure its continued readiness to function or the willingness and knowledge of personnel to use it when manual activation is required.
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From page 126... ...
In 2013 after issuing the SEMS rule, BSEE went a step further by emphasizing the importance of operators striving to develop a culture of safety within their organizations and those of the contractors who provide many of the services and personnel for offshore facilities.12 The safety culture statement emphasizes the importance of leaders demonstrating a commitment to safety and environmental stewardship in their decisions, behaviors, and communications; work processes that are planned and implemented with safety and environmental stewardship as the top priorities; personnel having the freedom and means to raise safety and environmental concerns; and reviewing existing conditions and activities on a continuing basis to identify and eliminate those that risk errors and inappropriate actions. Success in creating a positive organizational safety culture was characterized as being essential to a dynamic SEMS program, and instilling greater confidence in BSEE that operators will comply with (and properly integrate their contractors' safety management into)
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From page 127... ...
Current BSEE Efforts to Be More Discerning of New Technologies Advances in technology have enabled the oil and gas industry to explore and produce in more remote and deeper waters, higher-temperature and higher-pressure reservoirs, and harsher weather and marine conditions. Consequently, aspects of the safety regulator's job have become more challenging, both in trying to issue component- and activity-specific regulations that are applicable to more complex and facility-specific operations and in trying to verify and enforce regulatory compliance through inspector visits to facilities.
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From page 128... ...
Its eRecords initiative, as discussed in Chapter 3, is aimed at increasing the time inspectors spend offshore performing physical inspections rather than reviewing records that could otherwise be reviewed onshore separate from visiting the facility. As noted earlier, BSEE is investigating the use of machine learning and AI tools to mine its databases and is taking advantage of NASA's probabilistic risk analysis tools and machine learning tools through its SPEAR program.
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From page 129... ...
Having limited ability to transform its regulatory and inspection programs (akin to the offshore regulatory programs of Norway and the United Kingdom) , BSEE has responded with modest but nevertheless meaningful programmatic changes, such as by employing more risk-based inspections, holding operators more accountable for vigilant safety management (through SEMS programs)
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From page 130... ...
2016. Special Report 321: Strengthening the Safety Culture of the Offshore Oil and Gas Industry.
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