Government needs to take a more holistic approach when it comes to modifying existing practices for the newly mandated safety and environment programs for offshore drilling and production operations, a new study said.
The new approaches should include inspections, operator audits, bureau audits, key performance indicators, and a “whistleblower” program, according to the report from the National Research Council. The report emphasizes using cooperation and consultation to further develop a culture of safety.
These recommendations are consistent with the bureau’s proposed changes to Safety and Environmental Management System (SEMS) with the exception of one change to require audits by third parties. The Research Council report prefers an independent internal audit team to an external third-party team to avoid the development of a “compliance mentality.”
Audits should occur via the operator’s internal qualified, independent team whenever possible. The Bureau of Safety and Environmental Enforcement (BSEE), which oversees the offshore drilling and production operations, should approve all audit plans and receive a copy of each audit and follow-up report.
“BSEE should seize this opportunity to make a step change in safety culture,” said Kenneth Arnold, senior technical adviser at WorleyParsons, Houston, and chair of the committee that wrote the report. “The bureau can tailor its approach to evaluating the effectiveness of SEMS in order to move both the industry and the government from a culture of relying on punishment only — obtaining prescriptive adherence to pass/failure requirements — to a culture of continuous improvement. The idea is to meet the goals of SEMS through a mixture of cooperation and consultation as well as punishment.”
Since the April 2010 Deepwater Horizon blowout and explosion, the federal government as well as the offshore oil and gas industry have been undergoing major changes, including the issuance of regulations requiring operators of offshore facilities to adopt and implement comprehensive SEMS programs by Nov. 15, 2011.
These systems should shift from an entirely prescriptive approach to a proactive risk-based, goal-oriented regulatory approach to improve safety and reduce the likelihood of similar events recurring. The committee for this study came up with a plan for recommending a method of assessing the effectiveness of operators’ SEMS programs on any offshore drilling or production facility.
In addition to compliance inspections and an internal, independent auditing system, the report recommends the bureau establish a key performance indicator program to identify metrics to evaluate the SEMS audit approach and to find opportunities for improvement. This information should determine trends and should disseminate to the industry in a timely manner.
The report also recommends BSEE establish a “whistleblower” program to help monitor the culture of safety at each installation and correct any improprieties in its own operations. Workers must have a way to anonymously report dangerous deviations in norms and motivations that may not be obvious to bureau inspectors or even to internal auditors, as well as unprofessional conduct by BSEE’s own staff, the report said.
BSEE should continue to perform complete or partial audits when justified by reports, incidents, or events, and is responsible for verifying there are quality audits. To fill this role, the bureau needs trained auditors who can spend sufficient time on location to conduct the appropriate audits. Hiring and training additional personnel will likely be necessary, the report said. BSEE inspectors should focus on promoting safety rather than issuing citations for incidents of noncompliance that may or may not be important in meeting the intent of SEMS.