The Coast Guard and BSEE issued a joint safety alert on May 21 concerning a vessel that lost position when its DP failed. Read the alert here. Specific details are typically sketchy on safety alerts. This one says the vessels was involved in “well operations that introduced hydrocarbon flow from a well to the vessel,” when the dynamic positioning failed and the vessel went off station. The crew successfully disconnected and there were no injuries or pollution. It appears that the vessel was doing maintenance on the circuit breaker system when the failure occurred.
Other than a reminder to all companies to do maintenance on time and not while performing critical operations, what makes this alert so noteworthy is that the two agencies issued it together, “to highlight the interaction between a vessel’s Safety Management System (SMS) and a leaseholder’s Safety and Environmental Management System (SEMS).”
In other words,
- The Coast Guard is warning vessel owners to make sure they meet the requirements of their ISM plans by doing maintenance in a timely manner and under noncritical conditions, and to anticipate potential system failures;
- BSEE is warning operators that they need to factor in the potential for DP failures into their SEMS plans and require vessels to address it under their safe work practices; and
- Both agencies are saying that the interaction between vessel safety management and SEMS needs to mesh.
It is also noteworthy that BSEE believes it has authority over vessel operations when they directly involve interaction with a covered facility or, as the alert puts it BSEE and the USCG share “jurisdiction over vessels that perform this type of OCS activity.” That is probably news to most vessel owners in the Gulf who strongly believe that the Coast Guard is the only agency that has jurisdiction over their operations.
What does all this mean? For one thing, the agencies are working together to make sure this kinds of incidents don’t slip between the cracks of their jurisdiction. For another, BSEE is clearly sending a message to operators that their SEMS plans must anticipate and control the actual hazards that could put their offshore operations at risk. That will take a high level of coordination between operators and contractors to identify, address and document safe work practices.