Bud's Offshore Energy (BOE)

The Center for Offshore Safety (COS) was established in response to a recommendation by the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling for improved self-regulation by the offshore industry. The Commission supported the creation of a non-profit, industry-funded organization similar to the Institute of Nuclear Power Operations, to promote the highest levels of safety and operational excellence. 

The COS has been effective in strengthening corporate Safety and Environmental Management Systems, influencing the industry’s safety culture, and sharing best practices and lessons learned. These are important accomplishments.

The COS has fallen short in gathering the data needed to assess the offshore industry’s safety performance. As is the case with most voluntary reporting programs, data completeness and accuracy issues limit the significance of COS performance reviews.

Observations regarding the most recent COS Offshore Safety Performance Report follow:

• The COS uses accepted performance indicators and a logical classification scheme.
• COS reports that their members accounted for 78% of OCS oil and gas activity in 2024. This is accurate when cross-checked with BSEE hours worked data. However, the % of hours worked is not a good measure of the % of incidents reported in any category.
• Companies not participating included important operators like LLOG, Cantium, Walter, and W&T, a host of smaller Gulf independents, the 2024 violations leader (by a wide margin) Cox, and troubled Fieldwood. (See Fieldwood’s 2021 and 2022 performance.)
• Only two drilling contractors – Helmerich & Payne and Valaris – are members. Major contractors like Noble, Transocean, and Seadrill are not members. Their incidents will thus not be reported if they are not working for a COS member.
• No production contractors are COS members. These companies conduct most of the platform operations on the shelf, where many of the lease operators are not COS members.
• Pacific and Alaska Region operators do not participate.
• Looking only at fatalities (table below), the most important and easily verified incident category, there are troubling omissions:
  • COS reports no 2024 fatalities when in fact there was a fatality during an operation for a COS member.
  • COS reports no 2022 fatalities when there were actually five. A workover incident took the life of one worker, and four died in a helideck crash on an OCS platform. In both cases, the facility operator was a non-member company.
  • COS records one 2021 fatality, but fails to include a 2021 Fieldwood fatality. There were also 6 “non-occupational” fatalities on OCS facilities in 2021, as classified by BSEE. Given the importance of worker health (the H in HSE), such a high number of non-occupational fatalities should be of interest industry-wide.
  • The COS report includes only two of the six 2020 fatalities, 2 of which were classified by BSEE as non-occupational.
  • The bottom line is that COS accounted for only 3 of 12 (25%) occupational fatalities during the 2020-24 period. There were at least 20 fatalities if you include the non-occupational incidents.

The offshore industry is only as good as its worst performer, so complete participation is essential. Voluntary reporting is seldom complete reporting, because some companies are more concerned about confidentiality than completeness and information sharing.

For industry reporting programs to be comprehensive and credible:

• The entity receiving the reports and managing the data must be independent and not affiliated with an industry advocacy organization.
• All operating companies must participate and complete reporting must be required. This can be accomplished contractually. If necessary, the regulator can require participation (either as a separate regulation or as a SEMS element).
• Company incident submittals should be audited by the independent entity.
• Fees should be solely for the purpose of supporting the independent reporting system.
• For SP1 and SP2 incidents (per the COS classification scheme), the names of the responsible companies should be included in the performance reports. The current COS system prioritizes confidentiality over accountabiity and information sharing.

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