Those of us who were involved with OCS oil and gas operations in the 1970s remember the heated battles between Exxon and Santa Barbara County that led to the installation of the infamous Offshore Storage & Treatment (OS&T) facility in Federal waters. This was the first floating production, storage, and offloading facility (FPSO) in US waters by 3 decades!
In light of Sable’s difficult (bordering on impossible) onshore permitting challenges, the company resurrected the OS&T option in a recent presentation to investors (pertinent slide pasted above). The extent to which this is purely a tactical maneuver remains to be seen, but this option would be very difficult to execute, even with a supportive Federal regulatory environment.
Updatedincident tables for OCS oil and gas operations. The most recent data are nearly 2 years old. The public has a right to timely information on the type of incidents that are occurring, the operating companies, and the resulting casualties, pollution, and property damage.
A summary of incidents associated with the OCS wind program. From press reports, we know about the fatality during Empire Wind construction. What other incidents have occurred to date?
Earlier this week a tree service company was removing some large branches in our backyard. The 2 young workers stopped the job before they finished. They knocked on our door and told me that their foreman was off and they were uncomfortable tackling a large, high branch without him and a crane operator. They would come back with a full crew.
I congratulated them and told them they did exactly the right thing. I told them I was involved with offshore safety and many serious incidents would have been prevented if workers, with their employers encouragement, had been more assertive in stopping work. Developing that type of culture takes time and requires strong leadership and consistent, unambiguous messaging. Leadership matters, both at the site and in the office!
The Macondo well is a worst case example on many fronts, including the reluctance or inability of management and workers to stop taking actions that increased well control risks. Given the narrow pore pressure/fracture gradient, the prudent decision would have been to set a cement plug in the open hole and carefully assess next steps. However, delays and cost overruns were the overriding concerns, and well construction continued despite the long list of issues described here. Sadly, we know how that worked out.
Even after the well started to flow, the crew had time to actuate the emergency disconnect sequence and avert disaster. However, some combination of deficient training, uncertain authority, and fear of repercussions prevented that from happening.
Be it a small tree service company or a major oil company, safety culture development is a journey that has no end point and requires continuous leadership from everyone in the organization.
Attached is the Dept. of the Interior’s Semiannual Regulatory Agenda (9/22/2025). BSEE and BOEM decommissioning rules are excerpted below.
Of particular concern is the revised BOEM regulation (107) that “would reduce the amount of supplemental financial assurance required from oil gas, and sulfur lessees operating on the OCS.” See our previous post on this regulatory action. Note that a proposed rule is expected to be published by year end.
REVISIONS TO DECOMMISSIONING REQUIREMENTS ON THE OCS [1014–AA53] Legal Authority: Outer Continental Shelf Lands Act, 43 U.S.C. 1331 to 1356a Abstract: This proposed rule would address issues relating to (1) idle iron by adding a definition of this term to clarify that it applies to idle wells and structures on active leases; (2) abandonment in place of subsea infrastructure by adding regulations addressing when BSEE may approve decommissioning-in-place instead of removal of certain subsea equipment; and (3) other operational considerations. Timetable: NPRM ……………… 07/00/26 NPRM Comment Period End: 10/00/26
RISK MANAGEMENT AND FINANCIAL ASSURANCE FOR OUTER CONTINENTAL SHELF LEASE AND GRANT OBLIGATIONS [1010–AE26] Legal Authority: 43 U.S.C. 1331, OCS Lands Act; E.O. 14154, Unleashing American Energy Abstract: This proposed rule would rescind BOEM’s final rule ‘‘Risk Management and Financial Assurance for OCS Lease and Grant Obligations.’’ The proposed rule would revise the criteria for determining whether oil, gas, and sulfur lessees, right-of-use and easement grant holders, and pipeline right-of-way grant holders are required to provide financial assurance above the current minimum bonding levels to ensure compliance with their Outer Continental Shelf (OCS) Lands Act obligations. This rule, if finalized, would reduce the amount of supplemental financial assurance required from oil gas, and sulfur lessees operating on the OCS and would support the goals of E.O. 14154; Timetable: NPRM ……………… 01/00/26
How can AI and emerging technologies be used in risk management trending and operations?
Why are we not learning from accidents?
Breakthroughs in investigation techniques and sharing
The first IRF Conference was held 20 years ago in London followed by the 2007 conference at the Trump International Resort in Miami (little did we know 😀). More historical background.
The informed, diverse viewpoints about managing and regulating offshore operations sets these conferences apart from your typical professional events. The 2025 conference is highly recommended for those interested in offshore operations, risk mitigation, and regulatory policy.
The table below captures the shorter public comments and provides links to the longer ones. They are listed in the order they were posted on Regulations.gov.
commenter
summary/link
anonymous
I recommend under no circumstance that we allow the onsite worker to approve the commingling of bore holes because there is extreme significant safety and environmental hazards that exist. The best alternative is to have an environmental engineer and environmental scientist approve any commingling
…your regulatory proposal is inconsistent with the federal law, the best available science on protecting the health and lives of children, and the legal mandate that agency decision-making does not deprive children of their fundamental constitutional rights…
I support updating the regulations to align with the One Big Beautiful Bill Act, but I encourage BSEE to ensure that safety standards and environmental protections remain the highest priority in all commingling approvals. Clear guidance for industry compliance and transparent public reporting would also strengthen confidence in this rule.
Ananda Foster
Regulations need to catch up with technology and we have not had a chance to do that yet. If you allow them on throttle access, they will destroy it. We all rely on the ocean, how can you do this to your own constituents?
Legislatively dictating well construction, completion, or operational approvals is a redline for me, and I continue to strongly believe the downhole commingling rule should be published as a draft for public review and comment.
The only industry comments are from API and bp America. Both support the direct final rule, and I respect their position. My main quarrel is with the legislative action that put us in this position.
I have had many disagreements with API members over the years, but the dialogue has always been professional. Technical and policy disagreements are healthy for the OCS program, and I will continue to raise potential issues and concerns on this blog.
With regard to bp, I have been impressed by their commitment to the Gulf of America, as summarized in this excerpt from their comments:
John Smith shared the attached letter from Senators Adam Schiff and Alex Padilla, and members of the California congressional delegation. The letter questions BSEE’s inexplicable announcement about the resumption of Santa Ynez Unit (SYU) production. That announcement boasted:
“This is a significant achievement for the Interior Department and aligns with the Administration’s Energy Dominance initiative, as it successfully resumed production in just five months.“
BSEE’s announcement, which has not been explained and is still featured on their homepage, served only to further complicate the resumption of production from the SYU, which has reserves in excess of 500 million barrels.
ANP (Agência Nacional do Petróleo, Gás Natural e Biocombustíveis) nicely organizes and presents Brazil’s production data. Their 30-page monthly bulletin includes field specific information. The US does not have an equivalent publication.
Brazil produced 5.16 million boe/day in July, 97.7% of which was from offshore fields. Oil production was 3.959 million bopd, making Brazil the no. 1 offshore producer. Brazil’s offshore oil production is approximately the equivalent of the combined offshore production of the US and Norway.
How important is Brazil’s offshore sector? Their offshore production is from 568 wells. Assuming all 568 wells were actively producing oil wells (no gas or service wells), the average production rate was ~7000 bopd plus associated gas. More than 10 times as many wells (6033) produced Brazil’s limited onshore production. So <10% of Brazil’s wells (all offshore) account for nearly 98% of their production.
How important is pre-salt exploration and production technology? Pre-salt production (only 169 wells) accounted for 79.1% of the national total of 5.16 million boe/d.This means that pre-salt wells averaged 24,000 boe/d.
Room for improvement? 2.9% of the produced gas was flared (queima) in July (first chart). Over the past year, Brazil’s flaring volumes ranged from 2.2 to 3.9% of gas production. The fact that nearly all of their gas production is from oil wells, the growth in production (2nd chart), and the higher upset potential (perhaps) for FPSOs, may help explain the relatively high flaring numbers. 1.3% of Gulf of America gas production was flared or vented in 2024 (still too high). <1% flaring rates should be the target for all offshore producers.
…and should be an integral part of Job Safety Analyses!
According to BSEE, there is a recurring trend of equipment misuse contributing to fire and explosion hazards during offshore oil and gas operations in the Gulf of America.
Workers have used tools not rated for electrical work on live circuits (Figure 1) and mismatched hydraulic or pneumatic tools for high-pressure systems (Figure 2). In several cases, non-intrinsically safe hand tools were used in explosive atmospheres, including mudrooms and drilling floors.
Bud's Offshore Energy (BOE) 