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Effective June 7, 2002, MMS was authorized to conduct
inspections of
U.S. Coast Guard-regulated items on fixed OCS platforms. Under the
new rule, the Coast Guard retains regulatory authority over the
self-inspection program and will continue to be responsible for initial
facility inspections to ensure full compliance with all safety
requirements under Coast Guard jurisdiction. Inspections by both the MMS
and the Coast Guard will be conducted in accordance with
Title 33, Subchapter N, Outer Continental Shelf Activities, Parts
140-147.
MMS enforcement of regulatory requirements of the Fixed
Platform Self-Inspection Program is being accomplished through Potential
Incidents of Non-Compliance
(PINCs). The 27 program-specific
PINCs, which were jointly developed by the Coast Guard and MMS, are
denoted by the alpha-character “Z” and have
enforcement actions ranging from “Warning” to “Component Shut-in” to
“Shut-in Facility."
To prepare MMS staff for the assumption of new
inspection responsibilities, the Coast Guard developed
training modules and conducted classroom training for both
district inspectors and engineers in the Gulf of Mexico Region and the
Pacific OCS Region. To further ensure consistency in inspection
procedures, Coast Guard also conducted on-site training of MMS
inspectors. Following all requisite training, MMS began inspection
functions on August 30, 2002, in which MMS is conducting either a full
inspection of all items on the
Fixed Platform Self-Inspection form or a limited
inspection of key safety items.
Efforts have been made to ensure consistency in
program implementation and to establish procedures for the prompt
identification and resolution of problems. MMS compiles
biannual
reports, based upon inspection statistics reported by MMS District
offices, to highlight program progress and areas for improvement. These
reports are presented to the Coast Guard’s Assistant Commandant for
Marine Safety, Security, and Stewardship by the MMS
Associate Director of Offshore Energy and Minerals Management
during regular meetings between MMS and the Coast Guard, ensuring
program attention at the highest level.
In cases where formal clarification of inspection
policy is required, the Coast Guard is publishing guidance documents or
instructions that provide additional information on
how regulations are being enforced. In all cases where questions
about program implementation surface, the Coast Guard and MMS
Headquarters and Regional staff work closely in the evaluation of the
problem and the recommendation for its solution. The collaborative
effort, and the resultant policy guidance, ensures that all inspectors
from the MMS and the Coast Guard, as well as the operators, have access
to the same regulations and guidelines and thus share a similar
understanding of program requirements. |
