BSEE Discontinuing Seven-Day Courtesy Notification of Annual Compliance Audit and Engaging in Environmental Enforcement

Should they or Shouldn’t they?

For the entirety of my 35 years in offshore BSEE and MMS, before they always gave the offshore operator a phone notification that compliance inspectors would be making their annual compliance inspection of a specific facility. This was a most courteous activity on the part of BSEE giving offshore company personnel seven days to test and repair safety devices which did not function properly, seven days to correct chemical injection rates to comply with NPDES permits, seven days to correct reports.
Typically, at the end of the phone call, the project manager over the facility to be inspected notifies the platform personnel, then his second call is to a compliance specialist who would immediately deploy to the facility to assist with correcting any problem issues to insure a minimum of Incidents of Non Compliance. It is not a true representation of the facility and how it has been operated and maintained for the past 12 months.

BSEE should discontinue giving offshore operators any advance notice of inspection. Offshore operators should operate in compliance regardless if BSEE was making an inspection today or next week.
No advance notice should be needed for any facility to pass inspection with a minimum of INC’s.
BSEE – Bureau of Safety & Environmental Enforcement should also be required to collect overboard water samples for independent testing to ensure Environmental Compliance.

BSEE’s typical function in the past was to test the safety devices and audit the paperwork reporting of the facility. However, court records reflect operators use illegal methods of attaining overboard discharge results indicating the facility to be in compliance when in fact it is not. BSEE on its annual inspection has ample time to collect an overboard water sample from the facility to submit to an industry accredited laboratory to see if the results are indeed in compliance. Failure of the overboard water sampling should generate a follow up visit requiring a second sampling to verify compliance or noncompliance. Upon where a 2 offense of noncompliance would generate an INC and further monitoring of overboard discharge.

This would fulfill BSEE’s mission of Bureau of Safety and Environmental Enforcement, rather than just the safety function they have typically performed in the past during their annual inspections.

 

*The author’s views and opinions are entirely his or her own and may not reflect the views and opinions of 360factors.