9/2/2014: Safety culture offshore

Rear Adm. Paul Thomas, assistant commandant for prevention policy, spoke to the Marine Board of the National Academies and presented the Coast Guard’s views on safety culture offshore.

Thomas spoke about the efforts of the Marine Board and other similar committees and the type of work that they do in effort to improve safety in the maritime environment. This summer, a Coast Guard liaison was appointed to work with the Marine Board on a study for offshore oil and gas safety culture. The study aims to aid industry, government and other stakeholders in strengthening the safety culture of our nation’s offshore oil and gas industry.

During his speech, Thomas presented on safety culture as it relates to domestic energy production, safety management systems and cyber safety.

Domestic energy production:

Thomas touched on how safety culture is not a new discussion but is more relevant today than ever before.

“If you look around at what is going on in our nation with domestic energy production and transportation. We are drilling deeper. We are using more complex techniques…We have supply vessels, tankers, passenger vessels, research vessels, you name it…and they employ the most complex technology that we’ve ever seen in this industry,” said Thomas. “At the same time, we have mariners who have less experience today than they’ve ever had in the offshore environment. We also have more non-mariners on those vessels than we’ve ever had before.”

Thomas also spoke about developments ashore and identified several developments in the realm of energy production and transportation.

“If you look at what’s going on with gas production, soon we’ll be exporting LNG…we’ll be looking at a lot of gas-fueled vessels and all of the shore-side infrastructure that goes along with that, as well as all of the new mariners involved with dealing with gas,” said Thomas.

Thomas correlated domestic energy production and safety culture in the context of maritime connected production and transportation issues.

“We have more crude oil moving southbound in our river systems than we ever have. We have mariners who used to push rocks and grain now pushing crude oil,” said Thomas. “When you look at the safety culture issue in the context of just what’s going on with regard to domestic energy production and transport, I think it becomes even more relevant and more important than it ever has before.”

Thomas also brought attention to the potential for failure in the world of domestic energy production.

“The real kind of sense of urgency that I think we all should feel is that failure, in addition to lives lost and environmental damage done, could represent a real loss of opportunity for our nation in terms of our willingness to really leverage this new energy,” said Thomas. “I honestly believe if we fail once, early, with regard to LNG fueled vessels, we might lose that opportunity and all of the good that can come from that both in terms of the environment and economic activity.”

Safety Management Systems:

Thomas shared his perspective on safety management systems, or SMS, and the potential for being ineffective if not used properly.

“I believe that they [safety management systems] are a necessary but insufficient kind of precursor for safety culture. I think we do point to safety management systems frequently,” said Thomas.

Thomas explained how safety management systems define hazards, assign responsibility and accountability and can set the stage for a safety culture but that a safety management system, by itself, cannot instill a culture.

“SMS itself cannot make safety and environmental awareness an intrinsic value which a business actually makes part of its product. It can’t really establish a reporting culture. It can’t establish a culture where stop work authority is taken seriously and used,” said Thomas. “When a SMS is well-designed and well-implemented, and it has good oversight, it can be really effective.”

Thomas identified safety management systems as a reasonable way to manage risk but shared his concern of an SMS that is well designed but poorly implemented.

“When that happens, you have a total disconnect between what management expects to happen and what is actually happening. I cannot tell you how many times senior management has been genuinely shocked after an incident because they spent lots of time and money on really good systems, with rigorous third party oversight, but which are really not well implemented,” said Thomas.

Thomas identified common issues that the Coast Guard has been experiencing when inspecting for SMS:

• Disconnect between audit and survey results
• Disconnect between what a Coast Guard marine inspector and what third party auditors are finding
• Management having a false sense of security
• Serious discrepancies found by marine inspectors onboard
• Low crew awareness of the SMS

Thomas urged the Marine Board to create tools to help managers assess SMS and safety culture at the deck plate level.

“My inspectors are going to start asking questions to assess safety culture that might lead them to expand an exam,” said Thomas.

Cyber and safety culture:

Thomas shared the importance of including cyber in the discussion of safety culture.

“Most people hear cyber and think cyber is a security issue…but cyber is absolutely a safety issue. In fact, I believe we are much more likely to have to mitigate the significant consequences of a cyber incident that’s due to an accident in the maritime environment than we are to one that is due to a deliberate attack,” said Thomas.

Thomas highlighted the fact that there are rigs that operate on dynamic positioning systems that can interact in unexpected ways with other cyber systems aboard the vessel.

“There’s at least one example where a person ashore pushed a patch to an administrative system afloat and that interacted in a way that was totally unexpected with the control systems and caused an emergency disconnect,” said Thomas.

Thomas pushed for industry to understand potential problems in the cyber domain that they are responsible for. He posed some questions for management to ask of their own cyber systems in regard to safety.

• What are the stop-work authorities associated with cyber?
• Where are the fences that should not be crossed in the cyber domain?
• What are the credentials I should require to get in certain parts of my cyber domain?
• Is it really smart for all employees to have access to every aspect of cyber domain?

“Regulations have a role…still, that is not going to instill the deck-plate level safety culture,” said Thomas.

Safety culture is an emerging issue and a significant topic to the Coast Guard. Rear Adm. Paul Thomas wants to engage with stakeholders on this very important subject through social media. Stay tuned for blog posts and twitter feeds on the topic and chime in with your thoughts!

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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