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Posts Tagged ‘USGS’

Poster Child for Outdated Regulations

Posted in Regulation, tagged , , , on September 29, 2021| Leave a Comment »

US Coast Guard Subchapter N (current language as of 9/29/2021)

33 CFR §140.4   Relationship to other law.

(b) Any apparent conflict between the application of any requirement of this subchapter and any regulation or order of the U.S. Geological Survey should immediately be brought to the attention of the Officer in Charge, Marine Inspection.

I was proud to have worked for the Conservation Division of the U.S Geological Survey (USGS) when the US offshore program was at its peak in terms of scope and activity. I therefore like the nostalgia value of this provision. That said, USGS has not been the offshore safety regulator since 1982. While updating regulations can be extraordinarily difficult, simple administrative fixes are not. Such corrections are a good way to give old, outdated rules a fresh look. 😃

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Back to the Future!

Posted in Regulation, tagged , , , , , on November 1, 2010| Leave a Comment »

 

Hyannis Halloween - 1981

 

Note the sign (above) on our office at Barnstable Municipal Airport in Hyannis. Prior to 1982 when the Minerals Management Service was formed, the OCS regulatory program was part of the US Geological Survey (Conservation Division) and the leasing program was in the Bureau of Land Management. After a 28-year marriage, these functions are again being separated.

As one who worked in the OCS program for 10 years prior to the formation of MMS, I think the the pre-1982 framework is conceptually preferable. However, unless the separation is carefully executed, disruptive conflicts between the two organizations are guaranteed.  Such conflicts were common in the pre-MMS days, and the Department of the Interior had to set up a special office to coordinate activities and manage disputes.

In addition to being independent, the new regulatory authority must be fully responsible (without interference) for all regulatory actions from plan approval through abandonment.  Without such independence and authority, the separation will only add to the regulatory confusion that has handicapped the OCS program throughout its history.

Technical and scientific personnel in the OCS regulatory program must be freed from non-productive and time-consuming internal disputes and coordination responsibilities so they can concentrate on performance measurement, risk assessment, safety leadership, standards, and technical studies.

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