Inspections
BSEE continues to
evaluate risks posed by inspections but maintains authority to gain
unimpeded access to operator facilities and is performing
voluntary mitigations.
Drilling inspections have been prioritized over production inspections
due to the virus and eRecords inspection protocols
have been implemented
(see below). BSEE is conducting physical inspections following all
screening guidelines for inspectors and is developing
methods to facilitate
remote / virtual inspections for drilling and production operations.
Additionally, the following mitigations have been put
in place:
Communications
- Communicating with facilities prior to flying out for inspections and asking operators to provide details on potential issues
(i.e. using OOC "screening and status codes" provided on OOC website).
- Requesting that operators provide any specific company screening
requirements that exceed BSEE’s requirements when scheduling inspections.
- Monitoring reports provided by operators via web pages set up by the OOC in their Ryver application to track facility status.
- Tracking
changes in operator screening levels (has observed some moving to
lower-level screenings and some higher-level screenings).
Screening Levels- As the November 22, 2021 deadline for mandatory vaccination approaches, BSEE mentioned that it may want to use proof of vaccination in lieu of testing for inspectors visiting platforms. A final decision on this is pending the percentage of its workforce that becomes vaccinated. (October 18, 2021)
- Operators desiring matching protocols from BSEE inspectors visiting their facilities must send a letter to the Regional Director asking for vaccinated inspectors. The current options for those requesting a protocol match are requiring clean PCR tests or vaccinated inspectors. (October 4, 2021)
- BSEE leadership has communicated potential requirements for its
personnel to meet Federal mandates for vaccination. Although formal
policies are not yet in place, it is possible that all BSEE personnel
will be required to be vaccinated by November 22, 2021 or face
disciplinary action. (September 20, 2021)
- BSEE is working on revising protocols for vaccinated personnel. BSEE is
also concerned that operators are not testing vaccinated personnel
before traveling offshore. (August 2, 2021)
- BSEE has seen some operators change protocols that do not fit with currently defined OOC mitigations. (June 21, 2021)
- BSEE requests that operators provide written notice if their facilities are transitioning to a different screening level (e.g. from Level 2 to Level 3 protocols) so that the bureau can appropriately schedule inspectors for visiting facilities. Letters should be directed to GOM Regional Director Lars Herbst or Deputy Director Bryan Domangue. (June 07, 2021)
- BSEE is reviewing the recently updated CDC guidance on mask wearing for fully vaccinated people and will provide updates when any revised protocols are adopted. (May 17, 2021)
- BSEE is moving to some "modified" Level 3 protocols for vaccinated inspectors. For inspectors that are beyond their 14-day period after their full vaccination they will not be quarantining before reporting for a PCR test. After having a negative PCR test they will quarantine until they report for their flight out to the platforms. (April 12, 2021)
- Some BSEE inspectors have started to receive vaccinations on their own (i.e. not government-mandated / -sponsored). BSEE is reaching out to its contractor to discuss potential modifications to quarantining and testing, which could modify its Level 3 protocols. BSEE has reached out to industry to discuss, although no protocol changes have been made yet. (February 8, 2021)
- Holding ongoing meetings with operators of Level 3 facilities that had cases. The intent is to understand how barriers may be improved, how cases developed, and try to find gaps and best practices. (Posted July 22, 2020)
- BSEE has implemented protocols
and testing for Level 3 screening, which allow BSEE inspectors
to inspect Level 3 facilities.
- Protocols
include 7-day quarantining, PCR and serology testing.
- BSEE reminds operators to contact Bryan
Domangue or Lars Herbst when requesting Level 3 inspectors.
- Issues with differences between BSEE's and operators' Level 3 protocols have been brought to light and additional communications may be planned to discuss an appropriate way forward.
- BSEE has used Level 3 protocols to facilitate inspections of multiple Level 3 operators.
- Operator questions or concerns with Level 3 protocols should be brought up with Regional leadership (i.e. Bryan Domangue or Lars Herbst) rather than individual inspectors / districts.
- BSEE Level 3 inspectors will carry a doctor's letter verifying that they have passed screening protocols.
- Medically screening inspectors with questionnaires / body
temperature verification prior to boarding helicopters.
Inspection Processes- Due to an increase in COVID cases across the GOM BSEE's current ability to close out fiscal year inspections by September 30 is becoming limited with the number of "hot" facilities. (Posted August 16, 2021)
- October 1 the new fiscal year inspections
have begun.
- Some facilities that only received virtual or sample inspections
may undergo full annual inspection. This will be based on facility risk. (Posted August 5, 2020)
- Inspectors
performing "records inspections" when they cannot travel offshore.
BSEE has provided a list of eRecords to be submitted every Monday on a
7-day cycle to
District well
operations lead inspectors/supervisory well operations inspectors for
digital inspection in lieu of 30-45-day on-site inspections
(including IADC
reports, BOP test records, and other information). For more information,
see the Well Operations eRecords document.
- DOI
solicitors have affirmed Inspection protocols for eRecords and flyby
inspections for low-risk assets. Inspectors may return to assets already
shut-in to verify they are correctly / safely shut-in. BSEE
continuing work toward meeting OCSLA inspection obligations with inspection
protocol adjustments.
- Potential risks / options for adjustments to inspection protocols are
based on long-standing policy for inspecting drilling operations
every 45 days while
production inspections are conducted annually. BSEE wants to hear from
operators of any risk reduction measures being
taken for well
operations.
- Working with operators and OOC to address issues where access to
proprietary records is an issue in order to perform more electronic
inspections.
Specific Mitigations / PPE
- Reducing
exposure vectors for inspectors (i.e. 2 inspectors per helicopter,
sanitization logs, skeleton office crews, etc.) and practicing "social
distancing".
- Received and trained with personal protective equipment (PPE) to give inspectors for voluntary use. Inspectors are required to wear gloves and face shields are encouraged when social distancing cannot be maintained (both provided by BSEE).
- If possible, BSEE inspectors will follow operator protocols for PPE.
- Although
some operators are utilizing N95 masks, BSEE inspectors will not be
using N95 masks due to medical screening and fit test requirements, but
will utilize facial coverings on a voluntary basis since they are not classified as PPE. Operators utilizing N95 masks should review Subpart O
plans to ensure they have required fit testing for individuals that wear
the respirators.
- BSEE noted positively that some operators are using
secondary locations to transport personnel impacted by the coronavirus to shore
rather than through primary heliports.
Plans and Permit Approvals
Permitting operations
can chiefly be accomplished via teleworking although BSEE acknowledges
there have been permitting delays due to
difficulties visiting
the office for mail and large files. Mail continues to be processed on a
regular basis, but not as quickly as normal.
Paper applications will
need to be scanned in by BSEE personnel, which will also not be
processed as quickly as during normal operations.
Electronic permitting
via TIMSWeb and/or eWell will ensure the quickest processing of BSEE
applications. BSEE is encouraging and accepting OSRP submittals through
e-permits instead of via CD's. Forms will still have to be signed by
operator and agent and emailed (scanned versions are accepted).
COVID-19 Reporting
Current Statistics
BSEE
has provided guidance to operators in reporting COVID-19 cases. As of October 18, 2021, the Gulf of Mexico
OCS has reported 1,586 confirmed cases with 9 cases confirmed in the last 14 days. 19 personnel are PUI in last 14 days. Total cases are from 163 unique facilities, 129 are production facilities and 34 are well operations. This represents 24 percent of GOM OCS manned facilities. The total cases are from 30 unique operators. There have been four COVID-19 related fatalities offshore in the Gulf of
Mexico.
There have been recent outbreaks on facilities with confirmed cases and vaccinated personnel with confirmed cases, although BSEE does not receive data that provides whether personnel are vaccinated or not. There is concern that operators are not testing vaccinated personnel before traveling offshore.
BSEE is interested in lessons learned from the facilities with confirmed cases to see what failures or gaps exist that have resulted in cases. Companies willing to self-report should do so to Bryan Domangue. BSEE will reach out to facilities to gather this information.
Experience
during the pandemic has shown that a large percentage of personnel tested after
having close contact with confirmed cases have been asymptomatic. Most have
remained asymptomatic as BSEE has followed up with operators.
PCR
Tests have been used to determine recent cases whose facilities were at
screening Level 2+. PCR Tests detect the genetic information, (the RNA), of the
virus, which is only possible if the virus is present and a patient is actively
infected. PCR Tests are recommended by the OOC medical professional workgroup
to confirm positive cases (rather than antibody tests).
Evacuation
/ Positive Case Reporting
In accordance with BSEE
incident reporting requirements, those occupational injuries that
require or result in evacuation of the injured person(s)
by any means from the
facility to shore or to another offshore facility for the purpose of
receiving medical treatment must be reported. COVID-19
in itself is not deemed
to be a occupational injury; however, if the disease is passed along
from person to person at the facility, BSEE will
define it as
occupational. Additionally, if it elevates to a fatality, it will need
to be reported immediately. Operators should also notify BSEE
of any cases confirmed
after personnel return onshore via normal crew change so the facility
status can be updated.
Medical treatment means
the management and care of a patient to combat disease, disorder, or
injury. It does not include:
- Visiting a physician or other licensed health care professional solely for observation or counseling;
- Conducting
diagnostic procedures, such as x-rays and blood tests and including the
administration of prescription medications used solely for diagnostic
purposes (e.g., eye drops to dilate pupils); or
- Providing first aid (see NTL 2019-N05-BSEE for a complete list of first aid treatments)
Operators should input the notice into the BSEE system and mark it as
"Required Evacuation" and "Other event not listed above". Operators
should
insert "COVID-19" in the
text box provided next to "Other event not listed above."
Reporting
of COVID-19 case information to the USCG is also required but reporting
to BSEE via eWell satisfies USCG requirements (see below).
OSHA reporting for
medevac of infected personnel is recommended.
BSEE also
monitors reports provided via webpages set up by the OOC in their Ryver
application. Operators request a page to be created and set up access
permissions through the OOC. BSEE monitors these pages each day to see
the status of facilities.
Production Reporting
BSEE has provided a Voluntary Production Curtailment Form
for voluntarily reporting facility shut ins due to issues related to
COVID-19.
If this request is made,
BSEE would like to know the amount of production that is shut-in to
track the impact of the virus on GOM production
(similar to hurricane
reporting). This is only applicable to COVID-19 related shut-ins (i.e.
not applicable to facilities shut-in due to oil prices).
BSEE
regulations do allow for officially collecting production curtailment
data based on economic impacts or shut-ins outside of hurricane
curtailment. BSEE has not published any of the information it has
received on production shut-ins and would only be aware of more complete
data once OGOR reports are received.
Training
BSEE has established a
60-day grace period for in-house and hands-on training (not remote
training) for third-party training providers.
BSEE requests that
operators contact BSEE with lists of those affected. This does not apply
to initial training and BSEE stated that
un-trained personnel
should not go offshore.