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DCI Issues Response to USCG Draft Policy on DP MODU Critical Systems, Personnel and Training

Darley Consulting Incorporated has provided a response to the U.S. Coast Guard's request for comment on "Dynamically Positioned Mobile Offshore Drilling Unit (MODU) Critical Systems, Personnel and Training" as announced in the 29 December 2011 Federal Register (76 FR 81957).

While key aspects for offshore safety have been identified and recommended for consideration following the loss of 11 personnel and the Deepwater HORIZON in April 2010, one very important aspect of the tragedy was given little attention by regulators: the lack of Major Emergency Management (MEM) and Command Leadership training for those persons in command (and command teams) of rigs at sea.
 
Recorded accidents of this magnitude (e.g. Piper Alpha) most always demonstrate the same characteristics as noted in the assessment process of new and experienced command personnel during our MEM and leadership training. Command personnel, regardless of experience in the offshore sector, are frequently unsure of what to do in an emergency and therefore do not know how to respond to major incidents of this type. The reasons identified are numerous and are common across company lines.
 
The U.S. Coast Guard held a public meeting in Washington, DC, this afternoon to welcome comments from the offshore sector regarding their draft policy paper. The focus of the event was to receive comments and opinion on their proposal to offer new regulatory guidance on systems such as the Dynamic Position System (DPS), Emergency Disconnect System (EDS), and Blowout Preventer (BOP). Training and emergency procedures for these systems, along with OIM and Ship Master competency in the execution of these systems, were noted as critical in the safety of a MODU actively engaged in drilling.
 
DCI provided comments via a phone conference line, and despite the technical issues surrounding the quality of the phone connection and the ability to listen to all speakers, DCI was able to briefly expand on the need for additional training for the OIM, Ship Master, and command team. As noted in our simulated exercises over the past five years, one inter-related function to well-control that is commonly bypassed by command personnel is the use of the EDS. The order to utilize the EDS has taken as long as 10-15 minutes before execution, entirely too long (and now inoperable) after a devastating blowout occurs.
 
With regard to OIM competence, it was noted by one participant that the issuance of OIM licensing does not entail emergency preparedness or guarantee MEM expertise. While this is certainly true, licensing is only one aspect of an OIMs position. Until the OIM is thoroughly trained in MEM and command leadership skills, management schemes coupled with safety programs will never suffice for a properly trained OIM or Ship Master in their ability to mitigate major emergencies at sea. Command personnel at sea are the first to admit this handicap.
 
Additionally, an impression was given that well-control and MEM are one in the same, and that well-control measures should be the focal point for additional training. While we realize the absolute necessity in well-control training, it is a false assumption to compare well-control and MEM training as well-control does not provide the competency or skill set required for the assets command team; the two entities are completely separate. However, the combination of well-control and MEM training (a relatively new concept) is  a perfect match and is highly recommended.
 
Given the inconsistencies in training, and apparently, the relatively unknown capabilities of MEM or command leadership training amongst federal regulators and the offshore sector, it is DCIs contention that voluntary MEM and command leadership training should not be an option for personnel currently in command or about to receive command of a rig at sea. We highly recommend this training to be compulsary prior to an OIM or Ship Master assuming a command position.
 
We hope the U.S. Coast Guard considers our recommendation for improving offshore safety. DCI will be pleased to provide assistance to them in understanding offshore Major Emergency Management (MEM) training  for the oil and gas sector as required.
 

To review our response to the draft policy document as promulgated by the U.S. Coast Guard, please click here.