Speaking exclusively to SAFETY4SEA, Kevin Sligh, Director of the Bureau of Safety and Environmental Enforcement (BSEE), outlines the primary hurdles facing the offshore industry and discusses BSEE’s strategies for addressing them. Central to BSEE’s efforts is the cultivation of a safety-conscious culture and robust risk management practices across all offshore activities.
Emphasizing safety goes beyond mere regulatory adherence; it necessitates fostering a pervasive safety mindset across all offshore energy operations, embraced by all stakeholders. In that regard, Kevin Sligh adds that offshore wind industry needs to lead the charge in crafting new standards that prioritize safety and efficiency. Driving collaboration in the development of industry standards will ensure both safety and economic viability as well as United States’ ability to meet their offshore wind goals, he concludes.
SAFETY4SEA: What are currently the key challenges with the offshore industry from your perspective?
Kevin Sligh:
- Ensuring industry’s adherence to renewable energy regulations for workplace safety and environmental sustainability during a period of initial growth and installation for the U.S. offshore wind energy industry. As the lead regulator for the safe and environmentally responsible production of offshore renewable energy, BSEE is committed to ensuring safety and environmental sustainability in offshore renewable energy operations.
- Driving down risks of injury to offshore oil and gas workers and protecting the offshore environment as industry operates further offshore and uses novel technologies, including equipment used in high pressure or high temperature environments. BSEE is committed to the highest standards of worker safety and environmental protections, and is in the process of revising regulations to better ensure the oil and gas offshore energy industry drives down risks of injury to offshore workers and protects the offshore environment, particularly as industry starts encountering more challenging operating conditions.
- Addressing orphaned offshore oil and gas infrastructure that can pose serious safety hazards and cause ongoing air, water and other environmental damage. An important part of BSEE’s responsibilities is ensuring that infrastructure used in exploration, development and production activities is properly decommissioned according to the Outer Continental Shelf Lands Act, to provide for the long-term protection of offshore resources and the environment.
- Addressing cybersecurity risks to the offshore energy sector by implementing robust operational technology and industrial control systems. Aligning with its mission to promote safety and protect the environment, BSEE is working to establish a robust BSEE Offshore Energy Operational Technology cybersecurity strategy in collaboration with federal cybersecurity partners and experts.
Industry’s management of cybersecurity risks will require the implementation of a culture of cybersecurity risk management.
S4S: What are the top priorities on the BSEE agenda for the next five (5) years?
K.Sl.:
- Continued safety across all energy sources – Promoting and instituting an enduring culture of risk management is a legacy that BSEE aspires to, and we want it to permeate throughout all energy activities on the Outer Continental Shelf.
- Renewable energy – continuing to develop and implement renewable energy oversight programs, policies and regulations that keep workers and the environment safe, especially during this current phase of initial growth and installation.
- Decommissioning – enforcing timely decommissioning of infrastructure that is no longer useful, and addressing orphaned offshore oil and gas infrastructure that can interfere with other users of the OCS, posing serious safety and environmental hazards and perpetuating inequities to disadvantaged and marginalized communities.
- Carbon Sequestration – developing a joint offshore carbon sequestration rulemaking with the Bureau of Ocean Energy Management that will incorporate best practices and establish processes that support safe and environmentally responsible carbon dioxide sequestration on the OCS.
- Cybersecurity – ensuring industry’s implementation of robust operational technology and industrial control systems as they relate to cybersecurity risks. BSEE’s strategy is focused on keeping offshore energy operations safe through partnerships with the industry and with other experts in the government.
- Tribal Engagement – developing national Tribal coordination and consultation policies and procedures to enhance our bureau’s Tribal engagement initiatives and meet our trust responsibilities. We are committed to honoring our trust responsibilities to Tribes, Alaska Native Claims Settlement Corporations, and the Native Hawaiian Community.
- Environmental Justice – developing a focused strategy and action plan that integrates environmental justice considerations into bureau activities and supports the Department of the Interior’s environmental justice vision, goals and objectives.
S4S: What are the key lessons learned from recent accidents concerning the offshore industry? Have you identified any alarming trends/ topics or any particular needs for regulatory update/ best practices?
K.Sl.: Based on the most recent offshore oil and gas performance data from 2023, there were zero occupational fatalities in 2023. Recent data also indicates the number of reported injuries is significantly lower in 2023 compared to 2022. The number and volume of oil spills greater than one barrel per spill also dropped in 2023 compared to 2022. As BSEE continues its evaluation of the 2023 oil and gas performance data, we are working to identify possible contributions to the safety performance trends, and how we may be able to continue to improve awareness and management of risks in all offshore operations.
S4S: Are you satisfied with progress made toward improving environmental performance within the offshore industry? What would you like to see up to 2030?
K.Sl.: We are never satisfied because pollution incidents still occur. BSEE will continue to push for improvements in environmental performance across the entire offshore energy. Water quality and air quality testing continues to be a core element of our inspections and we work with the offshore energy industry to address the importance of mitigating marine trash and debris. Every environmental risk must be appropriately addressed in order to protect coastal communities, marine life and the offshore workers who are all impacted by offshore energy operations. To address climate challenges now and into the future, BSEE supports the Department of the Interior and the Biden-Harris administration’s commitment to advancing the nation’s offshore wind energy goal of deploying 30 gigawatts of offshore wind energy capacity by 2030 and 15 gigawatts of floating offshore wind capacity by 2035. Meeting these goals is expected to lead to the creation of nearly 80,000 good-paying jobs. Even as our nation incorporates clean energy sources offshore, BSEE will continue strengthening and modernizing offshore oil and gas energy standards and oversight.
S4S: What is your wish list for the industry and/or regulators and all parties involved for the offshore industry to enhance safety culture onboard?
K.Sl.: This year, we are strengthening our focus on preparedness. Not just internal to BSEE but also encouraging it across all offshore energy sectors. BSEE’s team of career engineers, scientists, and regulatory specialists continue to review and propose revisions to federal regulations to ensure that activity on the OCS is conducted in a safe and environmentally responsible manner. BSEE uses sound science and best practices to improve reliability, safety, and environmental stewardship when developing and updating regulations, and when making and implementing policy.
S4S: How can industry stakeholders best collaborate in support of sustainable development? In what ways does BSEE collaborate with industry stakeholders to promote safety initiatives and encourage compliance with regulatory requirements?
K.Sl.: BSEE takes every opportunity to engage with industry, developers, unions, academia, NGOs, federal and international partners, and Tribes in our effort to promote responsible, sustainable and safe energy operations. We fund and work with an academia/industry/government partnership called the Offshore Energy Safety Institute. We acknowledge and participate with educational entities such as the Center for Offshore Safety and G+. And we work with other Standard Development Organizations to develop and update consensus-based standards that improve safety and environmental compliance. For example, BSEE continues to collaborate with offshore wind industry developers and with offshore wind experts on health, safety and the environment. BSEE also engages with stakeholders and our European counterparts to define, establish and strengthen offshore wind oversight procedures that have a solid foundation in lessons learned, sound science and evidence-based information.
S4S: What do you think are the industry’s key strengths and weaknesses? How would you like to see it evolve?
K.Sl.: We engage often with industry to build a culture of safety (risk management) in all offshore operations. Promoting the industry’s continued commitment to safety is a priority.
S4S: If you could change one thing from your perspective, what one thing would it be and why?
K.Sl.: We’d like to see industry demonstrate a consistent commitment to:
- Preventing significant incidents, and to driving down the number and severity of safety and pollution incidents during offshore energy operations.
- Their financial responsibility for all operations throughout the lifecycle of their infrastructure, including decommissioning.
- Operational discipline and management system principles in every aspect of offshore work.
S4S: What is your message to industry stakeholders with regards to a more sustainable future for the offshore industry?
K.Sl.: BSEE supports offshore energy development and production from all sources. And as we do so, our focus will always be safety, sustainability and reliability. A continued focus on safety must go beyond simple compliance with regulations. It must ensure the adoption, by everyone, of a meaningful safety culture that permeates all offshore energy activities. We would like to see the offshore wind industry become more proactive in development of new industry standards. Industry standardization not only will help with safety but also can reduce costs to help ensure the United States’ ability to meet our offshore wind goals.
BSEE is currently working on:
- Updates to the Safety and Environmental Management Systems oil and gas regulation, which will help promote and grow a deepening culture of risk management in the industry.
- Oil Spill Response Plan regulations to improve environmental protections offshore, while providing best practices and lessons learned from Deepwater Horizon and the National Response Center guidance.
- High-Pressure and/or High-Temperature Environments and oil and gas Subpart B Revisions. This rule would formally codify BSEE’s existing practice for reviewing and approving new or unusual technology projects, including projects in HPHT environments, to provide clarity and certainty surrounding related requirements and BSEE processes.
- Updates to Pipelines and Pipeline Rights-of-Way regulations would implement a comprehensive revision of the regulations regarding pipelines and pipeline ROW on the OCS. This would result in an up-to-date set of pipeline regulations, reflecting current industry practices and BSEE policies.
- Updates to the documents incorporated by reference in oil and gas regulations that would incorporate the most recent editions of industry technical standards relating to safety, reliability and environmental protection to reduce regulatory uncertainty and provide enhanced enforceability.
- Renewable energy regulations and performance-based oversight related to worker safety and environmental sustainability.
- Regulations that lay out a framework for safe and environmentally responsible carbon sequestration on the OCS.
The views presented are only those of the author and do not necessarily reflect those of SAFETY4SEA and are for information sharing and discussion purposes only.