Bud's Offshore Energy (BOE)

The OCS Orders were the foundation for the current operating regulations in the US and many states and other countries. They were logically organized, easily updated, and published for public comment prior to being finalized.

I have an email message indicating that the first OCS Order No. 1 (Identification of Wells, Platforms, and Structures) was signed on 1/31/1957 and the first OCS Order No. 2 (Drilling) dates back to 2/3/1958! (If anyone has access to the actual documents, please let me know.) The orders were developed much further in the 1970s and 1980s.

Contents of the 1/1980 Atlantic Orders:

• OCS Order No. 1: Identification of Wells, Platforms, Structures, Mobile Drilling Units, and Subsea Objects
• OCS Order No. 2: Drilling Operations
• OCS Order No. 3: Plugging and Abandonment of Wells
• OCS Order No. 4: Determination of Well Producibility
• OCS Order No. 5: Production Safety Systems
• OCS Order No. 6: Well Completions and Workover Operations
• OCS Order No. 7: Pollution Prevention and Control
• OCS Order No. 8: Platforms and Structures
• OCS Order No. 9: Oil and Gas Pipelines
• OCS Order No. 10 (reserved)
• OCS Order No. 11: Oil and Gas Production Rates, Prevention of Waste, and Protection of Correlative Rights
• OCS Order No. 12: Public Inspection of Records
• OCS Order No. 13: Production Measurement and Commingling

You can view the full set of 1977 Gulf of Mexico OCS Orders here

There has been much discussion, particularly since the 1988 Piper Alpha tragedy, regarding the optimal approach to offshore safety regulation be it prescription, goal setting, safety cases, management systems, or some combination, and how to best influence facility, company, and industry safety culture.

My personal view is that the quality and type of regulations are not nearly as important as the people implementing them. My take:

• Good regulators are more important than good regulations and are the key to a successful regulatory program. 
• Regulators must understand and be committed to their organization’s mission and the strategy for achieving that mission. 
• While they should have a good understanding of the activities that they regulate, their focus is on challenging operators, not directing them. 
• Regulators should audit operator activities and carefully review incident and performance data.  They should identify problems and concerns, but should not direct solutions. 
• Safety leaders should be applauded and poor performers should be penalized. 
• The quality of regulators is more important than the quantity. 
• Internal and external communication and collaboration are critical to their success.
• Management should ensure that regulators are able to focus on their mission and that organizational distractions are minimized.