Posts Tagged ‘BSEE’

The most common causes of offshore fatalities and serious injuries, falls and being struck by equipment, receive little media attention because there is no blowout, oil spill, or fire. However, these are often the most difficult types of incidents to understand and prevent. Human and organizational factors predominate, and prevention is dependent on a strong culture that emphasizes worker engagement, awareness, teamwork and mutual support, effective training and employee development, risk assessment at the job, facility, company, and industry levels, stop-work authority, innovation, and continuous improvement.

This new BSEE Safety Alert addresses such a fatal incident on the Pacific Khamsin drilling rig, and makes recommendations that have widespread applicability.

Incident summary:

While unlatching the lower Marine Riser Package from the Blowout Preventor in preparation for ship relocation, a crewmember was lifted into the air after being struck by a hydraulic torque wrench (HTW), hitting a riser clamp approximately six feet above the elevated work deck before falling to the rig floor. The crew member was given first aid and transported to the drillship’s hospital, where he was later pronounced deceased.

In an upcoming post, BOE will provide historical fatality data by cause and operations category.

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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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“Former U.S. Rep. David Rivera, a well-connected Florida Republican, has been arrested on federal charges that include failing to register as a foreign agent. The case centers on Rivera’s signing of a $50 million contract with Venezuela’s government in early 2017, and his subsequent attempts to thaw Venezuela’s icy relationship with the U.S.”


Perhaps Mr Rivera’s conduct at a 2012 hearing on Cuban offshore drilling was a hint of things to come. Mr. Rivera inappropriately pressed BSEE, represented by Lars Herbst, to find ways to “bleed” Repsol should there be an incident while they were drilling in Cuban waters.

So, we need to figure out what we can do to inflict maximum pain, maximum punishment, to bleed Repsol of whatever resources they may have if there is a potential for a spill that will affect the U.S. coast. So, I hope you will look into that and verify that for us.”

Congressman David Rivera, 2012 Hearing on Cuban offshore drilling

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David Scarborough, Island Operating Co. employee who died in the crash.
  • The bodies of the 4 victims have been recovered.
  • The 3 offshore workers were employees of Island Operating Co., a production contractor. The pilot worked for Rotorcraft Leasing Company, the owner of the Bell 406 helicopter that crashed. The platform is owned by Walter Oil and Gas, the operating company.
  • A preliminary FAA report confirms that the helicopter crashed onto the helideck during takeoff, breaking apart and falling into the Gulf.
  • 4 passengers had been dropped off at the platform before the fatal takeoff. Presumably there were witnesses to the incident.
  • According to the FAA report, the platform was located at West Delta Block 106. Per the BOEM platform data base, the platform was installed in 1994, is in 252′ of water, and is continuously manned.
  • Per the BSEE INC data base, the platform had not been cited for any violations since 2016.

Lacy Scarborough, wife of victim David Scarborough, is pregnant. Tragically, the couple lost their first child in an accidental drowning in March. David was heading home for the holidays after completing his 2 week shift on the platform. He had worked offshore for 8 years. Per Lacy, David’s last message was that he was taking off and would be home soon.

The only other victim who has been identified is Tim Graham of Quitman, Mississippi.

I trust that the NTSB will conduct a timely and thorough investigation, and hope they consider offshore helideck oversight, both in terms of industry programs and government regulation. The most recent Coast Guard – BSEE MOA for fixed platforms added to helideck regulatory uncertainty by assigning decks and fuel handling to BSEE and railings and perimeter netting to the Coast Guard. This is the antithesis of holistic, systems-based regulation.

More on the crash: ominous message, update #3

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  • This was the second crash for the operator (Rotorcraft) in two weeks, its second fatal for the year, and the third in the Gulf of Mexico since October.
  •  On December 15, a Rotorcraft Leasing Bell 206L-4 with three aboard crashed while taking off from a platform 35 miles south of Terrebonne Bay, Louisiana. In that accident, one of the helicopter’s skids caught under the helipad’s perimeter railing, and the aircraft fell into the water below. (We have concerns that yesterday’s incident may have had a similar cause.)
  • On October 26, a Westwind Helicopters Bell 407 with three aboard crashed into the Gulf 25 miles south of Morgan City, Louisiana after the pilot apparently experienced an in-flight medical emergency and told his front seat passenger he “was not going to make it” and then slumped over the controls. The front-seat passenger then attempted to gain control of the helicopter prior to the water impact. After several hours, both passengers were rescued with serious injuries, but the pilot died. (This is why I never liked single pilot aircraft.)
  •  Another of the company’s Bell 407s crashed on January 14 near Houma, Louisiana, killing both occupants. A witness to the accident said the helicopter appeared to dive nose-down into terrain. To date, investigators in that accident have not discovered any mechanical or structural failure that would account for that crash. 

Get to work HSAC, NTSB, BSEE, USCG, FAA, and all others who are involved with offshore helicopter safety.

Not a word about this tragedy on the Rotorcraft, Walter Oil & Gas, or BSEE websites, and no public statements can be found. At a minimum, one would have expected condolences to the families and a commitment to find out what happened and prevent recurrences.

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As we approach the end of 2022, I’m still waiting for:

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The comment (pasted below) by the trade associations asserts that BSEE ignored the requirements of the National Technology Transfer and Advancement Act (NTTAA).


  • BSEE and its predecessors (MMS and the Conservation Div. of USGS) have been incorporating industry standards since 1969, 27 years prior to the enactment of the NTTAA (1996).
  • 127 standards are currently incorporated into the BSEE regulations. Does this imply ignoring the NTTAA?
  • The keystone of the BOP regulations, API Standard 53, is cited in 250.730, the very section of the rule that is under discussion. Seven other industry standards are cited in that section of the rule. Does this imply ignoring the NTTAA?
  • Regulators cannot cede their authority to standards development organizations. If a standard is outdated or deficient, the regulator must address the issues of concern.
  • Deviations between provisions in the regulations and API Standard 53 are expected and specifically provided for in 250.730 as follows: “If there is a conflict between API Standard 53 and the requirements of this subpart, you must follow the requirements of this subpart.
  • For years, the production safety system regulations specified different leakage rates for surface and subsurface safety valves than those allowed in the API standards. An MMS research project addressed and helped resolve these differences.
  • While essential to safety and regulatory programs, standards are not a panacea; nor is the standards development process without weaknesses. One need only consider the case of the delayed cementing (zonal isolation) standard to appreciate both the importance of standards and the potential weaknesses in the development process.

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Per Regulations.gov. BSEE received 30 comments on the proposed revisions to the Well Control Rule, 25 of which have been posted. The other comments were presumably deemed inappropriate for posting per the guidance at Regulations.gov.

Two of the responses were submitted collectively by 8 industry trade associations. Only 3 operating companies commented and their comments largely echoed the trade association responses. Only 2 drilling contractors responded independently. Four service and engineering companies commented.

Three environmental organizations, a group of Atlantic states, a government watchdog, and a law school provided comments.

Three individuals and 4 anonymous or unknown parties commented.

Below is a list of the respondents preceded by their comment identifiers. More to follow.

  • 0003 Foley Engineering
  • 0004 Frank Adamek
  • 0005 Anonymous
  • 0006 Project on Government Oversight (POGO)
  • 0007 E.P. Danenberger
  • 0008 Chevron
  • 0009 B. Mercier
  • 0010 Anonymous
  • 0011 Anonymous
  • 0012 Foley Engineering (2nd comment)
  • 0013 HMH (?)
  • 0014 NYU School of Law
  • 0015 Beacon Offshore
  • 0016 Shell
  • 0017 Diamond Offshore
  • 0018 7 industry trade associations: API, IADC, IPAA, NOIA, OOC, EWTC, USOGA
  • 0019 NOV (service company)
  • 0020 NRDC
  • 0021 Oceana
  • 0022 Transocean
  • 0023 Louisiana Mid-Continent Oil & Gas Association
  • 0024 Kinetic Pressure Control Limited
  • 0025 Attorneys General of Maryland, Connecticut, Maine, Massachusetts, New York, and North Carolina
  • 0026 Ocean Conservancy
  • 0027 Rigscope International

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On Monday, the offshore world lost Mike Conner, an outstanding engineer and a major contributor to the success of the US offshore program.

Mike is the person most responsible for the Deepwater Operations Plan (DWOP), a pioneering safety-case approach to regulating deepwater oil and gas development. The DWOP program was initiated 30 years ago and facilitated deepwater production at a time when there were no deepwater-specific regulations or standards. Innovative tension leg platform, compliant tower, spar, production semisubmersible, and subsea projects would not have been possible without the DWOP program. 93% of Gulf of Mexico oil production and 76% of the gas is now attributable to deepwater production facilities. Thanks in large part to the DWOP program, these facilities have had a nearly flawless safety and environmental record.

While his obituary is no yet available, this link announces Mike’s well-deserved selection for the OTC Heritage Award in 2017, and provides good information on Mike and his career.

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Comments on the proposed revisions to BSEE’s Well Control Rule are due on Monday (11/14/2022). My comments were submitted yesterday, and I have attached a copy for those who might be interested. Bud

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