Following the Deepwater Horizon spill and investigations that found that federal inspections and enforcement of outer continental shelf (OCS) energy activities were lax in the extreme, the government has taken multiple steps to strengthen its policing role. One of the best ways to keep track of how this new initiative is rolling out is to review the Bureau of Safety and Environmental Enforcement’s (BSEE) Enforcement Newsletter. The first issue of this concise, 4-page quarterly appeared early this year, and the second issue has just been published. Issue 2, covering January 1, 2012, through March 31, 2012, contains the following items of interest:
- For the first quarter of 2012, BSEE performed a total of 3,857 OCS inspections, including 3,588 in the Gulf of Mexico, 267 in the Pacific region, and 2 in the Alaska region. Total inspections are down by about 90 over those conducted for the fourth quarter of 2011. As of March 31, 2012, there were 3,107 production platforms in the Gulf of Mexico and 23 in the Pacific region. The Alaska region has one federal/state production operation.
- Safety alerts, which inform the offshore oil and gas industry of the circumstances surrounding an accident or near miss, were issued as Failure to Properly Bleed Tubing Hanger Void Results in Injury and Unplanned Emergency Disconnect Sequence (EDS) of the Lower Marine Riser Package. Both alerts concerned incidents that occurred in the Gulf of Mexico.
- A total of 693 incidents of noncompliance (INC) were issued, with 666 in the Gulf region. The majority of INCs were handed out for general reasons, followed by 220 for production; 39 for personal safety; 34 for measurement and site security; 26 for pollution; 23 for pipelines; and 20 for electrical.
- For the 3-month period, BSEE closed two civil penalties for a total of $65,000. One penalty for $50,000 involved two open holes or fall hazards allegedly discovered on a rig by BSEE inspectors. Currently, the maximum civil penalty rate for violations of the Outer Continental Shelf Lands Act is $40,000 per violation per day. For the fourth quarter of 2011, BSEE received $340,000 in penalty payments.
The enforcement newsletters are available at BSEE's website.