BP’s Procedural Spills

Another thing that happened while I was tromping around one of the most beautiful places on earth (Yosemite) is that the BP drilling rig that had an explosion and fire last week sunk and oil has started to spill into the Gulf (as this dramatic NASA picture makes clear). In the last day, the Minerals Management Service (one of the federal agencies that regulate offshore drilling) has released documents showing that BP was cited in 2007 for training problems related to a similar problem in 2002.

BP Exploration & Production, which owns the deep water rig that exploded last week in the Gulf of Mexico, was cited in 2007 for inadequately training employees in well control, according to the US Minerals Management Service.

The conditions of the training are the same as those suspected in the possible blowout aboard the TransOcean Deepwater Horizon, which left 11 workers missing and presumed dead.

MMS slapped BP with $41,000 in fines in October 2007 after a series of violations related to a near-blowout five years earlier.  In November 2002, the Ocean King rig, operated by Diamond Offshore Drilling, in the Gulf had to evacuate all 65 of its workers for nearly two days after operators detected a dangerous rise in gas pressure.  The rig, which had been drilling at a depth of more than 5,000 feet, didn’t resume work for nearly a week, according to the MMS report.

Unlike last week’s disaster, workers were able to keep the well from leaking by using cement and mud to plug the well.  The same subcontractor, Diamond Offshore, was also used when BP was fined $25,000 in 2004 for bypassing a gas detection system while drilling.  A BP spokesman in London says the company still uses Diamond Offshore as a contractor.


In the 2002 incident, the MMS said that BP and Diamond Offshore were unaware that some of the key safety procedures they used to initially stop the dangerous rise in pressure could have contributed to a blowout.  The MMS cited BP for what it called “no formal procedures” and “no written guidelines” to follow in case of an emergency.  MMS also cited BP and contract workers in the incident for what they said was a “lack of knowledge of the system, and lack of pre-event planning and procedures.”

Let me give some background on this. In the 1990s, I worked for a company that consulted on safety procedures for the oil industry (a writer who reported to me did some procedures for one Amoco refinery, which was subsequently purchased by BP; we bid on, but did not get, a job that included BP; and we did some procedures for a drilling entity that has since been purchased by Halliburton, which is involved here as well). The way in which the government forces oil companies to operate in ways which minimize the safety and environmental danger of inherently dangerous processes is to ask (either nicely or by mandating) a set of procedures to cover both normal and emergency procedures. It’s a way of setting up documented procedures which can be trained and audited; the procedures allow the government to check whether the operators are operating as safely as possible. Just as importantly, it’s a way of proactively making sure that in case something does go badly wrong, the operator in question–and more importantly, the workers actually doing the work–will have a way of figuring out what to do quickly enough so as to minimize the safety and environmental damage.

MMS is saying that in 2002, BP not only had none of these procedures, but it hadn’t trained the workers and contractors on the rig, and as a result, the workers did the wrong thing to contain the damage. BP got lucky in 2002, because doing the wrong thing did not exacerbate the problems.

As a reminder, subsequent to that 2002 drilling rig problem, BP had a huge disaster in its Texas City refinery in March 2005 in which 15 people were killed and 170 were injured. BP’s own assessment of the accident found training and procedures to be one of four key factors in the accident. While it had appropriate procedures for the unit in question, it didn’t make sure the guys on the line were trained on or used them.

Despite the startup procedure not being fully updated, the procedure is generally of high quality, addressing all the safety warnings and key process control steps in detail. Many steps in the procedure were not followed, and the fact that the procedures were not updated indicates that they were not seen as important documents. Supervisors and Superintendents did not verify that the procedures were available and correct or being followed. Poor handover procedures meant that risks were not discussed and the correct procedures were not available to the board operator. In general, employees were unaware of the risks of operating without the procedures, considering this to be a routine operation needing little evaluation or thought. As a result of this, the Control of Work process broke down.


There was a lack of rigor and follow through in the area of training. Records showed incomplete training and there was little verification that all required training was occurring. The lack of gun drills to reinforce practical knowledge meant that operators’ theoretical knowledge was not complete and rarely witnessed. The heavy reliance on computer based training (typically done by individuals on their own) appears to limit the overall effectiveness of the training program.

In other words, BP has a recent history of blowing off the procedures and training that are one key to emergency management in this industry (though FWIW, I believed BP was better than most of the industry when I was working in it in the early 1990s). And, as the HuffPo reports, some the same companies involved in last week’s accident opposed MMS mandating this kind of procedure and training process just last year.

BP and TransOcean have also aggressively opposed new safety regulations proposed last year by a federal agency that oversees offshore drilling — which were prompted by a study that found many accidents in the industry.

There were 41 deaths and 302 injuries out of 1,443 incidents from 2001 to 2007, according to the study conducted by the Minerals and Management Service of the Interior Department. In addition, the agency issued 150 reports over incidents of non-compliant production and drilling operations and determined there was “no discernible improvement by industry over the past 7 years.”

As a result, the agency proposed taking a more proactive stance by requiring operators to have their safety program audited at least once every three years — previously, the industry’s self-managed safety program was voluntary for operators. The agency estimated that the proposed rule, which has yet to take effect, would cost operators about $4.59 million in startup costs and $8 million in annual recurring costs.

The industry has launched a coordinated campaign to attack those regulations, with over 100 letters objecting to the regulations — in a September 14, 2009 letter to MMS, BP vice president for Gulf of Mexico production, Richard Morrison, wrote that “we are not supportive of the extensive, prescriptive regulations as proposed in this rule,” arguing that the voluntary programs “have been and continue to be very successful,” along with a list of very specific objections to the wording of the proposed regulations.

While some of the specific complaints in BP’s letter make good sense (for example, making electronic documentation sufficient for procedures may lead to such documentation be better accessible in case of an emergency), it appears BP specifically wanted to limit its own responsibility for the procedures and hazard analysis of its contractors. In addition, BP resisted sharing audit information with MMS.

Now, we don’t yet know what caused this explosion and–just as importantly–what has led to the failure to limit the damage from the explosion. But BP’s recent history shows that it hasn’t made sure that the operators on its facilities are prepared to deal with emergencies like last week’s explosion.

50 replies
  1. bonjonno says:

    $41K in fines? look at the size of that spill. Gonna cost a helluva lot more to clean that up. How much will they get fined this time? $61K?

    • emptywheel says:

      That was the 2002 incident. But that sort of illuminates the whole point: the fines on this, for the big players, are ALWAYS less than it would cost to comply with the spirit of these regulations (rather than the letter of them). Back when I was doing refinery work, the middle-sized players always tried for the spirit of the law, bc it also made them a more efficient player. But the big players often tried to take the workers out of the equation, which was easier to do, bc the fines for killing one of those workers never amounted to more than pocket change for a big player.

  2. WilliamOckham says:

    I find BP’s problems in this area (which seem to be ongoing) a bit inexplicable. Unlike, say, in the coal industry, in the oil industry, it’s almost always better to be strict about safety procedures for purely economic reasons. The infrastructure is so expensive relative to the labor costs that it pays to be really anal about safety. There was a lot of talk in Houston a couple of years ago about BP having some serious management issues locally and this latest episode makes me think there was something to that.

    • emptywheel says:

      I don’t know the internal structure of BP, but I’d assume the guys responsible for the 2005 incident are entirely different than the exploration guys. For this to be a management issue (which it may well be) would be breathtaking for how pervasive it would have to be institutionally.

      • WilliamOckham says:

        I sometimes forget that people aren’t as in touch with the oil industry as geeks in Texas have to be. Yeah, that’s point I was making that if this a management issue, it would have to start really high up the chain and go down a long way. The rumors (or maybe they were allegations in the lawsuit by survivors, I’m not sure) were that the corporate guys wouldn’t support proper safety procedures. At the time, I sort of dismissed that as typically bitching about corporate that you hear in lots of companies. At this point, we shouldn’t jump to conclusions, but this does make me wonder…

  3. Jim White says:

    Wow, it’s just so shocking that BP had been warned and fined about similar problems!

    From an AFP article on the attempts to stem the flow, it’s pretty clear there has been virtually no planning for a well that has had its platform snap off in this way:

    “The dome would capture or gather the oil and allow it to be pumped out of that dome structure,” explained Danner.

    “If you could picture a half dome on top of the leak and the oil collects inside of this dome and is pumped out from there, that is the idea behind it.”

    Danner said the dome would be similar to welded steel containment structures called cofferdams used in oil rig construction, but stressed this would be an original design.

    “This is the first time this has ever been done. This idea didn’t exist until now. It has never been fabricated before.”

    “This idea didn’t exist” means to me that this scenario was never fully contemplated. But isn’t this the scenario that would be expected if the platform is detached?

    • emptywheel says:

      Note one more thing they said in their letter to MMS: they didn’t want to be required to do hazard analysis to prevent damage to their own property, arguing that you could have property damage without employee safety or environmental ramifications. Which says, among other things, that they may well not HAVE the hazards analysis on what happens when your platform snaps off. Though that probably would also fall into the category of the things your contractor does, not you yourself.

      • oldoilfieldhand says:


        thank you!
        In exploratory drilling the onus for emergency preparation and drills is on the contractor (Transocean), not the operator(BP). The people who work on the rigs are trained to recognize trends and signs that problems exist in the well bore. All deepwater offshore drillers and their supervisors (called toolpushers) are trained to “shut the well in” using the subsea BOP (blow out preventer)if there is any question of stability. BP and other Deepwater and Deep pocket operators have real time data transfer from their rigs to their exploration offices in New Orleans and Houston so engineers and accountants can monitor the progress against the daily costs. Deepwater dynamically positioned rigs are leased for long term projects involving numerous wells and frequently cost between half a million and a million dollars a day to operate. EVERYTHING is monitored to continually improve performance and cut the bottom line costs. Whatever happened on the Deepwater Horizon, the data was collated ,monitored and simultaneously recorded and transmitted in real time. These records will not be erased, lost or consumed in a man sized safe fire.
        The men and women who work in deepwater oil exploration will want to know what happened and they will ensure measures are implemented to prevent a recurrence. There will be no whitewash on this investigation.

        • emptywheel says:

          Is there a double meaning to the term contractor here? I understand that Transocean is the Big-C Contractor (and Halliburton was involved as well). But as there–as there are in refineries–also operators who are small-c contractors whose training might not be up to the level of BP or Transocean employees?

          • oldoilfieldhand says:

            There are “third party” contractors on all large off shore exploration vessels. They and the primary contractor (owner of the vessel) will all work for and under the supervision and direction of the operator. Most major offshore drilling contractors require the operator to adhere to their safety policies and procedures especially in the area of “well control”. This prevents the operator from risking the personnel and equipment to lower costs and increase profits. Large offshore drilling contractors have huge investments in equipment, personnel and training. Everyone has to have survival training and most have fire fighting training. In my experience major operators like BP do not cut corners when it comes to safety and training.
            Halliburton and other service companies provide specialized personnel and equipment to assist the primary contractor in drilling, monitoring, casing, cementing, testing and completing the wells. Hope this is some help.

            • WilliamOckham says:

              Yes, this has been my experience as well, even just from the side of being a software contractor. When I did some work at Schlumberger, they even made us go through safety training, although nothing like the guys who worked on the rigs went through. In general, oil companies are the most safety conscious that I’ve worked with. That’s why the stories I heard about BP never made sense to me.

              • bmaz says:

                Would it be fair to say that the overall safety record of offshore drilling platforms/rigs is pretty good? I have no idea, and in fact am somewhat surprised, but is my takeaway from your guy’s discussion.

                • WilliamOckham says:

                  Drilling is an inherently dangerous job, but yes offshore drilling in general has a pretty decent record. I think it get backs to economics. If you look at the costs of fielding a piece of machinery as expensive and complex as Deepwater Horizon and the amount revenue that is lost in an accident like this, you quickly see that it really does pay to be safety conscious.

                • oldoilfieldhand says:

                  If you’re into statistics: consider the millions of man hours involved in staffing hundreds of drilling rigs, production platforms, refineries and pipelines that deliver the river of oil and gas that powers not just the US, but the infrastructure of every country on the planet. For the most part this is accomplished safely and without fanfare. The safety records of the major oil companies and drilling contractors is extremely impressive. The downside is that when mishaps occur, they tend to be spectacular.

              • oldoilfieldhand says:

                I’ve worked on a number of very expensive BP projects. The “Company Men”, BP employees who specialize in supervising offshore drilling operations are good at what they do. They do not care about cost when safety is a factor. (That takes cojones in this business)

                • WilliamOckham says:

                  That’s good to hear. I’ll take a first hand report over the sort of rumors I’ve heard any day. And, frankly, what you say is what I would expect to be the case.

  4. Arbusto says:

    As the British Petroleum commercial states, BP, Beyond Petroleum. Could be Byond Procedures or Beyond Principles.

    I wonder how their and other oil/oil support company re-branding spiels are working.

    Good thing Obama loves him some off shore drilling as it’s so environmentally friendly

  5. PJEvans says:

    I don’t know how BP handles (or, apparently, doesn’t handle) their procedures, but the company I work at has sets of binders for this, and we not only have to read the updates, we have to sign off that we read them, and it’s available through a link on our computers. The information we need to get material safety data sheets (MSDS) is posted in both of the copy rooms on my floor – we know where to go for information. We also have the information we need to get safety clothing, from helmets to boots, through the company processes.) And we’re almost all office workers in my department.

    If BP isn’t doing at least as much, it needs a whopping big fine dropped on them.

    • emptywheel says:

      They’re saying they don’t necessarily have the paper binders out there. There is an argument to be made that it’s better to have computer based procedures (because it’s easier to guarantee people are working from the most up-to-date procedure and it’s easier to search for a procedure online than in a binder, particularly if shit is exploding), assuming the operators have access to those computers and a high degree of competence on using them. But that’s a key assumption.

      • WilliamOckham says:

        Several years ago, I worked on a project to automate a lot of procedures on deep sea rigs. Connectivity to the Gulf of Mexico is a lot better than a lot of places we worked with (for the geeks, TCP/IP needs a lot coaxing to work effectively over satellite-based networks, lag time sucks), but I suspect most people would definitely want both. The first things that are gonna go in a blowout are your network and your computers. Of course, the last thing you want to do in an emergency is to have to haul out your three-ring binder or laptop. You need to have folks prepared in advance.

        • emptywheel says:

          Fair point. At the point I was working on this stuff, the only place that had good computerized procedures was Alyeska, curiously enough. Though I can’t attest that the procedures worked all the way up and down the pipeline.

          • EdwardTeller says:

            the only place that had good computerized procedures was Alyeska, curiously enough.

            Curiously enough, indeed. Alyeska may have actually learned something from being caught doing so many things so terribly wrong in 1989. They have been caught since falsifying records, though, as has BP in Alaska, regarding when and how safety procedures or trainings occurred.

            That NASA shot is a great graphic. It is also approaching more than a day old. I used it this morning, explaining that this could be Bristol Bay or the Chukchi Sea.

            Just had lunch with a guy who says BP should have had blowout preventers on their operation at -500 and two or three more below that.

            • emptywheel says:

              Yeah, at that point BP was the smartest partner on Alyeska. But they had a bunch of computerized procedures they couldn’t access. They were trying to fix their procedures such that when a fire on the pipeline started they could actually find a way to put it out.

        • Synoia says:


          “TCP/IP needs a lot coaxing to work effectively over satellite-based networks, lag time sucks)”

          That what the sliding acknowledgment window in TCP is designed for.

          In IBM’s now obsolete SNA/SDLC IBM implemented a modulo 128 acknowledgment in the SDLC frames for satellite latency.

          • WilliamOckham says:

            Let me rephrase that. The TCP/IP stacks of several major vendors needed some coaxing to work properly with satellite-based networks. There’s more to it than the sliding window, but since this isn’t a geek blog, I’ll leave it at that.

            • MadDog says:

              I’ll back your rephrasal, and reinforce the point that running any protocol stack over a satellite link, even a finely tuned one, can never overcome the inherent latency. It is what it is.

      • PJEvans says:

        We have both. The monthly safety reports come out via e-mail (actually, just about everything does: the paper is the backup version).

        Which reminds me I need to find time this month for the company-required business-conduct classes. (It’s a good question what I should be getting from Sarbanes-Oxley. FERC compliance is more familiar.)

  6. rosalind says:

    I worked for Foss Maritime in their Environmental division for 2 years putting together Oil Spill contingency plans. This was in the wake of the Exxon Valdez spill and due to a jurisdictional tug-of-war the tugboat companies had to file three separate plans, one federal, one state, and one regional. Each one had separate, conflicting criteria on what to do in an actual spill. I imagine this has been smoothed over, but at the time it was quite the cluster. And the crews were not amused at having to stow three sets of binders onboard.

  7. RLMiller says:

    If this news is of concern, don’t just comment here. Comment on the MMS website as well. Say you’re concerned about safety. Say you’re concerned about climate change, sea turtles, white beaches, oyster farms, or the folly of drilling for oil to win votes on a bill to wean us off oil — but, whatever you say, say it there. Help create a strong public record.

  8. freeman says:

    Was it Obama who said drill baby drill , or someone else , I forget .

    Well in either case opening the east coast and Alaska up to oil exploration is probably not the right strategy if , as the guardian has recently reported , the US military has warned of serious world wide shortages with a year and a half .

    From the guardian:

    US military warns oil output may dip causing massive shortages by 2015• Shortfall could reach 10m barrels a day, report says
    • Cost of crude oil is predicted to top $100 a barrel

    The US military has warned that surplus oil production capacity could disappear within two years and there could be serious shortages by 2015 with a significant economic and political impact.


    • hankstamper says:

      we’ll never know, when the shortage is announced, if it’s due to depleted supplies or curtailed production. Dry wells or market manipulation.

      We’ll just buy the gas, at whatever price they sell it for, or take the bus. But one thing you can bet on…the impending shortage will be rolled out with more forethought, planning and coordination than a Spring fashion show in Paris.

    • ubetchaiam says:

      “Bloch faces a maximum sentence of one-year in jail and a fine of $100,000. Bloch’s likely sentencing range is 0 to 6 months in jail under the Federal Sentencing Guidelines.”; see, it really isn’t a BFD to lie to Congress but boy, don’t lite up a joint in public in Texas.

  9. hankstamper says:

    To use Sarah Palin’s words against her…Next time you’re driving along the Gulf Coast and see someone in a car with a “McCain-Palin” bumper sticker, pull them over and ask them:

    “How’s that “drill Baby drill” thing workin’ out for ya?

  10. fatster says:

    O/T. Do you think this is likely, EW? I sure hope it is, even though a larger estimate would have been much better. They do seem to mean new jobs in the USA.

    Forecast: Auto industry to add 88,000 positions


    • bmaz says:

      Does that include China? In the US, I do think they will be adding significant jobs, though maybe not that many in the next year domestically.

      • fatster says:

        Seems they mean the 88,000 in USA only: “automotive employment in the U.S., including automakers and suppliers, will grow from an average of 565,700 this year to 653,600 in 2011 and 742,200 in 2012.” Hope so!

        (Source same as @ 41 above.)

  11. bobschacht says:

    Gee. A major energy company skimping on safety issues. Sounds kinda familiar. Oh, wait… I got it! Coal! or Oil? I get so confused…

    Bob in AZ

  12. orionATL says:

    edward teller @30

    yeah, i’ve wondered why only one lone (460 ton -can you believe that?) valve at 5k ft.

    is redundancy only for nasa and REALLY smart engineers?

    given the loss of the men,

    the loss of the rig,

    the terrible hit to corporate reputation,

    the possibly severe environmental damage (with attendant costs),

    the hassle over insurance payments,

    the years-long contest over legal responsibility,

    how could any top-of-the-corporation management team have let this happen?

    this accident reeks of high-level managerial incompetence.

    • oldoilfieldhand says:

      It would be time consuming and likely fruitless to even attempt to explain the amount of redundancy that a modern 15,000 psi 500 ton sub sea blow out preventer encompasses. Take my word for it, it is not “one lone 560 ton valve”.

      • zenjuris says:

        Thanks for info. I looked up BOP stuff and ran into a flickr site that has a number of excellent photos about the spill, the site, and pictures of the blow out preventer. A few of the comments were also useful. I did take your word for it and the pictures took my breath away. The complexity of the BOP, the degree of difficulty in “fixing” this thing are almost mind numbing.

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