The Bureau of Safety and Environmental Enforcement (BSEE) and the U.S. Coast Guard have signed a memorandum of agreement (MOA) that lists the specific responsibilities of each agency in the regulatory oversight of mobile offshore drilling units (MODUs). 

The MOA cites the definition of an “MODU” as a vessel capable of engaging in drilling operations for the exploration or exploitation of subsea resources.  The vessel is identified as one that is seagoing and 300 or more gross tons and self-propelled by motor; seagoing and 100 or more gross tons and non-self-propelled; or more than 65 feet in length and propelled by steam.

2012 MOU

The MOA follows up on a November 2012 memorandum of understanding (MOU) in which the two agencies agreed on a “vision statement” to coordinate regulation and enforcement of activities, facilities, and units on the Outer Continental Shelf (OCS).  The MOU noted that MOAs would be subsequently developed to provide specific guidance on each agency’s role and shared responsibilities.

Vessels vs. drilling
In general, the Coast Guard enforces all regulations relating to vessels and matters promoting safety of life and property.  The Coast Guard also oversees unregulated hazardous working conditions on the OCS.   When an MODU is temporarily attached to the seabed, the BSEE regulates well operations, including drilling, completions, workover, production, and decommissioning. 

Coast Guard

The MOA lists 38 specific systems that come under the authority of the Coast Guard.  These include:

• Structural integrity
• Modifications for construction, and repair requirements
• Mooring and anchoring equipment
• Marine engineering systems
• Decks, fuel handling, and storage
• Fire-fighting water pumps, piping, hose reels, and monitoring equipment
• Prevention of unauthorized discharges to the marine environment
• Petroleum and other product transfers to and from a vessel
• Structural inspection requirements
• Emergency evacuation plans; and
• Safety management systems (per 33 CFR 96).

The BSEE

The BSEE is assigned 24 specific systems, including:

• Drilling systems
• Blowout prevention equipment and control systems
• Cementing systems
• Drilling floor electrical equipment
• Pipeline operations and components (certain pipelines are subject to BSEE MOUs with the Pipeline and Hazardous Materials Safety Administration)
• Pollution associated with exploration, development, production, and transportation of oil and gas and sulfur; training of drilling personnel
• Inspection and testing of all drilling equipment; and
• Safety and environmental management systems (per 33 CFR 96).

The agencies note that all provisions in the MOA are subject to the availability of personnel and funds.

Click here for the MOA.

Click here for the November 2012 MOU.