The MMS also inspects the stockpiles of industry's oil-spill response
containment and clean-up equipment that are cited in the industry required
Oil Spill Response Plans. These inspections are conducted by engineers
located at the one of the five MMS district offices or by Oil-Spill
Program staff in the New Orleans Regional Office. Operators are required
to ensure that the response equipment listed in their response plan is
inspected at least monthly and is maintained, as necessary, to ensure
optimal performance. They are further required to ensure that records of
the inspections and maintenance activities are kept for at least 2 years
and are available to any authorized MMS representative upon request.
To conduct these inspections, the MMS engineers travel
to locations throughout the Gulf of Mexico Region to inspect oil spill
equipment owned and operated by the contracted OSROs cited in the
Oil-Spill Response Plans. The four primary open water OSROs contracted by
industry to respond to spills in the GOM have spill response equipment
stockpiles located at over 30 strategic sites along the Gulf coast.
Through inspections, MMS verifies that the equipment is located at the
designated locations, that it is being maintained and is in good working
order, and that records of its deployment or use in training exercises
have been documented.
As part of the MMS GOM inspection process, the engineers
check the equipment inventory list to determine whether it matches the
availability of the equipment located at the designated OSRO equipment
base. The condition of the equipment is noted during this process. All
major equipment systems are photographed during this inspection. All
equipment with moving parts and skimming systems is started. It is MMS
policy that this equipment must be fully functional on the first start up
attempt. Any equipment not fully functional on first start-up attempt
would receive a failing rating. That OSRO would be given 14 days to repair
the failing equipment and make the failing equipment fully functional for
a follow-up MMS inspection. Over the past five years there has only been
one piece of equipment requested to be started by an MMS representative
that did not operate during the inspection process.
MMS then conducts a records review to verify that all
OSRO team members have had the required annual hands on equipment training
that is required. Record checks are also made to determine whether the
annual equipment deployment exercises have been conducted and that the
required monthly equipment inspection and maintenance has been performed.
