The Bureau of Safety and Environmental Enforcement (BSEE) released a Safety Alert, informing on the findings of BSEE’s Gulf of Mexico-wide inspection effort under its Performance-Based Risk Inspection pilot, and provided recommendations.
The US Government Accountability Office conducted a review of BSEE’s oversight of offshore oil and gas operations, and found that the bureau had been unsuccessful in implementing a risk-based inspection component as part of its inspection program.
During his first 90 days at the helm, in August 2017, BSEE Director Scott Angelle instructed Gulf of Mexico regional staff to complete the pilot with the goal that risk based inspections implementation would become a reality in 2018.
“There are great safety benefits to having a full cadre of inspection protocols to manage operational risk. I saw the critical need for the smart tools necessary to ensure an effective inspection strategy and this protocol helps deliver added safety for all offshore operators,” Mr. Angelle said.
The pilot began with BSEE engineers reviewing recent compliance and incident data in the Gulf of Mexico Region to highlight areas where the offshore oil and gas industry faced problems. One such area was gas release hazards. BSEE conducted these targeted inspections on both production and well operations.
“Having witnessed the Gulf of Mexico staff’s efforts in completing this pilot, I am confident that BSEE will be able to achieve the goal of integrating a risk-based inspection protocol in 2018. Having this risk-based inspection protocol as part of BSEE’s strategy will move us further down the road toward safe and environmentally-sustainable operations,” Scott Angelle explained.
After the inspections were completed, BSEE further reviewed the results supplied by the district offices and conducted additional reviews on Safety and Environmental Management System specific items, finding the following:
- 17% of the facilities involved in the inspections had documented oil or gas accumulation.
- Eight of the thirty-six facilities, or 22%, had a non-operable gas detector, no process implemented for calibrating devices, failed a bump test, or had no documentation on the frequency and/or results of inspections.
- The facilities associated with the Gas Release inspections had no issues identified by BSEE staff on excessive temperatures. In fact, most observations made by inspectors indicated high temperature areas were well insulated and out of human reach.
- Only one facility had an outdated electrical classification drawing, but very few facilities had warning signs to address area classification. Most signs observed by BSEE inspectors during the Gas Release investigation focused on personal protective equipment. Additionally, one facility failed to notify BSEE of potential hazards through an orientation.
- The inspections suggest that operators’ safe work practices do not fully cover pressurized welding enclosures, and are not readily available to offshore personnel. Bridging documents with contractors need to be evaluated to ensure personnel are fulfilling their obligations.
- Develop and implement daily and weekly inspection protocol to check for common gas releases based on incident data – float cells, thief hatches, produced water treatment units, etc.
- Work with gas detector original equipment manufacturers to develop and implement monthly, quarterly, and annual inspection protocol for the handheld gas detectors on their facilities that document the date of the inspection or test; include the name and position, and the signature of the person who performed the inspection or test; include the serial number or other identifier of the equipment on which the inspection or test was performed; include a description of the inspection or test performed.
- Review their facilities and contracted drilling rigs to determine if area classification signs exist. If they don’t exist or they’re not properly marked, operators shall mark the area with signs identifying potential hazards.
- Review all safe work practices associated with gas detection and verify that they are available to all employees involved in the operations and reflect current practices.
- Verify their compliance with 30 CFR 250.1928 and evaluate / audit their latest JSAs with 30 CFR 250.1911.
- Meet with gas detector original equipment manufacturers, production contractors, and drilling contractors to develop minimal training requirements for day-to-day operations.
- Verify that all responsible company personnel and contractors are trained in the work practices necessary to understand and perform their jobs in a safe and environmentally sound manner in accordance with all provisions of Subpart S.
The protocol will be integrated into BSEE’s overall inspection strategy, with the first risk-based inspection scheduled for the second quarter of 2018.
For more information about BSEE’s Safety Alert, consult the PDF herebelow
