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A question of technology, people & risk Salerno describes BSEE’s evolving approach to the regulation of offshore oil and gas exploration, development and production Alan Bailey Petroleum News
In 2011, in the wake of the Deepwater Horizon disaster, the U.S. Department of the Interior established the Bureau of Safety and Environmental Enforcement, or BSEE, to oversee regulatory enforcement for the oil and gas industry on the outer continental shelf. And, having cut its teeth on the difficult issue of the regulatory response to lessons learned from the Gulf of Mexico disaster, the new agency is continuing to evolve in the way in which it tries to ensure the safety of offshore operations.
On May 8 BSEE Director Brian Salerno talked to attendees of the 2014 Offshore Technology Conference about his agency’s latest thinking, and about some of the initiatives that it has been launching. The agency and the oil industry share the overlapping goals of safety and the protection of the environment, with catastrophic events having the effect of undermining public confidence in both the industry and the regulators, Salerno said.
And, to achieve a constructive relationship between the regulator and the regulated industry it is necessary to focus on three areas: the technology that the industry uses; the human element in technology usage; and the effective management of risk, he said.
Technology From the perspective of technology, BSEE faces a significant challenge in keeping pace with rapid technical innovation by the industry, with both regulatory and industrial standards liable to be outpaced by technology change. With that in mind, BSEE has been moving towards more of a performance-based, safety-case approach to regulation, setting required performance standards rather than trying to prescribe specific standards for the use of specific types of equipment.
But BSEE sees a need for a hybrid approach, maintaining traditional safety standards where appropriate, but also introducing performance-based language into regulations, to more efficiently accommodate technical innovation, Salerno said.
BSEE has also established the Ocean Energy Safety Institute to act as a forum for collaboration between industry, government and academia in exploring the safety implications of emerging technologies. And Salerno said he had recently announced an intention to establish a technology center within BSEE, to support the agency’s regional offices by keeping abreast of technology, as industry innovates and develops new capabilities.
The human element But the human element in decision making and technology use is also important in ensuring industrial safety, Salerno said. From this perspective, the oil and gas industry needs the “no-failure-accepted” culture of high reliability entities such as naval submarines, nuclear power plants or the space program, he said.
BSEE has taken a lead in this area by mandating the use of a performance-focused safety and environmental management system, or SEMS, for integrating and managing offshore operations, Salerno said. Among other things, a SEMS protocol requires a focused look at industrial systems and at people’s roles in work processes, with obligations for people to report unsafe practices, he said. However, the achievement of a widespread safety culture in the industry remains a work in progress, with tragic accidents involving the loss of life pointing to a failure to follow established safety processes in some companies, he said.
Risk management As a component of a safety culture, risk management must form the lens through which to view the interaction between technology and the human element, Salerno said, adding that risk management forms the foundation for the regulation and enforcement of standards.
From this perspective, BSEE is exploring a risk-based inspection approach to focus inspection efforts on facilities and companies that seem to pose higher safety risks than others. Once the agency has developed a solid methodology it anticipates being able to use a lighter touch in the oversight of high performing companies while visiting the poorer performers more frequently, Salerno said.
Risk management could also be incorporated into a SEMS through, for example, the inclusion of procedures that involve the recognition of industrial hazards and the identification of “barriers” to mitigate those hazards, he said.
Information dissemination BSEE is also considering how to improve its dissemination of information from accident investigations, with this information potentially providing companies with knowledge for improved safety awareness, Salerno said. And the agency is developing a near-miss reporting system, such as is used in the aviation industry, he said. The reporting of near miss events, with guaranteed anonymity for the reporting source, could become a valuable source of safety lessons learned, he said.
Salerno also commented on the importance of coordination between different government agencies, particularly citing the critical nature of the relationship between BSEE and the U.S. Coast Guard in the regulation of offshore activities. It is imperative that the agencies convey a consistent message to the regulated community, he said.
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