Part of BSEE’s Approach to Operational Risk is Remaining a High Reliability Organization
BSEE has a defined and well-established command and control structure with a strong culture of commitment to the quality of our permit reviews, confirmed through Internal Control Reviews. BSEE has taken measurable steps to improve Risk Awareness through identification, prevention, and mitigation and applies risk informed decision making in many areas; especially areas of highest concern like technology, HPHT, and alternate compliance.
Risk Definition and Ties to Strategic Plan
Risk = Probability X Consequence
BSEE includes “Promoting a culture of maintaining Safety and Risk Reduction” in its first Strategic Goal on Safety through:
- Including Risk in its inspection program.
- Implementing innovative activities to strengthen compliance and reduce Risk.
BSEE includes Risk in its Energy Security Program: Permit review strategies support timely development and accurately reflect the risks of development of the OCS.
Risk and Data-Driven Decision Making: BSEE emphasizes identifying risks for Data-Driven Decision Making through daily review of incidents and incidents of non-compliance, SafeOCS programs, and other data analysis efforts including annual safety data reporting, equipment failures analysis, and special outreach and research efforts based upon findings and recommendations.
In addition to the aforementioned, BSEE partners with NASA for Probabilistic Risk Assessment (PRA) on complex technology issues. Initiated in 2016, the BSEE and NASA interagency agreement (IAA), among other joint goals, evaluates the use of PRA in the offshore oil and gas industry. Managed from the Risk Assessment and Analysis Branch (RAAB) and jointly staffed by Engineering Technology Assessment Center (ETAC) and RAAB, the IAA develops and maintains capability and capacity for qualitative risk analysis. BSEE has successfully applied this approach to a number of high technology evaluations and frontier areas where companies are interested in using unknown technologies or in combinations with existing applications in new ways and enabled BSEE to find the areas of greatest concern and determine the feasibility of offered approaches. Results are shared with the submitter and the public.
Risk Focus in Permit Review: BSEE is focused on reducing risk offshore, upholding the principle that permit review is an important opportunity to consider proposed offshore activities risk and an operator’s ability to demonstrate sufficient management of risk. To advance this goal, BSEE incorporates and reinforces risk management principles through establishing and updating BSEE policy.
BSEE’s focus on reducing risk can be found in a number of related activities, to include its reflection in BSEE SEMS regulations in 30 CFR 250.1910: Analysis of Hazards of the Operation; Direct Application of the Hazard Identification Principle.
BSEE’s Risk Analysis Committee and Data Analysis Committees
BSEE’s Risk Analysis Committee (RAC) is comprised of membership from throughout the Bureau and evaluates potential risks associated offshore operations under BSEE jurisdiction.
BSEE’s Data Analysis Committee (DAC), among other activities, evaluates incoming reports and documents for possible referral to the RAC or other offices within BSEE for appropriate action on operational safety and risks. The Risk Assessment and Permit Policy Section (RAPPS) and Data Analysis and Stewardship Section (DASS) support these efforts by providing formal staffing and by active membership in these two committees.
Contact: Michael Pittman, Chief, Risk Analysis and Assessment Branch, Michael.Pittman@bsee.gov