Alternatives for Inspecting Outer Continental Shelf Operations (1990) / Chapter Skim
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6. Assessment of Present Program and Alternatives
6. Assessment of Present Program and Alternatives
Pages 58-74
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From page 58... ...
and because of advancements in safety technology, a fresh look at the effectiveness of the present program is indicated. Responsiveness in Meeting Present Safety Needs: Adaptability to Changing Circumstances The present MMS inspection program is responsive to the express terms of the Outer Continental Shelf Lands Act (OCSLA)
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From page 59... ...
The following findings give further weight to this perception. The committee reviewed the events file for 1982 for deaths, injuries, fires, and pollution in Gulf of Mexico production operations.
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From page 60... ...
, filling operations by the fvessel's] pumps were not completely shut down before the deceased had replaced the tank vent plug, which caused a pressure buildup in the land Ignition occurred immediately and was most likely caused by the generator en~ne's exhaust direct)
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From page 61... ...
Design violations 7. Handling heavy loads 8.
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From page 62... ...
Control component failure Totals 15 13 8 5 5 5 3 2 2 64 Number of Number of events - barrels Potential PING violations 38 34 18 16 15 13 13 6 6 48 2 2 .
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From page 63... ...
The committee also analyzed 262 events in 1982 pertaining to drilling and workover operations, though not in as much detail as it did the events related to production operations. Table 6-7 summarizes these events by category of cause.
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From page 64... ...
Tank runover, ruptured hose Electrical systems Loss of well control Pollution from mud circulating system Welding Opening a pressurized system Equipment overpressure Premature firing of perforating gun Boat collision Unknown Tota s 209 16 9 8 5 4 3 1 1 2 4 262 ., tested prevented fires in 4 of the 8 events. The extent of injuries or oil pollution in the course of the 8 blowouts—although clearly not major, based on collateral evidence regarding major accidents in 1982 cannot be determined from the events file, as this information is not reported for some of the events.
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From page 65... ...
For these and other reasons the committee believes that continued frequent onsite inspection of drilling rigs is important. In the aggregate, the committee's analysis of the 1982 events file shows that the vast majority of events in both drilling and production operations resulted only in minor personnel injury, small flash fires, or small oil spills.
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From page 66... ...
On the Gulf Coast the question of public confidence in MMS' role in the safety of OCS operations is a dormant issue. The gradual migration of the center of industry activity from shore to marshes and lakes and to the open sea, its current remoteness from population centers, and its pervasive importance to the Gulf Coast economy all have combined to make the attendant risks an accepted part of the local scene.
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From page 67... ...
Moreover, a violation record involving no more than the failure of a device to trip at its specified set point or the failure of a check valve to seal within the small tolerances specified by MMS, for example, does not necessarily translate into a poor safety record. Further, until more directly relevant data can be collected and collated effectively, it will not be possible to assess the impact of safety-related changes introduced into the offshore oil and gas industry.
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From page 68... ...
ALTERNATIVE 1: INCREASED INSPECTION ONSITE BY MMS This alternative, mirroring as it does the present program, was analyzed solely with respect to the potential impact of "more of the same." The negative elements of the present program probably would not be exacerbated, with the possible exception that an increased MMS presence on Gulf of Mexico platforms would lead operators to place even greater reliance on an expectation that MMS personnel will detect anything that is "wrong." In this event there would be a further clouding of the fact that the operator has ultimate responsibility for safety and a corresponding diminishment of operator safety consciousness. While in some cases the increased presence of enforcement personnel has a positive influence on public confidence, it seems unlikely that this step would be significant with regard to public perception of the MMS's effectiveness in ensuring the safety of offshore operations, given the limited public awareness of the nature of the agency's activity.
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From page 69... ...
Integrating the efforts of the MMS inspectors with those of the operators should reinforce the nrecent thnt c~f~tv is the responsibility of the operator; if no more than a shift in attitude results, the outcome should be a level of safety higher than that achieved with the present system. At the heart of this alternative is the commitment of time to an increased number of unannounced spot inspections, which will enable MMS inspectors to observe operating procedures more frequently and assess safety attitudes more accurately.
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From page 70... ...
These inspection are augmented by a Coast Guard oversight program of random announced inspections, a headquarters analysis of inspection reports filed by operator and Coast Guard personnel, spot inspections of facilities with poor safety records or questionable reports, individual investigations of worker complaints, and investigations of casualties.
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From page 71... ...
MMS responsibly could defer inspections of operators whose safety performance was superior, in order to concentrate on those encountering problems; or it could ease off inspections of categories of PINCs in which no problems were being encountered to concentrate on those that have posed safety hazards. This alternative, placing as it does an additional burden of accountability on operators and operating personnel, might diminish the accountability of individual MMS inspectors and their supervisors for the performance of detailed inspection tasks.
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From page 72... ...
With the reduction of their inspection duties, MMS inspectors would have time to perform the audit and safety analysis functions the committee described earlier as providing the MMS with better insight on operational safety on the OCS. In this case, however, they also would be required to conduct audits of the private inspection organizations.
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From page 73... ...
Substantially more MMS resources would be available for SpOt inspections and safety analysis activities, as noted in Chapter 4. But it is likely that the collection of valid, detailed data needed for those analyses would become more problematical, as the frequent direct contact between MMS inspectors and operating facilities and personnel was lost.
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From page 74... ...
However, use of the freed resources for additional spot inspections and a program of systematic safety analyses that are needed to address recurrent safety problems is an integral element of this alternative. The necessary resources for an ongoing safety analysis program and an enhanced spot inspection program would be made available by having MMS inspectors witness only a limited number of tests during the annual inspections of production facilities, in lieu of attempting to witness 100 percent of the tests in the PINC list as is now done.
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