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November 13, 2013
BSEE director puts compliance into perspective

For offshore energy companies, the top priority in building a safety culture at their facilities is addressing risk.  In fact, how risk is addressed is more a measurement of “safe” than the absence of accidents, how complex activities are managed, and even compliance with regulations.  And risk is best addressed when each and every employee on an offshore installation has no fear about speaking up when he or she sees something that may put someone in danger.  Neither is risk addressed when, for example,  employees pay attention to problems such as a missing handrail only when they see the inspector’s helicopter approaching.

Those and related views that will be of interest to offshore operators were contained in a speech delivered by Brian Salerno, director of the U.S. Bureau of Safety and Environmental Enforcement (BSEE) at the 2013 International Regulators’ Offshore Safety Conference in Perth, Australia. 

Interest fading, risks remain

Salerno notes that 3 years after the Deepwater Horizon disaster, fading public interest may lead people to believe that the kinds of problems that lead to offshore accidents have been fixed.  In fact, during the past year, there have been three major well control incidents and a separate explosion resulting in loss of life.  These incidents occurred during different types of operations on different facilities and all of them occurred in shallow water, Salerno points out.

“They are a clear reminder that risk does not discriminate,” said Salerno.  “It is not isolated to highly technical, deepwater operations or high-temperature and high-pressure reservoirs, or any other type of new, frontier area.  Risk is ever-present, across all operations.”

Accidents, Salerno emphasized, typically result from a series of failures, any one of which, if avoided, could have prevented the outcome.  Thus, while operational risks are typically the first to receive attention, there are financial risks, technical risks, geologic risks, and risks related to human factors.  “Failure to address any of these appropriately can have catastrophic consequences,” said Salerno.

BSEE’s actions

According to Salerno, BSEE’s goal in regulatory and nonregulatory actions is to aid operators in identifying, quantifying, and mitigating risks.  Recent risk-related actions the BSEE has taken include:

  • An interagency agreement with the Bureau of Transportation Statistics to enable offshore workers to report near-misses in a way that protects their identity and is completely independent of the BSEE.
  • A project with a Department of Energy national lab on improved statistical analysis and risk modeling to help better quantify risk, prioritize BSEE’s limited resources, and focus regulatory actions on higher-risk activities.
  • Near-completion of a proposed rule to enhance the reliability of blowout preventers based on studies of the Deepwater Horizon.
  • The recently finalized Safety and Environmental Management Systems regulations (SEMS II) that require that operators apply certain tools to their management processes, including stop-work authority, ultimate work authority, employee participation, third-party audits, and bridging documents with contractors.  “BSEE will not dictate how that [application] is accomplished,” added Salerno.  “It is up to the operators to determine how to best apply the tools to their management systems and processes.”

Proactive measurement

Salerno conceded that safety is difficult to measure.  “Safety is an element that is easier to measure when it is absent,” he said.  “When an accident occurs, it is easy to point to that and say, ‘they were not safe,’ and you can then peel back the contributing factors and identify things that should have been visible before the accident. That is why we must proactively identify, quantify, and mitigate risk based on new, relevant data streams.” 

Salerno's speech 

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