Friday, April 22, 2011

Bryant’s Maritime Blog–22 April 2011–Special

Headlines: Deepwater Horizon – Report of Investigation

April 22, 2011 - Special

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USCG – Deepwater Horizon – Report of Investigation

The USCG-BOEMRE Joint Investigation issued a news release stating that it posted Volume I of the Deepwater Horizon – Report of Investigation. This volume addresses only issues under jurisdiction of the US Coast Guard. Volume II, addressing issues under the jurisdiction of the Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE), will be posted separately at a later date. This 288-page report is preliminary, in that it has yet to be reviewed and acted upon by the Commandant. The findings cover five aspects of the disaster, including (1) explosions on the MODU Deepwater Horizon; (2) the resulting fire; (3) evacuation of personnel from the MODU; (4) the flooding and sinking of the MODU; and (5) the safety systems of the MODU and its owner. This report does not include an analysis of what led to the loss of well control or other issues within BOEMRE jurisdiction.

While the report includes 61 conclusions, 54 safety recommendations, and nine administrative recommendations, a major root cause of the casualty relates to the safety systems. The following quote is particularly pertinent:

This “maritime safety net” system, however, failed to prevent this disaster. The investigation revealed that DEEPWATER HORIZON and its owner, Transocean, had serious safety management system failures and a poor safety culture. It has also shown that [Republic of the Marshall Island’s] oversight of safety issues was inadequate and created an environment in which the casualty could occur. These failures [also] have exposed a weakness in the United States regulatory regime in which the U.S. Coast Guard is called upon to conduct only limited oversight of foreign-flagged vessels engaged in OCS activities.

With regard to the blowout preventer (BOP), the report found that, contrary to the manufacturer’s guidelines which called for inspection and certification of the BOP every three to five years, Transocean did not arrange to have the Deepwater Horizon BOP recertified for over ten years. In addition, key BOP parts had “significantly surpassed the recommended recertification period” and needed to be replaced. (4/22/11).

Personal Note: An initial reading of this report indicates that, within its constraints, it is generally very thorough and seldom pulls any punches. Room for improvement (sometimes quite significant) is found with regard to all parties. As pointed out in the report, the US Coast Guard needs to be much more involved in oversight of foreign-flagged vessels operating on the US outer continental shelf (OCS). As this tragic incident has demonstrated, the consequences of failure are too high for the risks to be treated casually.

One potential deficiency in the report relates to the concern expressed therein regarding the dual command structure on the Deepwater Horizon. The master was in charge when the MODU was underway or in an emergency situation, while the OIM (offshore installation manager) was in charge when the MODU was latched on to the well. As shown in this casualty, when and how command is transferred from the OIM to master can be unclear, and more so when the MODU maintains its position dynamically, rather than through the use of anchors. Surprisingly, the report does not mention the Coast Guard’s 1985 marine casualty report regarding the loss of the drillship Glomar Java Sea. That marine casualty report specifically recommended that a single individual be vested with the sole responsibility for marine safety and evacuation of personnel on all MODUs. That recommendation was approved by the Commandant and a rulemaking was initiated to formalize that requirement. Unfortunately, the rulemaking fell by the wayside. As pointed out in this Report, the current regulation in this regard is vague. It is time to dust off that old rulemaking project and impose a “sole responsibility” requirement on all MODUs (foreign and domestic) operating on the US OCS.

If you have questions regarding the above items, please contact the editor:

Dennis L. Bryant

Bryant’s Maritime Consulting

4845 SW 91st Way
Gainesville, FL 32608-8135



© Dennis L. Bryant – April 2011

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1 comment:

  1. Thank you for your insight Dennis, and for mentioning the Glomar Java Sea. At one point the CFRs clearly stated that the OIM of a "drillship" must have a master's license. However, I believe this only pertains to US flag drillships (of which the Glomar Explorer is the only one I know of). This allows foreign flagged drillships (operting under a "Certificate of Compliance") in the US Gulf of Mexico to "get away" with the dual command person in charge system.

    There are clearly some improvement opportunties here to clarify the roles of the master and OIM.