One of the lessons from the Macondo disaster was that the jobs people do on vessels in offshore oil and gas are out of sync with the regulations. Whether it is a MODU involved in drilling or an offshore workboat performing sophisticated well control operations, Coast Guard oversight is generally limited to seafarers. That ignores a lot of workers who are lumped into the general category of “persons other than crew.”
The Coast Guard just opened up the whole can of worms by releasing an Advance Notice Of Proposed Rulemaking (ANPRM) that tackles the issue head-0n, The ANPRM, titled Training of Personnel and Manning on Mobile Offshore Units and Offshore Supply Vessels Engaged in U.S. Outer Continental Shelf Activities seeks public comments by July 14th on a range of concerns that reflect the Coast Guard’s view that there are too many questions about non-seafarers on oilfield vessels.
What training do they require? What are the lines of authority? Who is responsible if things start blowing up? It is a hugely complex problem and every technological advance we make to the work vessels do in offshore oil and gas just adds more moving parts to the problem. We know that the vessel master and other seafarers need training on safety and other emergency response practices, but what about all the workers who are involved with anchor handling, ROVs, company representatives and other specialty workers who may find themselves on vessels? (I think here about a paleontologist I once meet who spends his days on a drill ship looking at microscope slides…not exactly Popeye, the sailor man).
These questions of chain of command, decisionmaking authority and training for non-seafarers played such a prominent role in the investigation of the Macondo disaster that the agency committed to address them through a rulemaking.
And here comes that rulemaking. It is bound to be controversial because the questions the Coast Guard is trying to address do not have easy answers. Or cheap answers. The Coast Guard indicates it may want everyone on the vessel to go through some level of basic training. Right now STCW Basic Training is a five-day course.
It could also require a clear and unambiguous document that explains the lines of authority on the vessel. That opens up a whole liability/insurance risk area that has been glossed over in the past.
Finally, it could put the Coast Guard on a collision course with BSEE over the question of who is in charge. Coast Guard regulations say it is always the Master of the vessel and this rulemaking may put the responsibility on the vessel to define lines of authority after that. BSEE puts the responsibility on the oil and gas leaseholder to determine the “Ultimate Work Authority,” specific to each type of operations (drilling, production, P&A, etc.). It is going to take some coordination between agencies to work that out and then if will take coordination between vessel owners and oil companies to put it into practice.