As we have noted in the past, government regulators are changing enforcement tactics for offshore oil and gas. We recently saw new evidence of how that change when the Bureau of Safety and Environmental Enforcement (BSEE) released a safety alert on gas hazards. The three factors driving change have been:
- Limited budgets,
- Requirements for companies to address safety through Safety and Environmental Management Systems (SEMS) plans, and
- A push for targeted inspection programs that focus on incidents and accident histories.
The safety alert released on January 5th is an example of a targeted inspection project. BSEE studied reported incidents over a period of time and found it had thirty-one reported gas releases during the period, so it launched an intensive inspection project. in a two day period, inspectors landed on 26 production platforms and 10 well operations in the Gulf of Mexico Region.
Here’s what they found:
- 17% of the facilities had documented oil or gas accumulations
- 22 % had one or more of the following problems –
- a non-operable gas detector,
- no process implemented for calibrating devices,
- failed bump tests,
- no documentation on the frequency and/or results of inspections.
- In many cases, safe work practices and bridging documents were inadequate.
- In some cases, job safety analyses reviewed by BSEE met the intent of Subpart S, but not the specifics of the SEMS rule
- Multiple facilities lacked evidence of personnel training in gas detection
- One facility had an outdated electrical classification drawing
- A number of facilities had warning signs to address area classification
- One facility failed to notify BSEE of potential hazards during its arrival orientation
A lot of those problems, like bump tests, training records and inoperable gas detectors are pretty basic stuff. However, we can’t lose sight of the fact that these violations involve safety rules and not actual injuries. That is what targeted inspections or internal reviews are supposed to do – identify potential gaps in safety controls before an incident happens and anyone get hurt. They are also based on the trust that industry will address problems in the spirit of safety.
The safety alert contains a number of recommendations. Offshore operators and their contractors need to recognize that this is the new enforcement model and work to implement the changes.