Offshore Oil and Gas Regulatory Compliance 2016

In 2016, the U.S. Coast Guard conducted at least one inspection on 103 unique Floating Production Systems (FPS’) and Mobile Offshore Drilling Units (MODUs) that operated on the Outer Continental Shelf (OCS). Additionally, 49 fixed platform inspections were performed.

These inspections resulted in 222 deficiencies being written on FPS’ and MODUs and 100 deficiencies on fixed platforms. Fourteen OCS units (8 MODUs, 5 FPSs and 1 platform) received an operational control action as a result of a top-level deficiency being discovered.

Deficiency category breakdown is shown by the diagrams below.

Helping your company ‘Walk the Walk’ in response readiness

As a management consulting firm, Meridian assists our clients’ compliance with safety, environmental and quality management system standards. For example, we recently conducted an external review to verify that an organization’s internal quality system is based on ISO 9001:2015. Similarly, in enhancing our clients’ contingency preparedness, our Response Services Division provides Incident Command System (ICS) training and facilitates drills and exercises.  

In “Walking the Walk,” Meridian uses ISO 9001 and ICS processes and tools in managing our tactical operations.  Potential tactical operations, which Meridian may be asked to provide, include:

  • Armed Vessel Security
  • Direct Asset Response Team
  • Event Management
  • Executive Protection
  • Fixed Site Security
  • Oil / Hazardous Material Spill Response
  • Route/Convoy Security

The ISO-ICS integrated process starts with Meridian’s standard operating procedures and policies, which creates our framework. From there, Meridian has ensured its personnel have the required training and experience for the position they are assigned to. This includes becoming familiar with the Meridian Incident Management Handbook (MIMH), as well as completing our position-specific qualification requirements.

There are numerous moving parts when it comes to managing tactical operations. There is a constant flow of information. To ensure our readiness to respond, Meridian proactively developed Incident Action Plan (IAP) templates for various types of tactical operations. These templates incorporate lessons learned and best practices.  They serve as a 70% solution, which enables Meridian to respond to the needs of a client quickly and effectively.

From the moment a client requests our services, Meridian begins updating the appropriate template with the client’s specific information.  We assess and track the current situation.  We document the client’s objectives and priorities.  We identify resources and develop assignments.

By using ICS processes and tools, Meridian can make a seamless transition from managing routine activities to supporting crisis management while  easily assimilating into the client’s response management organization.

By having things well-organized and documented, it ensures continuity of operation.  Meridian upper management can quickly step in and effectively and efficiently complete the operation if an emergency arises and the project manager is unavailable.

Once an operation is complete, Meridian electronically archives the IAPs, so they can be referenced at a later point in time if needed. We update our IAP template.  This procedure is not only ISO compliant, but it also allows us to reference the documents as needed.  

Meridian Operational Planning Cycle for Managing Tactical Operations

 

Meridian.US Announces New Designated Person Services

Regulations, including International Safety Management Code and Towing Safety Management System, require a vessel operator to appoint Designated Person(s) that have the following responsibilities:
  • Ensuring the safety management system is implemented and continuously functions throughout management and the fleet.
  • Ensuring the safe operation of each vessel.
  • Providing a link between the Company and those on board.
  • Monitoring the safety and pollution-prevention aspects of the operation of each vessel and ensuring that adequate resources and shore-based support are applied, as required.
For companies looking for highly experienced contractors to supplement their staff, Meridian.us has senior-level personnel who can serve effectively as Designated Person(s).
For more information on Meridian’s Designated Person services, please contact Captain Hung Nguyen at (808) 282-4981 or hnguyen@meridian.us.

ISM Code and Risk Management

December 2012 – Grounding of MODU KULLUK in Alaska (courtesy of nytimes.com)

On December 31, 2012, the Noble Drilling-operated Mobile Offshore Drilling Unit (MODU) KULLUK went aground on the eastern coast of Sitkalidak Island, Alaska. Amid winds as high as 50 miles per hour and seas as high as 18 feet, 18-member crew had to be rescued by the U.S. Coast Guard (USCG). The USCG and the National Transportation Safety Board (NTSB) investigated the casualty. The USCG determined the most significant factor being the inadequate assessment and management of risks associated with a complex vessel movement during the winter in the unique and challenging operating environment of Alaska. The NTSB concurred with the USCG that the inadequate assessment of the risk for the planned tow resulted in implementation of a tow plan insufficient to mitigate that risk.

August 2016 – Grounding of TRANSOCEAN WINNER in western Scotland
(courtesy of bbc.com)

Almost four years later, we saw similar images of Coast Guard helicopter flying over the TRANSOCEAN WINNER, which was grounded in western Scotland. The casualty released approximately 12,000 gallons of diesel oil into the ocean. The UK Marine Accident Investigation Branch (MAIB) investigation into the grounding highlighted the lack of a contingency plan.

Both vessel operators are required to comply with the International Safety Management (ISM) Code. Section 1.2.2.2 requires a company to assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards. Inadequate assessment and management of risks would be considered a Major Non-conformity under the Code. Per Section 13.5, this may result in the issuing government’s withdrawal of the company’s Document of Compliance, i.e., its ISM-compliant vessels can no longer operate until the identified discrepancies are corrected.

Meridian.us has certified and experienced ISM Code Lead Auditors, who can assist your company with their internal audits and management review. For additional information, please contact Captain Hung Nguyen at (808) 282-4981 or hnguyen@meridian.us.

REGULATORY ADVISORY: Maritime Transportation Security Act (MTSA) Facility Access Control Discrepancy on the Rise

On May 4 the Coast Guard Office of Port & Facility Compliance released its 2016 Year in Review.

In 2016, the Coast Guard completed 6,002 MTSA annual and spot check examination activities. About a third of the enforcement actions are related to access control—a category that has doubled in two years.

Per Title 33 Code of Federal Regulations (CFR) 105.255, the facility owner or operator must ensure the implementation of security measures to:

(1) Deter the unauthorized introduction of dangerous substances and devices, including any device intended to damage or destroy persons, vessels, facilities, or ports;

(2) Secure dangerous substances and devices that are authorized by the owner or operator to be on the facility;

(3) Control access to the facility; and

(4) Prevent an unescorted individual from entering an area of the facility that is designated as a secure area unless the individual holds a duly issued TWIC and is authorized to be in the area.

For assistance with MTSA compliance, please contact Meridian.us at (251) 345-6776 or info@meridian.us.

REGULATORY ADVISORY: Proposed Manning Changes for Mobile Offshore Drilling Unit

Nearly seven years ago, on April 20, 2010, while conducting temporary well-abandonment activities in the U.S. Gulf of Mexico, the mobile offshore drilling unit (MODU) Deepwater Horizon experienced a series of events that resulted in explosions, fire, loss of eleven lives, sinking of the vessel, and the largest oil spill in the U.S. history.

There were many investigations in the aftermath of the disaster to determine causal factors and identify potential safety improvements to offshore oil and gas drilling. The Department of Homeland Security and The Department of the Interior conducted a joint investigation. All told, the Joint Investigation Team (JIT) held seven public hearings, called over 80 witnesses, issued more than 90 subpoenas, and collected over 400,000 pages of evidence.

Within the U.S. Coast Guard jurisdiction, the JIT recommended 52 safety improvements, on 80 percent of which the Commandant agreed to take action. One major recommendation was to implement regulatory changes that provide clear designation of the person in charge under both operating and emergency situations for all MODUs operating on the U.S. Outer Continental Shelf.

Additionally, in March 2013, the International Maritime Organization (IMO) began its investigation into the Deepwater Horizon casualty.  A proposed amendment to the MODU Code under consideration is “For units that use dynamic positioning systems as a sole means of position-keeping, the master should be designated as the person in charge at all times.”

On November 28, 2014, the Coast Guard published the Proposed Rules on Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems, which requires all MODUs be under the command of an individual holding an appropriate certificate of competency as a master issued by the Flag State authority.

For assistance with regulatory compliance, please contact Meridian Global Consulting at (251) 345-6776 or info@meridian.us.

  1. International Maritime Organization, Review the MODU CODE, LSA CODE and MSC.1/CIRC.1206/ REV.1, SSE 2/12 19 December 2014

  2. Federal Register, Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems; Proposed Rule, Vol. 79, No. 229, November 28, 2014

For more information please contact Meridian.us at (251) 345-6776 or info@meridian.us.

Oil Spills and Emergency Preparedness on the 28th Anniversary of the Exxon Valdez

On March 24, 1989 at approximately 12:04 AM, the single-hull tanker EXXON VALDEZ with a full load of crude oil grounded on Bligh Reef in Prince William Sound, Alaska. Approximately 11 million gallons of oil were spilled into the pristine waters of Prince William Sound.

In terms of volume released, the spill is the second largest in U.S. waters, after the 2010 Deepwater Horizon incident. Prince William Sound’s remote location, accessible only by helicopter, plane, or boat, made response efforts difficult and severely taxed existing plans for response.

The EXXON VALDEZ spill led to enactment of the Oil Pollution Act of 1990 (OPA 90), which improved oil spill prevention, response, and restoration by providing greater environmental safeguards by mandating contingency planning.

Meridian has many technical experts and experienced responders who successfully implement OPA 90. Depending on the needs of your organization, our regulatory planning staff can assist with development of all or partial plans, including:

  • Facility and Vessel Response Plans
  • Integrated Contingency Plans
  • Spill Prevention Control and Countermeasure Plans
  • Emergency Response Plans
  • Tactical Response Plans

We provide training in the following areas:

  • NIMS ICS 100b/200b, ICS 300, 320, 400, 410, 420, 440, Executive Level and Section Specific
  • HAZWOPER (8HR Refreshers)
  • USCG, EPA, BSEE, and DOT Qualified Individual

We offer a wide range of drill and exercise programs to meet your organization’s preparation and training needs.  These include:

  • Tabletops
  • Worst Case Scenario Equipment Deployment
  • National Preparedness for Response Exercise Program
  • Qualified Individual Notification

Our team can also provide response expertise to oil spills across the U.S. and Canada with:

  • Spill Management Team Partial Team Augmentation or Full Team Deployment
  • Qualified Individuals
  • Operations/Planning/Finance/Auditing/Documentation
  • Government Liaison/Public Information/Safety
  • GIS Services and Trajectories

For additional information on our response services, please contact Meridian.us at (251) 345-6776 or info@meridian.usMeridian will make sure you are ready.