Archive for the ‘Health’ Category

BSEE has posted the 2021 incident data for US OCS oil and gas operations. While the 13 month publishing lag is disappointing, the spreadsheet (below the table at this link and attached at the end of this post) appears to be comprehensive and complete.

Of the 8 fatalities in 2021, 6 are classified as “non-occupational” and are thus not included in the 2021 fatality count (see table below).

The 2 occupational fatalities are the result of falling metal plates on a drilling rig and the release of casing pressure on a production platform. These fatalities are still being investigated.

The 6 non-occupational fatalities on OCS facilities also merit further attention. While historical data on health-related OCS fatalities are not readily available, 6 such fatalities seems high relative to past experience, particularly given that the total number of hours worked has declined by more than 50% since 2011. Are these and other health related questions being considered?

  • Were covid or covid related health issues a factor?
  • Are health screening programs sufficient, particularly for contractors? Contractors are 80% of the workforce but accounted for 100% of the 2021 fatalities?
  • Are offshore medical care and evacuation capabilities sufficient?

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7 cadets ordered off Coast Guard Academy campus over vaccine status. “They were escorted to the gate like they were criminals or something,” the lawyer, Michael Rose, told the newspaper.

Even those of us who are fully vaxed acknowledge the vaccines’ uncertain efficacy and risks, and the many issues with the CDC guidance and Covid protocols. Military personnel must comply with orders, but questionable orders should be revised as new information becomes available.

Regulators know that regulations, policies, and practices cannot be static. As we learn, we update and improve. Enforcing outdated guidance is just a power play, and demonstrates rigidity not competence. The Coast Guard understands all of this, so their decision to evict the cadets is especially disappointing.

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Although OSHA is withdrawing the Vaccination and Testing ETS as an enforceable emergency temporary standard, OSHA is not withdrawing the ETS to the extent that it serves as a proposed rule

OHSA Notice

Should we call the proposed rule an ETS variant?

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Oil and gas workers’ union, Unite Scotland, has demanded intervention by the Scottish government in response to Canadian Natural Resources (CNR) International introducing mandatory vaccinations, calling these measures “draconian.”


As previously reported, a Norwegian union criticized the absence of consultation before Aker BP imposed vaccine requirements at their facilities.

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This should not surprise experienced OSHA regulators given the absence of clear legislative authority.

Offshore regulators in the US have used “work-arounds” in the form of Notices to Lessees, Conditions of Approval, and other types of guidance documents. However, there was a general understanding that requirements imposed by these methods would not survive legal challenges unless they were clearly authorized by legislation or regulations. Most work-arounds aren’t challenged because the regulatory authority is reasonably clear, their issuance is at least minimally acceptable to the regulated industry, or the perceived cost of challenges exceeds the cost of compliance.

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A Norwegian union representing offshore oil and gas workers has criticized Aker BP’s process to introduce a Covid-19 vaccine mandate for its offshore employees.


“We agree that we must protect our employees and our suppliers in the best possible way, but it also requires that we are involved in how it should happen and how our employees and suppliers are taken care of in this process.”

Ingard Haugeberg, Industri Energi

Seems like a reasonable position on the part of the workers. As previously reported, many US oilfield workers are skeptical of the vaccine mandate and have warned that they will quit.

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Vaccine mandate revived.

WSJ story on oilfield workers. Highlights:

  • Many oil workers are skeptical of the mandate and have warned they will quit
  • Ann Fox, chief executive of Nine Energy Service estimates that <15% of the company’s field workers are vaccinated.
  • Justin Clark, a field services manager understands why workers resist:

“I don’t like to be forced to do anything. I almost want to just do the opposite when someone tells me, in that manner, you’ve got to do this.”


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They extended the comment period. (Only an old regulator would find this amusing. Love OSHA’s panache 😃)

The ETS on Vaccination and Testing was published in the Federal Register on November 5, 2021. The ETS also acts as a proposal for a permanent standard and OSHA has decided to extend the comment period for that rule by 45 days. Written comments on any aspect of the ETS must now be submitted by January 19, 2022


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and they will presumably do so with an emergency final rule. This will be interesting. Over-under on the days until publication? Number of public comments?

And since the Coast Guard functions as OSHA on the Outer Continental Shelf, will they be enforcing the offshore industry’s compliance with this mandate? BSEE inspectors?

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A Coast Guard MH-65 Dolphin helicopter crew from Air Station Houston, Texas, medevacs an oil rig crew member experiencing a cardiac event on the Hoover-Diana oil platform, 150 miles east of Corpus Christi, Texas, Aug. 19, 2021. The helicopter crew successfully transported the man to the University of Texas Medical Branch in Galveston, Texas, in stable condition. (U.S. Coast Guard video, courtesy Sector/Air Station Corpus Christi)

US Coast Guard

But what happened to industry medevac capabilities? Or is this simply a matter of Hoover-Diana’s isolation?

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