726 Ab
726 Ab
Based on the findings from the Task 1 Report, ABS Consulting conducted a further analysis of selected
agencies and industry organizations. Each agency and organization was reviewed for further
programmatic elements, best practices, the role of the regulated industry, statutory regulatory
elements, effectiveness, data, and the onus of liability.
In this Task 2 Report, we conducted a review of the following agencies and organizations:
• Domestic Agencies:
o Department of Homeland Security: United States Coast Guard
o Department of Transportation: Federal Highway Administration
• International Agencies:
o New Zealand Department of Labor
o Norway Petroleum Safety Authority
o United Kingdom Health and Safety Executive
• Industry Organizations:
o American Waterways Operators
o International Organization for Standards
o American Petroleum Institute
o International Association of Drilling Contractors
o Industry Representative Company
Based on the review of these agencies and organizations, ABS Consulting compiled findings for what a
Life Cycle Management (LCM) system can contain and what the main components that make a
functional LCM system. Several of the LCM systems in place are often paired with other safety and
management systems like the Safety and Environmental Management System or a Failure Reporting
System, or as part of an integrated, custom-built software solution unique to the company. For example,
programs like the American Waterways Operators’ Responsible Carrier Program incorporate
maintenance and aspects of LCM into their program, but as one component.
One of the main findings of the review is the importance of definitions. Having clear, understandable
definitions that can uniformly apply across the industry will aid in the collection and aggregation of data
that can be used for risk analysis. If BSEE implements regulations mandating an LCM system, BSEE would
need to set clear and understandable definitions and guidelines, even if incorporating an industry
standard or best practice. This will be further addressed in the Task 4 Report.
A main issue raised by industry representatives and evidenced throughout many of the agencies is the
data collected. An LCM system may not need much data submitted to BSEE for review, but should
instead be used by industry to identify trends in manufacturing issues or process improvements. Since
Liability of data is a key issue as well. BSEE would need to strike a balance between sanitizing the data
collected enough to protect and preserve the industry confidential data, but provide enough detail that
trends and analysis can be conducted. BSEE would also need to be able to turn over data for analysis in a
timely manner, particularly in an industry that can be fast-moving with ever-changing technologies.
The usability of the data, as well as the information gathered in this report, is dependent upon the
regulatory structure that BSEE would choose to implement an LCM system. Many offshore
petrochemical industry participants are currently engaged in some aspects of LCM and have robust
systems in place. BSEE can implement regulations within a spectrum of approaches, from “prescriptive”
regulations, characterized by command and control regulations, heavy inspection schedules and
onerous reporting requirements for industry, to a regulatory approach with industry-led regulations
(Figure 1). The industry-led approach can involve simply the incorporation of industry standards systems
or be based on industry involvement and consensus standards. While this can allow industry more
flexibility in defining the compliant system that would meet both their operational needs and the safety
and data needs of the Government, liability might fall on BSEE, as the regulator-led approach may result
in compartmentalized or fragmented systems which may not produce usable, industry-wide data. A
“hybrid” LCM approach would be a blend of both prescriptive and industry involved LCM models.
Prescriptive Regulations
Industry-based
Feasibility is a key consideration in developing recommendations that may actually lead to successful
implementation. A regulatory framework that meets the needs of the government while staying flexible
enough for the industry can be difficult to identify and implement; however, this approach may ease
implementation difficulties and boost industry acceptance. BSEE’s aim should be to develop a regulatory
regime that is robust enough to ensure the safety of employees and the environment while being
flexible enough to allow industry to continue with their best practices. In this way, BSEE can avoid
creating redundant or onerous resource and financial burdens on industry.
Incorporation of industry standards like American Petroleum Institute Specifications for Quality
Programs Q1 and Q2 will provide a basis for the development of a system, and, with additional
regulatory guidelines, industry can develop their programs within that framework. BSEE can then
develop further guidelines and structure to ensure consistency across the industry. By incorporating
these standards by reference, it is likely that BSEE can improve regulatory acceptance as a first step. This
discussion will be further addressed in the Task 5 Report.
LCM systems provide a way for the Oil and Gas (O&G) industry to monitor the functionality and
performance condition of any piece of equipment, component, or system. In order to support BSEE in
developing an effective regulatory program, this project will validate the knowledge and findings from
the Task 1 Report: Agency Review. Specifically, American Bureau of Shipping (ABS) Consulting will assist
BSEE in creating a regulatory program based on risk management for Outer Continental Shelf (OCS) O&G
operations.
Additionally, we have identified the key elements of an LCM system. These elements include the policies
and regulations enacted, the activities of responsible parties, and the different approaches used to
implement or regulate an LCM system. Following the review of the selected agencies, ABS Consulting
compiled several findings that BSEE can adopt to strengthen its regulatory-related guidance document
processes. This, in turn, will enable greater effectiveness and flexibility for BSEE to regulate a complex
and fast-paced industry.
2. Introduction
LCM systems are an integral part of a successful organization. These systems are vital to ensure that
costs are reduced while simultaneously maintaining an ever safer operating environment. This report
describes the results of inquiries and analyses in support of contract E14PB00045, Risk Assessment for
Life Cycle Management and Failure Reporting Systems. It describes the results of inquiries and analyses
in support of Task 2 of the subject Call Order. The purpose is to identify LCM concepts for critical
equipment used in OCS O&G operations and recommend changes to 30 Code of Federal Regulations
(CFR) 250. In keeping with BSEE’s mission, this Task 2 report provides a deeper review of the LCM
systems and recommends improvements that BSEE can implement.
The report provides an analysis of the selected domestic agencies, international agencies, and industry
representatives. ABS Consulting aimed to capture features that may be appropriate for BSEE to consider
in developing its requirements for an LCM system. The information gathered during this research will be
used to create an initial definition of critical systems, equipment, and components and to develop
recommendations for possible changes to BSEE’s regulations and procedures.
Several of the key findings and theories identified in Task 1 were further investigated and elaborated
upon. LCM systems were analyzed for the policies, regulations, industry standards, guidelines or official
communications they incorporated. This part of the analysis will provide the structure for how other
regulators and industry representatives have developed and implemented LCM systems.
ABS Consulting conducted outreach to the selected agencies and coordinated with our international
offices to obtain information for international regulators. ABS Consulting used a standard template to
review and collect consistent data for each identified program and, consequently, was able to gather
uniform information.
Once the information for each agency was collected, ABS Consulting reviewed data across the various
LCM systems to identify key commonalities, components, trends, and viability, in addition to each
system’s overall applicability to BSEE. Given the list of selected agencies and their associated industries,
it is possible that some programs might not be applicable to the OCS O&G industry. The LCM systems,
therefore, merited further scrutiny to help ensure potential functionality, viability, and acceptance by
the industry. These elements are essential to understanding how to best implement and manage an
LCM system.
ABS Consulting analyzed these findings further to provide feedback and options for progress forward. As
a result of our Task 2 efforts, ABS Consulting is providing preliminary recommendations for LCM systems
that, along with our Task 3 findings on Failure Reporting Systems, will inform Tasks 4 and 5 of the Call
Order.
4. Agency/Organizational Review
The following section is an in depth review of organizations initially evaluated in the Task 1 report and
subsequently selected by BSEE for further review. This section is separated into three sections: Domestic
Federal Agencies, International Regulators and Industry. Each organization reviewed in this section has
been thoroughly researched to identify the elements listed in the Task 2 description statement of work
for this project. The following information describes the findings of this research.
1
Templates are included in Appendix A
In Section 2 of the Blanket Purchase Agreement (BPA) Call Order No. E14PB00045, BSEE offered a
description of an LCM system “as inclusive of the following as related to a piece of equipment; design,
fabrication, installation, repair and maintenance, failure reporting/analysis, design modification/
refurbishment/re-specification, and operation” (BPA Call Order No. E14PB00045, 2014). Using the BSEE
description of an LCM system, the following discussion will examine the USCG’s use of LCM systems
from two perspectives. The first perspective is the application of LCM systems external to the USCG; the
second perspective is internal to the USCG’s application of LCM systems.
4.1.1.1 History
Prior to World War II, few standards and specifications were defined for materials being used to build or
equip U.S. flag vessels; subsequently, products lacked uniformity. The USCG had no way to distinguish
acceptable materials or equipment from substandard ones. As a result of this lack of quality assurance,
there were numerous catastrophic failures that led to the loss of life. In 1945, the USCG promulgated
the regulations in 46 CFR Subchapter Q, Parts 160-164. These regulations consolidated the standards
for equipment and materials and ensured that the USCG developed minimum standards for certain
materials and equipment.
Given BSEE’s definition of an LCM system, the USCG’s enforcement of Title 46 of the CFRs can be
inferred as a de facto imposition of an LCM system that is already applicable to the OCS. Specifically,
Subchapters F, I-A, J, Q and W address the “maintenance, failure reporting/analysis, design
modification/refurbishment/re-specification, and operation” of critical equipment (BPA Call Order No.
E14PB00045, 2014). Though the term LCM is never used in these regulations, it is clear that the intent of
these regulations is to control critical components and utilize reporting to “promote safety, protect the
environment, and conserve resources offshore through vigorous regulatory oversight and enforcement”
(BPA Call Order No. E14PB00045, 2014). Parts of these regulations establish or incorporate by reference
standards for the design, materials, installation, and modification of critical equipment. Other parts
clearly define standards for maintenance, refurbishment, and recertification of critical equipment.
In addition to the regulatory regime that functions as an LCM, it should also be recognized that the
USCG has its own internal LCM system. The USCG has no single methodology or policy that speaks to the
agency-wide application of an LCM system. Instead, the USCG uses a hierarchy of agency-wide policies
that address the various aspects of an LCM system for assets it owns and operates. The USCG
developed most of these policies in the last ten to twenty years. Though these policies do not
specifically use the term LCM in most cases, they address the same processes associated with LCM. The
fragmentation of these policies would make it difficult for BSEE to neatly extract models or examples
that could be applied to the OCS. However, there are components of these policies that could help BSEE
define the structure of an LCM system.
The USCG’s internal policies and programs do not come directly from industry, trade groups, or trade
associations, but many polices or guidelines are incorporated by reference to recognized standards
organization such as: Air Transport Association (ATA), American Welding Society, Manufacturers
Standardization Society of the Valve and Fittings Industry, Compressed Gas Association (CGA), Fluid
Sealing Association, Society of Automotive Engineers (SAE), the Society for Protective Coatings, Boating
Industry of America, Telecommunications Industry Association (TIA), Electronics Industry Alliance (EIA),
International Building Code (IBC), the National Electrical Code (NEC), and International Residential Code
(IRC).
The USCG has, broadly speaking, two levels of policy related to LCM. Higher level policies provide
agency-wide strategic LCM guidance related to the acquisition, operation, maintenance, and disposal of
major assets. Lower levels of policies are structured to address the LCM processes based on major asset
categories (i.e., facilities, aircraft, vessels, electronics, etc).
The primary policy related to the acquisition phase of LCM is Commandant Instruction Manual
5000.10C, Major Systems Acquisition Manual. Direct applicability of this policy to BSEE’s desired
Once a major acquisition has been completed and the major assets are operational, the controlling
USCG policy regarding LCM is Commandant Instruction M4500.5D., U.S. Coast Guard Personal Property
Management Manual. This policy states that maintenance programs for USCG-owned aircraft must
comply with Title 41 CFR, Part 102-33 (Commandant Instruction M4500.5D., Personal Property
Management Manual, 2013). Additionally, the USCG defines the term “Life Cycle” in this policy as
“Taken together, the steps or phases experienced by an item of property from acquisition through
disposition.” The policy also describes the management of personal property management (i.e., LCM),
as “the control over acquisition, management, utilization, reutilization, excess, accounting, and disposal
of property.”
This regulatory reference is important because 41 CFR, Part 102-33.170(d) mandates, “Procedures for
recording and tracking maintenance actions; inspections; and the flight hours, cycles, and calendar times
for life-limited parts and FSCAP [Flight Safety Critical Aircraft Part].” The FSCAP concept has direct
applicability to BSEE’s inquiry. 41 CFR Part 102-33.20 defines FSCAP as, “…any military aircraft part,
assembly, or installation containing a critical characteristic whose failure, malfunction, or absence could
cause a catastrophic failure resulting in loss or serious damage to the aircraft or an uncommanded
engine shutdown resulting in an unsafe condition.” According to 41 CRF Part 102-33.5 and 102.33.15,
the concept of FSCAP in this instance is related to Public Contracts and Property Management and
applies to “all federally funded aviation activities of executive agencies of the U.S. Government” but
does not supercede any regulations related to Federal Aviation Regulations. Therfore, FSCAP is not
directly applicable to and LCM system; rather the definition of a “Critical Aircraft Part” can help shape
BSEE’s definitions.
In the hierarchy of policies, the next level becomes asset specific and addresses the unique
requirements of LCM for each asset category. The following discussion will focus on four policy manuals
that provide LCM guidance for major asset categories: aeronautical, naval, civil, and electronic
engineering.
The RCM Program is an organized procedure designed to monitor the reliability of aircraft
components by utilizing historical maintenance data and statistical methods. Experience has
shown that this technique is an accurate method of evaluating the reliability of aircraft systems
and components. The program monitors the performance of aircraft components continuously
and brings problems and deteriorating trends to the attention of Coast Guard management. The
program determines whether preventive action is needed if the inherent reliability of
components is not realized.
The RCM Process Guide, CGTO PG-85-00-30 could be useful to BSEE, as it outlines a maintenance
philosophy and concepts that BSEE could apply to the offshore industry. There is also a decision logic-
model in the guide that highlights how the crew should address a functional failure shown in Figure 2
below. From this model we can see that functional failures are initially divided into what is evident and
what is hidden. Then, the decision tree moves to whether the failure poses a safety, mission, or non-
mission (economic) effect. No matter the particular effect, the steps addressing each failure are
generally the same:
The applicability of each of these steps is dependent on the failure not being resolved through a
previous task, with the first being lubrication & servicing. The effectiveness of each task is evaluated for
the safety and mission effects. Accordingly, each should be completed so the risk of failure is reduced to
an acceptable level. For the non-mission (economic) effects, each task should be completed so that it is
cost effective, specifically in that the cost of the task is less than the cost associated with the failures
prevented (United States Coast Guard, 2006).
The USCG currently uses an Asset Computerized Maintenance System (ACMS) software program that
tracks FSCAP to individual maintenance tasks by discrete barcode numbers. The barcode numbers link
FSCAP designated parts to specific maintenance tasks. However, as a matter of redundancy, a user can
input a component’s serial number and Component End Item Number in case a barcode is not
applicable or has fallen off. This program will probably not have any direct applicability to the offshore
industry, but it is a tangible example of the management of “critical equipment.” Commandant
Instruction M13020.1 does not directly define ACMS, but references the ACMS Users Process Guide,
CGTO PG-85-00-10. The guide provides a detailed description of the forms, reports, and procedures
associated with ACMS (Commandant Instruction M13020.1, Aeronautical Engineering Maintenance
Manual, 2011). It is important to note that as of December 2014, the USCG announced it has
implemented a Logistics Information Management System (LIMS) as the primary maintenance software
for the HC-144A Ocean Sentry aircraft fleet. If the implementation of the system goes well with the HC-
144A Ocean Sentry aircraft fleet, the USCG has the option to transition to the LIMS for all of its aircraft
and some of its vessels by the end of 2018.
Finally, there is the Commandant Instruction M10550.25, Electronics Manual. This manual addresses
LCM more directly and extensively than any other USCG policy discussed to this point. The manual
describes five stages of the life cycle of electronic equipment -- acquisition and procurement,
installation, equipment maintenance, equipment engineering changes, and equipment disposition. The
manual also has two chapters devoted to life cycle; one chapter addresses LCM for general use
electronic equipment and the other addresses LCM for electronic test equipment. In addition to the two
chapters devoted to life cycle, the manual has numerous chapters devoted to installation and
maintenance processes. At 755 pages, the Commandant Instruction M10550.25, Electronics Manual is
comprehensive in its scope and detail as it relates to the principles of LCM (Commandant Instruction
M10550.25, Electronics Manual, 2007). Unfortunately, it is so detailed and so specific to USCG-related
systems that it would be difficult to apply the policy to any other system or agency because the
components and systems mentioned in this manual are very specific, such as the broadcasting
frequencies of radios used by the USCG. This is done intentionally, as the target audiences of this
manual are electronics technicians tasked to repair and maintain the components and systems.
Therefore, while the manual is descriptive in the methods of maintaining the systems and components,
it is completely specific to the USCG.
In support of the requirements life cycle, the policy establishes a Systems Engineering Life Cycle (SELC)
framework. The SELC is a one of the key processes for USCG acquisition programs and their related
projects. The SELC guides the definition, execution, and management of an interdisciplinary set of tasks
required to plan, define, design, develop, implement, operate, and dispose of systems. The eight stages
of the SELC model, with an explanation of each stage are presented in Figure 4.
The USCG uses industry standards and specifications in the regulatory structures of 46 CFR which
highlights how government agencies can implement existing industry standards and specifications in
development of guidelines. This helps reduce duplication of effort while providing an acceptable end
result. The following list is not all inclusive, but representative of standards recently reapproved for
incorporation:
• American National Standards Institute (ANSI)/ISA 12.12.01–2012, Nonincendive Electrical
Equipment for Use in Class I and II, Division 2 and Class III, Divisions 1 and 2 Hazardous
(Classified) Locations
• ANSI/ISA 60079–18—Electrical Apparatus for Use in Class I, Zone 1 Hazardous (Classified)
Locations: Type of Protection—Encapsulation ‘‘m’’, 2012 (‘‘ANSI/ISA 60079–18’’)
• ANSI/UL 674—Electric Motors and Generators for Use in Division 1 Hazardous Locations
(Classified) Locations, 5th Edition (‘‘ANSI/UL 674’’)
• ANSI/UL 823—Electric Heaters for Use in Hazardous (Classified) Locations, 9th Edition (‘‘ANSI/UL
• 823’’)
• ANSI/UL 844—Electric Lighting Fixtures for Use in Hazardous (Classified) Locations, 13th Edition
• (‘‘ANSI/UL 844’’)
• ANSI/UL 913—Intrinsically Safe Apparatus and Associated Apparatus for use in Class I, II and III,
Division 1, Hazardous Locations, 7th Edition (‘‘ANSI/UL 913’’)
• ANSI/UL 1203—Explosion-proof and Dust-ignition Proof Electrical Equipment for use in
Hazardous (Classified) Locations, 4th Edition (‘‘ANSI/UL 1203’’)
• ANSI/UL 2225—Cables and Cable Fittings for use in Hazardous (Classified) Locations, 3rd Edition
(‘‘ANSI/UL 2225’’)
The USCG also uses industry standards and specifications in the acquisition and maintenance of the
major assets it owns and operates. These include:
• ATA
• API
• ABS Rules for Building and Classing Steel Ships
• ASTM
• American Welding Society
• IEEE
• ISO
• Manufacturers Standardization Society of the Valve and Fittings Industry
• CGA
• Fluid Sealing Association
• NEMA
• NFPA
• SAE
• The Society for Protective Coatings
In addition to these regulations, numerous guidelines exist in Navigation and Vessel Inspection Circulars
(NVICs), along with procedures in divisional policy letters that inform the process. To better understand
how the regulations in 46 CFR function as a LCM system, it is instructive to examine Subchapter Q. This
Subchapter demonstrates how the USCG implements regulatory structures that control the
“maintenance, failure reporting/analysis, design modification/refurbishment/re-specification, and
operation” of critical pieces of equipment.
The USCG has also established a system of “type approvals” for categories of critical equipment that
require USCG review and approval. In order for a piece of equipment to receive Type Approval it must
comply with the requirements within the regulations, successfully complete specific tests, and be
enrolled in a quality control or follow up program. While there is no charge for the USCG issuing a
certificate of approval, the costs associated with laboratory testing and follow-up inspections are the
responsibility of the applicant. Once approved, a certificate is issued to the manufacturer for approval of
equipment and is valid for five years 2. The Certificate of Approval is renewed upon request so long as
the equipment or material has not changed, the requirements have not changed, and the item is still
under a continuous follow-up program. Unfortunately, specifics on the approval process are not
provided, however, in general the USCG will review all necessary drawings, specifications, proof of
follow-up program, and the required testing before approval (U.S. Coast Guard, 2014).
4.1.1.5 Effectiveness
USCG marine inspectors and program managers monitor the number and type of LCM-related
deficiencies issued to vessel owner/operators. The USCG has been monitoring these deficiencies for
decades, and these efforts have been greatly facilitated with improved information technology, such as
the Marine Information System for Safety and Law Enforcement (MISLE) and the Coast Guard Business
Intelligence (CGBI) system. While these systems are designed to provide insight on the occurrence of
incidences, this information can be connected with inspection and maintenance schedule to better
understand the effectiveness of the LCM systems in place by the USCG. In an effort to better understand
the effectiveness of their programs, in 2009, the USCG commissioned a study by the Homeland Security
Institute to independently assess effectiveness of the USCG’s prevention programs and identify potential
improvement and found “[the] Coast Guard’s measures of effectiveness for marine safety include the
number of maritime deaths and injuries. These are lagging indicators that are recorded after tragic
events occur. To achieve a higher level of effectiveness, it would be very beneficial to identify leading
indicators of high-risk situations so that interventions could be achieved before tragic events occur”
(Homeland Security Institute, 2009).
4.1.1.6 Liabilities
The risk of legal liabilities to the government regulatory body and to the members of the regulated
industry is relative based on a particular incident that may occur as it relates to the life cycle of a critical
2
The certificate is valid for five years, and the approval will be listed on the internet at http://cgmix.uscg.mil.
BSEE should consult with the USCG to explore the possibility of sharing information stored in MISLE.
MISLE could help identify the success or deficiencies of an LCM maintenance or inspection schedule as
they relate to offshore vessels. The USCG Office of Investigations and Casualty Analysis (CG-INV) has
extensive experience analyzing the data in MISLE and could therefore provide assistance to BSEE.
4.1.2.1 History
Based on our research of available resources, the term “Life Cycle Management” is not used in FHWA or
DOT documents to specifically define or distinguish such processes. However, careful inspection of the
FHWA’s systems reveals that LCM systems do exist even, if not termed in such a way. This report will use
the term LCM to describe the processes found during our research, comprised of the following systems:
The 23 CFR 500 sections that provide instructions for the systems listed above are not binding on the
state. The state may choose to develop their management systems internally using its own resources or
to contract any or all of these management systems to be developed for its use. For example, the 23 CFR
500.205 (d) requires, “Pavements shall be designed to accommodate current and predicted traffic needs
in a safe, durable and cost-effective manner,” but does not specify how the state is to meet the
requirement.
While the FHWA has three LCM systems, they each have a different history. The PMS began at
engineering workshops held in 1980 in Phoenix, Arizona and Charlotte, North Carolina. The discussion
held addressed how to measure the condition of pavements to prioritize maintenance planning. Before
that, states used their own methodologies to assess and prioritize pavement maintenance within their
respective domains. The BMS began as a software tool developed in the 1990’s under an FHWA contract
to the American Association of State Highway and Transportation Officials (AASHTO). The SMS was
envisioned at a 1981 symposium whose objective was to enhance highway safety through engineering
management. The SMS requirements approach was directed by the ISTEA Act of 1991. Further
legislation from the Highway Safety Act of 1996 provided comprehensive requirements for safety
management that became the responsibility of each state’s governor.
The Moving Ahead for Progress in the 21st Century Act: MAP-21 requires minimum standards for
conditions of interstate pavements by requiring a state to devote resources to improve the conditions
until the established minimum is exceeded. The Secretary will establish the minimum standard for
Interstate pavement conditions, which may vary by geographic region. If interstate conditions in a state
fall below the minimum set by the Secretary, the state must devote resources to improve conditions.
During the same time as the original ISTEA legislation was the implementation of 23 CFR 500.106
The parent organization to AASHTO, the American Association of State Highway Officials) was founded
in 1914. The name was changed to AASHTO in 1973. Although AASHTO is not a government body, its
guidance is incorporated into the 23 CFR 500 regulations, similar to the incorporation of API standards
into the CFR regulations for the O&G industry, but with the exception that 23 CFR 500 does not mandate
a PMS system. However, the findings made during the research for this report indicated that most, if not
all, of the states and the District of Columbia have PMS systems in use. Training programs, seminars, and
workshops are available by both the FHWA and AASHTO to support consistency of SMS programs by the
states.
Bridge Management System: BMS requirements are shown in 23 CFR 500.107 and state that the BMS
system should be based on the AASHTO Guidelines for BMS 4 and utilize modeling to forecast the need
for preventative maintenance and predict bridge structural deterioration. The management systems
approach was implemented by ISTEA of 1991, which is now MAP-21, signed into law in 2012.
Safety Management System: The requirements for an SMS are found in 23 CFR 500.108, where it states
the SMS may be based on the guidance found in Safety Management Systems: Good Practices for
Development and Implementation. Additionally, MAP-21 requires every state to develop a Strategic
Highway Safety Plan (SHSP). Under its Safety Performance, MAP-21 provides that:
• States will set targets for the number of serious injuries and fatalities and the number per
vehicle mile of travel. If a State fails to make progress toward its safety targets, it will have to
devote a certain portion of its formula obligation limitation to the safety program and submit an
annual implementation plan on how the State will make progress to meet performance targets.
• Although MAP-21 eliminates the requirement for every State to set aside funds for High Risk
Rural Roads, a State is required to obligate funds for this purpose if the fatality rate on such
roads increases.
• The Secretary is required to carry out a study of High Risk Rural Road “best practices.”
• States are required to incorporate strategies focused on older drivers and pedestrians if
fatalities and injuries per capita for those groups increase.
3
AASHTO (1985). Guidelines on Pavement Management, American Association of State Highway and
Transportation Officials, Washington D.C., 9p.
4
Bridge Maintenance, Safety, Management, Life-cycle Performance and Cost: Proceedings of the Third
International Conference on Bridge Maintenance, Safety and Management, Porto, Portugal, 16-19 July 2006
PMS details are discussed in 23 CFR 500.106, which suggests that the PMS be based on AASHTO
requirements noted below:
• Data collection and management – An inventory of physical pavement features including
number of lanes, length, width, surface type, functional classification, and shoulder information.
o A history of project dates and types of construction, reconstruction, rehabilitation, and
preventive maintenance.
o Condition surveys that include ride, distress, rutting, and surface friction.
o Traffic information including volumes, classification, and load data.
• Analysis, at a frequency established by the State, consistent with its PMS objectives.
o A pavement condition analysis that includes ride, distress, rutting, and surface friction.
o A pavement performance analysis that includes an estimate of present and predicted
performance of specific pavement types and an estimate of the remaining service life of all
pavements on the network.
o An investment analysis at network and project levels.
o An engineering analysis for appropriate sections to include evaluation of how design,
construction, rehabilitation, materials, mix designs and preventative maintenance all relate
to pavement performance.
• Annual evaluations and upgrades as necessary in conformance with agency policies, practices,
engineering criteria, and experience.
The PMS LCM processes involve inspections to measure and determine the deterioration of the
pavement over time. The evaluation protocols include use of an International Roughness Index (IRI),
measurement of rut depth, faulting and cracking. These measurements are taken periodically as
determined by the state. This PMS LCM evaluation process has been evolving by the states but some
form of LCM has been adopted and in use since the 1980 workshops (Transportation Research Board,
2003).
For an effective BMS, the 23 CFR 500.107 states that at a minimum, it should include procedures for:
• Collecting, processing and updating data
• Predicting deterioration
• Identifying alternative actions
• Predicting costs
• Determining optimal policies
• Performing short and long term budget forecasting
• Recommending programs and schedules for implementation within policy and budget
constraints
An example of a state developed process is a web enabled role based relational database structure first
implemented in 2009 by Texas. This system allows data to be:
• Directly populated
• Validated prior to acceptance
• Stored electronically
• Easily audited
• Easily available to end users (Freeby, 2013) (AASHTOWare, n.d.)
For SMS, the 23 CFR 500.108 includes a minimum list of requirements that the SMS should meet. Within
these requirements the SMS LCM process can be extrapolated as requiring a constant evaluation and
reevaluation of driver, road and vehicle interactions. The SMS LCM process can be described as having a
goal of reducing driver injuries and destruction of property to the lowest possible achievable through
research and evaluation of road conditions to reduce/eliminate all possible unsafe situations.
Specifically, this goal is to be emphasized by leadership to keep a focused vision on accomplishment by:
• Development of an SMS for all public roads
• Incorporation of all roadway, human and vehicle safety elements
• Establishing formalized and interactive communications and cooperation among the major
highway safety elements
• Using projects and programs identified by use of the SMS in their Highway Safety Plan and
Motor Carrier Safety Assistance Program State Enforcement Plan
• Coordination of development, establishment and implementation of the SMS within all agencies
responsible for roadway, human and vehicle safety
The LCM structure for SMS is found within the eight elements that are suggested to be incorporated in
the SMS:
1. Establishment of short and long term highway safety goals.
2. Establishment of accountability by identifying and defining safety responsibilities of units and
positions.
3. Recognition of institutional and organizational initiatives at state and local levels, assessment of
responsibilities, establishment of coordination, cooperation and communication mechanisms.
The data collected within these management systems appears to align, at least partially, to an LCM
system because a dedicated LCM and PMS, BMS, SMS processes are all working toward the same goal –
to use carefully selected data parameters, consistently and qualitatively taken to assist management to
make informed decisions regarding construction, maintenance and replacement of system assets with
regard to safety, budget limitations and time constraints.
Non-public clients that may require PMS and BMS include neighborhoods that use private roads,
churches, private schools, businesses, and property owners in rural areas.
The results from LCM processes and the recommendations made from their analysis can only be as
effective as the type and quality (accuracy) of the database parameters chosen to be acquired and then
selected to base transportation decisions on, the ability to scale up or down the response to LCM
decisions based on those parameters and the funding made available to each system to perform its job.
It was interesting to find that the National Transportation Safety Board (NTSB) does not provide the
state DOT’s with data collected during investigations undertaken in states where accidents above some
threshold have occurred. This data may be available through public means but this project did not find
evidence of a direct sharing of information between the NTSB and state DOT PMS, BMS, SMS programs.
During the 1970’s several firms began collecting data on pavement management. The Pavement
Management Primer describes how these studies revealed five key areas:
1. Pavement Deterioration—Pavements tend to deteriorate very slowly during the first few years
after placement and very rapidly when they are aged. Even though pavement designs and
materials varied widely, the deterioration of pavements followed a standard curve. This curve,
pavement condition versus age, is shown in Figure 5. (x-axis = number of years, y-axis = quality of
pavement in terms of percent)
2. Costly Maintenance Practices — Typically, State and local governments invest more funds for
maintaining highways than for any other public purpose. While much of this is due to the high
cost of repairs and heavy usage of the highways, there is strong evidence that some of the high
operating costs originate from inappropriate or poorly timed maintenance decisions.
3. Preserve versus Reconstruct — Successive years of collecting pavement condition data showed
that it was far more economical to preserve roads than to delay repairs and reconstruct roads.
The studies further showed that as traffic levels increase the costs of delaying repair work
increased greatly. This suggested that the traditional practice of repairing the worst roads first
is, in fact, a very expensive way to operate a highway system.
4. Data Collection Problems — Data collection by observation was very difficult and was often not
objective. Data collection on large highway systems usually required several observers to collect
data and led to inconsistencies in the data. This finding led to the development of vehicles that
mechanically measure smoothness and other road conditions.
5. Using Computers — Early mainframe computers took as much as a week to analyze pavement
data and cast some early shadows on the value of the process. With the incredible computing
power available on today’s desktop computers, these analyses can be run in a matter of seconds.
This allows decision-makers to consider numerous “what-if” alternatives. (Federal Highway
Administration, pp. 2-3).
4.1.2.7 Outcomes
The FHWA measures the outcome of its various LCM systems in a few different ways. Of the 52 DOT
agencies, 47 of them use IRI for their PMS to measure ride quality for drivers. In addition, these
agencies use ten different types of equipment to take measurements. Unfortunately, it is difficult to
compare IRI across DOTs since not only does the equipment vary but also the method of measurement.
One agency may measure the right-side wheel path only while another may measure only the left side;
some agencies report only the worst wheel path and some use an average value from both wheel paths.
According to a publication by FHWA, “among the 19 states that provided information about criteria for
determining quality levels, the beginning of the unacceptable (poor) level for IRI measurements ranged
from 450 inches per mile (7.09 meters) to 45 inches per mile (0.71 meters)” (Finn, 1998). We did not find
significant information on how BMS and SMS outcomes are measured across the industry.
4.1.2.9 Liabilities
If state DOTs do not properly manage roads using PMS and road conditions become unsafe (i.e.,
potholes), the state DOT could be liable if a driver is involved in an accident from faulty road conditions.
The same could be true for any incidents involving the degradation of bridge safety due to a faulty BMS.
While the FHWA’s liability may be less severe than the state DOT, the FHWA still risks slight legal liability
should the state DOT place blame on the FHWA for not mandating and designing PMS, BMS, and SMS
for all state DOTs.
Similar to the common national goal mentality instituted by the FHWA, BSEE may want to consider
requiring that their constituents work to goals developed and agreed upon by the BSEE and the OCS
O&G Industry towards a common national goal. This leaves flexibility in the regulation to allow the
Industry to find the best way to achieve those goals without the encumbrance of meeting well intended,
but unnecessary, extraneous rules that add cost and time without adding benefit.
4.2.1.1 History
The Health and Safety in Employment (Petroleum Exploration and Extraction) Regulations 2013 (SR
2013/208) were enacted on June, 5th, 2013. These regulations require organizations requesting to
conduct business within New Zealand to develop and establish a SMS.
Under the Health and Safety in Employment Act, the Department of Labor has established and
developed Approved Codes of Practice (Best Practices). These codes of practice are not legislation, but
deemed statements of good practice under the Act. Failure to follow approved codes of practice is not a
violation; however, they are recognized by the New Zealand court system and may be produced as
evidence of suitable means of compliance with the Act. Under the Act, there is a specific process of
approval prescribed for developing Approved Codes of Practice. Gazette Notices are published
announcing proposed Approved Codes of Practice. These are followed by consultation and approval by
the Ministry after all consultations by any interested party have been completed. Although Approved
Codes of Practice are available to the public, a nominal fee may be charged to obtain copies of the
approved codes.
It is the duty holder’s and or operator’s responsibility to ensure all operations specifically follow the
requirements described in the facilities Safety Case and report all deviations as may be required by
regulations. Reportable deviations may include: serious injuries or fatalities, major accidents, or major
environmental damage.
It is also the role of the operators to ensure arrangements are in place for periodic assessments of the
facilities safety and materiel integrity. Operators must also schedule independent and competent
persons to verify that the safety critical elements of the facility are in place and effective as described in
the installations Safety Case.
The primary role of industry is to ensure all regulatory requirements are met and all health, safety, and
environmental laws are followed. In the event of serious accidents or significant environmental damage,
it is the operator’s responsibility to report these incidents as required under New Zealand laws and
regulations. Ultimately, the operator’s role is to provide a safe and environmentally friendly work
environment for employees.
4.2.1.6 Effectiveness
No specific effectiveness data could be identified during the research for this project; however, New
Zealand regulations require a performance monitoring process be included in the SMS. Though New
Zealand regulations do not require an LCM system be developed by name, if mandated SMS
requirements are met and adhered to, then effectively, an LCM system would be in place. Organizations
continue to operate in New Zealand so it can be assumed that the SMS process is effective.
4.2.1.8 Data
There is no data available to identify examples of LCM systems for the New Zealand SMS program. The
New Zealand regulations do not specify how an operation establishes an LCM system. If an organization
has an LCM system, it must be specifically addressed and the process clearly defined in the safety case
developed by the duty holder and/or operator. It would then be the responsibility of the duty holder
and/or operator to have the LCM system approved as described in the safety case, make all required
reports, and make the program available for audit and review as required under New Zealand
regulations.
4.2.1.9 Liabilities
There is no information available to determine the effects of legal liability for the New Zealand Health
and Safety in Employment (Petroleum Exploration and Extraction) Regulations 2013 (SR 2013/208) SMS
program (New Zealand Government Parlimentary Council Office, 2013). The duty holder and/or
operators are responsible for developing the facility safety case and ensuring all responsibilities
associated with the safety case are followed. It can be assumed that most legal liability then rests with
the duty holder and/or operator. When the New Zealand government approves a safety case, they are
then agreeing with the construct of the facility’s plan to operate. This would then imply that the
government assumes some liability and responsibility for an organization to begin operations.
The burden of responsibility and the specifics of how a facility meets the required elements of the
regulations are placed solely on the industry organization, as long as the safety case meets the
requirements of the regulations and is approved by the New Zealand government. How the elements of
safety case are specifically developed and executed are the responsibility of the industry organization
requesting authorization to build and operate a facility.
4.2.2.1 History
Norway’s PSA develops, implements, and enforces regulations that pertain to the health, safety, and
environmental factors associated with the petroleum activities on the Norwegian Continental Shelf and
land-based facilities in Norway. The PSA is an independent government regulator for the Norwegian
Petroleum Industry whose offshore regulations rely heavily on national and international standards
(Petroleum Safety Authority, 2014). An effort was made a few years back to revise the regulations to
become functionally risk-based, with guidelines to suggest how the regulations could be fulfilled. This
effort resulted in a significant reduction of regulatory text (from 1,200 to 300 pages) on account of
references to standards. In the same timeframe, some of the text in the previous regulations was used
as basis for the development of the industry NORSOK standards (International Association of Oil and Gas
Producers, 2010).
From the documentation process detailed in Table 2: Norway PSA Process, it is readily apparent that the
PSA upholds an LCM-based mindset in its regulations. Before operations can commence the potential
operator must have an approved plan that accounts for health, safety, and environmental factors; risk
analysis; emergency preparedness; maintenance; and decommissioning. Once operations begin, the
various components of a Failure Reporting System are also required through a documentation process
of alert notifications and follow-up reports. The continual development of preventative measures is also
maintained through monitoring pollution and the re-evaluation of risks and corrective action plans.
As mentioned earlier, the PSA does cite IADC health, safety, and environmental case guidelines as
requirements or adhered to with an acknowledgement of compliance in order to obtain a permit of
operations (American Petroleum Institute, 2013). In its guidelines, the IADC cites ISO 14001,
Occupational Health and Safety Advisory Services (OSHAS) 18001, and ISO 17776 as relevant standards
for which it developed some of its recommendations. However, these provide little insight into
minimum requirements.
It should also be noted these standards may have overlap with ISO and API standards.
The Forum, a “tripartite” collaboration between company, union, and governmental representatives of
the Norwegian O&G industry, was first developed in the mid-1980s. Overall, the PSA asserts that the
purpose of the Regulatory Forum is to mitigate antagonism between industry and the regulations
applied to industry (Safety Status and Signals, 2012). The PSA emphasizes its role to, “secure the
necessary risk management” from industry, but also recognizes that industry must agree with the goals
behind additional regulation and guidance (Safety Status and Signals, 2012). Specifically, through
“discussion, debate, and contributions” from all three parties – industry, unions, and government
agencies – the PSA hopes to reach a consensus on all issues brought up in the Regulatory Forum (Safety
Status and Signals, 2012).
Both the documents are published in English and Norwegian, but interpretations of them are only
available in Norwegian. In the event of any ambiguity of language, the Norwegian translations take
precedence (Petroleum Safety Authority, 2014).
a) “Identify conditions that can lead to failures, hazard and accident situations
b) “Reduce the possibility of failures, hazard and accident situations occurring and developing
c) “Limit possible harm and inconveniences” (Petroleum Safety Authority, 2014).
Guidelines: The guidelines elaborate, “The requirement does not necessarily entail the establishment of
a separate management system for health, safety and environment” (Petroleum Safety Authority, 2014).
Overall, the PSA emphasizes that risk management regulations and guidelines should prevent both
equipment failure and human error. The LCM mindset manifests itself as risk management is not just
about installing proper safety equipment, but involves “organizational solutions” that reflect a risk-
based analysis of the entire operational process.
Chapter III: Objectives and Strategies, Internal Requirements, and the Basis for Making Decisions
Regulations: For this chapter, the PSA defines the broader responsibilities of the operator in terms of
adhering to general PSA principles. The operator, or “responsible party,” must develop “internal
requirements that put regulatory requirements in concrete terms, and that contribute to achieving the
objectives for health, safety and the environment.”
Moreover, the operator must also establish an “acceptance criteria for major accident risk and
environmental risk,” including cases for:
a) “The personnel on the offshore or onshore facility as a whole, and for personnel groups exposed
to particular risk
b) “Loss of main safety functions (as defined in Section 7 of the Facilities Regulations for offshore
petroleum activities)
c) “Acute pollution from the offshore or onshore facility,
d) “Damage to third party.” (Petroleum Safety Authority, 2014)
Guidelines: Providing some explicit definitions, the guidelines define a major accident as “an acute
incident such as a major spill, fire or explosion that immediately or subsequently entails multiple serious
personal injuries and/or loss of human lives, serious harm to the environment and/or loss of major
financial assets.” Additionally, environmental risk is defined as “the risk of acute pollution” (Petroleum
Safety Authority, 2014).
The PSA grants responsible parties a fair amount of autonomy in setting customized acceptance criteria.
However, it must be noted that this also allows for a large degree of flexibility on the part of industry to
innovate and adapt existing methods for overall improvement. An approach of this style is heavily
dependent on the O&G industry’s willingness not only to comply with the less concrete regulations set
forth, but to also orient themselves in a direction that greatly emphasizes health, safety, and
environmental best practice adoption.
Guidelines: The guidelines clarify these minimum requirements can be encompassed by “plans where
health, safety and environment are integral parts” (Petroleum Safety Authority, 2014).
Chapter V: Analyses
Regulations: The PSA stipulates that all risk analyses must:
a) Identify hazard and accident situations;
b) Identify initiating incidents and ascertain the causes of such incidents;
c) Analyze accident sequences and potential consequences; and
d) Identify and analyze risk-reducing measures. (Petroleum Safety Authority, 2014).
In addition, “risk analyses shall be carried out and form part of the basis for making decisions when:
a) “Identifying the need for and function of necessary barriers;
b) “Identifying specific performance requirements of barrier functions and barrier elements,
including which accident loads are to be used as a basis for designing and operating the
installation/facility, systems and/or equipment;
c) “Designing and positioning areas;
d) “Classifying systems and equipment;
e) “Demonstrating that the main safety functions are safeguarded;
f) “Stipulating operational conditions and restrictions; and
Moreover, “emergency preparedness analyses shall be carried out and be part of the basis for making
decisions when:
Furthermore, the PSA asserts that operators are to set their own requirements on data collection in
regards to “the quality and validity of the data, based on the relevant need” (Petroleum Safety
Authority, 2014).
While this approach creates less of a burden on industry than a rigid data set to be reported, the
potential shortcomings of these regulations relate to data’s quality and overall usefulness. Allowing
individual operators to set customized data requirements could result in multiple datasets from the
various operators that are incomparable. The PSA does not provide a specific enough definition of the
data it seeks, thus feasibly undermining the later analyses of that data.
For incident reporting, the PSA once again grants the operators the ability to set their own criteria “for
which situations … must be registered, examined and investigated. Moreover, the operators will also set
the ‘requirements ... for scope and organization’ of the investigation process” (Petroleum Safety
Authority, 2014).
a) “Death
b) “Serious and acute injury
c) “Acute life-threatening illness
d) “Serious impairment or discontinuance of safety related functions or barriers, so that the
integrity of the offshore or onshore facility is threatened
e) “Acute pollution.”
Additionally, the PSA requires that such notifications over the phone must also “be confirmed in
writing.” For pollution accidents or hazards, reporting must be “in accordance with the Regulations of 9
July 1992 No. 1269 relating to notification of acute pollution, etc. (in Norwegian only)” (Petroleum
Safety Authority, 2014).
4.2.2.6 Effectiveness
Measures of effectiveness for the PSA’s LCM system regulations and guidelines cannot be divorced from
explicit success and failure measures found in the Trends in Risk Level Norwegian Petroleum Activity
RNNP failure-based analysis system. Discussed more thoroughly in Task 3, RNNP and its subsequent
reports are used to identify areas involving the highest level of risk, and thereby the priorities for
surveillance. RNNP includes both qualitative and quantitative indicators on health, safety, and
environmental conditions, the data from which is analyzed and published annually.
4.2.2.7 Outcomes
The PSA assists the Ministry of Labor and Social Affairs (ASD) in developing acceptable Health, Safety,
and Environment, as well as Emergency Preparedness plans within the O&G industry (see Figure 6). As
mentioned previously, the PSA collaborates heavily with industry in the development of regulations that
ultimately meet the expectations of the ASD. Therefore, through programs like the Regulatory forum
and RNNP, the PSA can readily communicate with industry to ensure these goals are achieved (Eriksson,
2014).
4.2.2.9 Liabilities
The regulations enforced by the PSA are based on the prescriptions of the following legislation:
The PSA regulates the O&G industry to ultimately ensure it meets the adequate emergency
preparedness and Health, Safety, and Environmental goals for the ASD. The PSA has the authority to
both issue and revoke operating licenses, in addition to conducting routine inspections of facilities and
practices to maintain the specified levels of safety set with the ASD (Eriksson, 2014).
In an effort to standardize the O&G industry further, the PSA has also worked to incorporate ISO and API
references into its regulatory text. As internationally recognized and pervasively used documents, the
ISO and API standards provide the PSA with a well-established foundation for additional regulations in
line with its specific goals. The PSA was able to significantly diminish the volume of its own regulatory
text with references to ISO and API standards, reducing the amount of legal review and research on the
part of drilling companies to obtain a permit of operations, while still maintaining an acceptable level of
LCM planning.
KP4 evaluated several ‘duty holders’ drilling in the UK, both onshore and offshore along the following
lines:
The HSE carefully defines “ageing equipment” in the scope of continued use stating, “the management
of equipment begins with an awareness that ageing is not about how old the equipment is, but is about
what is known about its condition, and the factors that influence the onset, evolution and mitigation of
its degradation” (U.K. Health and Safety Executive, 2006). Necessarily, with KP4, the HSE sought to
establish a more uniform system of evaluating equipment that had exceeded its anticipated life span in
terms of an acceptable level of operational safety.
Moreover, the HSE requires that IADC guidelines are followed in the development of safety cases
(International Association of Drilling Contractors, 2015). While these guidelines give a general
framework for health and safety cases, the HSE’s KP4 offers a more in-depth approach for regulating the
ageing and life extension of safety critical elements.
Building on KP3, KP4 was proclaimed to be more progressive and collaborative than its predecessor. KP3
“focused primarily on the maintenance management of SCEs [safety critical elements], and reported
back on the findings of their condition” (U.K. Health and Safety Executive, 2012). It also “assessed the
condition of assets (AIM) at the time of the inspections.” The HSE emphasizes strongly that “KP4 is
forward-looking, inspecting duty holders’ abilities to anticipate and prepare for the integrity challenges
of the future, up to cessation of production” (U.K. Health and Safety Executive, 2014). Thus KP3 sought
to correct existing problems as they were discovered, while KP4 was designed to anticipate such
problems and make adequate adjustments before safety issues arose.
In conjunction with the KP4 report, the HSE issued a guide on managing ageing plants. In the report, the
HSE asserted “the identification and management of ageing plant issues in relation to process safety is
recognized in a number of key risk control systems.” Of these systems, elements deemed crucial by the
U.K. HSE (2014) for regular inspection and maintenance were:
• Maintenance Management Systems
• Asset Management and Integrity Systems
• Audit and Inspection regimes
• Risk Assessment Management processes
• Management of Change procedures
In accordance with HSE RR509 and HSG65 (UK HSE, 2014), the specific considerations listed for each
element are listed in Table 3 below.
The HSE makes use of RR 509 and HSG65, in addition to RR 076, RR 253, API RP 571, API RP 574, and API
RP 1160. (U.K. Health and Safety Executive, 2014). Beginning with the Research Reports (RR 509, RR 076,
and RR 253), all three detail the management and inspection specifics for certain types of machinery.
This recommended practice (RP) supplements API 570 by providing piping inspectors with
information that can improve skill and increase basic knowledge and practices. This RP describes
inspection practices for piping, tubing, valves (other than control valves), and fittings used in
petroleum refineries and chemical plants. Common piping components, valve types, pipe joining
methods, inspection planning processes, inspection intervals and techniques, and types of
records are described to aid the inspector in fulfilling their role implementing API 570. This
publication does not cover inspection of specialty items, including instrumentation and control
valves (American Petroleum Institute, 2009).
This recommended practice (RP) is applicable to pipeline systems used to transport “hazardous
liquids” as defined in U.S. Title 49 CFR Part 195.2 … This RP is specifically designed to provide the
operator with a description of industry-proven practices in pipeline integrity management. The
guidance is largely targeted to the line pipe along the right-of-way, but the process and
approach can be applied to pipeline facilities, including pipeline stations, terminals, and delivery
facilities associated with pipeline systems.
This recommended practice (RP) outlines a process that an operator of a pipeline system can use
to assess risks and make decisions about risks in operating a hazardous liquid pipeline in order to
achieve a number of goals, including reducing both the number and consequences of incidents.
The HSE also utilizes good practice guides in asset management set forth in the Publicly Available
Specification (PAS) 55 and Contract Research Report (CRR) 363/2001. The Institute of Asset
Management defines PAS 55 as a standard that “provides objectivity across 28 aspects of good asset
management, from lifecycle strategy to everyday maintenance (cost/risk/performance). It enables the
integration of all aspects of the asset lifecycle: from the first recognition of a need to design, acquisition,
construction, commissioning, utilization or operation, maintenance, renewal, modification and/or
ultimate disposal.” Comprised of two parts, PAS 55 gives “definitions of terms in asset management
[and] requirements specification for good practice,” in addition to “guidance for the implementation of
such good practice” (Institute of Asset Management, 2008).
Contract Research Report 363/2001 “discusses the best practice for application of RBI as part of plant
integrity management, and its inspection strategy for the inspection of pressure equipment and systems
that are subject to the requirements for in-service examination under the Pressure Systems Safety
Regulation 2000 (PSSR).” To elaborate, CRR 363/2001 describes PSSR as “a risk-based approach to be
used for the planning of inspection. Notably, these regulations “allow the Duty Holder and Competent
Person flexibility in deciding upon a suitable written scheme of examination in terms of the equipment
to be inspected and the frequency and nature of examination” (Wintle, Kenzie, Amphlett, & Smalley,
Best practice for risk based inspection as a part of plant integrity management, 2008).
4.2.3.5 Effectiveness
The HSE uses separate templates for onshore and offshore inspections. While there is significant overlap
in the evaluation styles, they nonetheless require separate assessments in order to address their
differences. Effectiveness appears to be measured on the various scales employed by these templates.
Onshore Templates:
The HSE developed a “Traffic Light” system on a scale of 1-6, with 5 and 6 being red, 3 and 4 being
amber, and 1 and 2 being green. Through a series of questions, certain benchmarks are expected in the
answers to determine a duty holder’s score on the categories of ALE Policy and Leadership, ALE
Table 4: U.K. Health and Safety Executive Color and Compliance Codes
Score Color Code Compliance Action
6 Red Serious Non-Compliance Court Proceedings Recommended
5 Red Significant Non-Compliance Enforcement Notice Served
4 Amber General Non-Compliance Letter and Changes Made to Intervention
3 Amber Partial Compliance Letter
2 Green General Compliance Verbal Advice
1 Green General Compliance No findings
(U.K. Health and Safety Executive, 2014).
Offshore Templates:
The offshore templates consist of five areas:
• Review of documentation covering ageing/degradation mechanisms.
• Review of equipment/system physical condition.
• Discuss the impact of the ageing/degradation of the equipment/system with the personnel
who operate and maintain it.
• Assess how the known ageing/degradation has been used to modify the inspection plan. It is
expected this will be achieved by discussion with the onshore Technical Authority after the
offshore inspection.
• Assess how the known ageing/degradation has been used to inform the equipment/system
estimated life and used as an input into field life extension decisions. It is expected this will
be achieved by discussion with the onshore Technical Authority and Asset manager after the
offshore inspection (U.K. Health and Safety Executive, 2014).
While most employ the 1-6 scaled traffic light system seen in the onshore templates, a few use a three-
tiered system of red, amber, and green to each denote one level of satisfaction. It is unknown at this
time how long these systems of evaluation have, in a comparable form, existed in the HSE, but these
templates reflect the KP4 program objectives started in 2010.
While the KP4 program concluded in 2013, the HSE has not conducted a follow-up study assessing the
most current progress of ALE policies for its evaluated duty holders. In its final report, the HSE made
recommendations for itself in continuing the goals of KP4, specifically to “continue to be involved with
the industry, and maintain the positive dialogue which has taken place during the KP4 program for the
long-term safety of offshore workers.” It also planned to:
The inspection templates seem particularly beneficial as they introduce a more elaborate grading
scheme than a simple pass/fail system. The six tiers partitioned into three groups offer more
information on why a duty holder manages an acceptable or unacceptable rig. Moreover, the system to
determine grading reinforces the positive dialogue HSE noted when reporting on the completion of KP4.
4.3 Industry
The information in this sub-section describes the data collected for the following organizations: ISO, API,
American Waterway Operators (AWO), Industry Representatives, and IADC.
4.3.1.1 History
The RCP has been in place since 07 December 1994 when the board of directors of the AWO
unanimously approved the establishment of the program. In April 1998, the AWO changed its
organizational bylaws to require members to demonstrate a “good faith commitment” with RCP as a
condition of membership. In January 2000, 100 percent of the remaining member organizations were in
“audited compliance” with RCP. To achieve compliance, member organizations were given until 01
January 2000, or within two years of joining the AWO. Thirteen chose not to comply with the new
requirements (American Waterways Operators, 2013).
On 07 December 1994, AWO unanimously approved the establishment of the AWO RCP as a code of
practice for association member companies. Within AWO’s Strategic Plan, AWO 2000, it states their
overall goal is to “improve industry safety and environmental protection by establishing preferred
industry operating principles and practices,” utilizing the process of industry self-examination which
began in the wake of the September 1993 derailment of the Amtrak Sunset Limited (American
Waterways Operators, 2013).
The RCP serves as a template for AWO member companies to use for developing company-specific
safety programs, including maintenance programs. These programs must be consistent with applicable
law and regulation, but can also incorporate sound operating principles and practices not currently
required by law or regulation. Overall, these individualized programs are practical and flexible enough to
reflect a company's unique operational needs. In addition, RCP combines a set of common principles
and practices that can be observed by a company regardless of its trade or its size, with an emphasis on
company-specific policies and procedures, which may vary significantly both between and among
industry sectors. For instance, the RCP requires all crewmembers onboard vessels be properly trained;
however, training programs do not necessarily have to be USCG-approved, but must be formal and well
documented (American Waterways Operators, 2013).
In 2008, AWO determined that as requirement for membership, its current and prospective members
should achieve compliance with the AWO RCP and undergo an AWO-certified audit of their program
within two years of joining. Failure of a company to complete its required RCP audit within the time
allowed would result in AWO immediately removing the company’s certification of RCP compliance and
a termination of membership (American Waterways Operators, 2013).
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1) Vessel Operating Policies and Procedures: AWO RCP states that companies are to develop specific
operating and maintenance procedures. The vessel-specific operating procedures will depend on vessel
size, cargo, and trade, along with procedures for making horsepower/tow size decisions. Vessel
maintenance procedures are to include maintenance schedules, qualifications and training requirements
for maintenance personnel, procedures to correct deficiencies identified during maintenance, and
maintenance record retention and reporting requirements.
2) Safety Policy and Procedures: AWO RCP mandates that companies have an implemented safety policy
that includes an accountability for and commitment to safety. A company must also provide safety
training, safety drills, and safety meetings (including station bill) accompanied by training on safe use of
equipment, corrective action processes, and hazard communication procedures (right to know) under 29
CFR 1910.1200.
4) Environmental Policy and Procedures: AWO RCP states that a company is to have a company-wide
environmental policy that includes garbage disposal requirements, procedures and documentation,
handling of waste oil, oily bilge slops, used filters, hazardous waste disposal and handling, sanitary
systems, and handling of sewage procedures.
5) Incident Reporting Procedures: AWO RCP states that a company is to have an incident reporting
procedure that contains guidance for personal injury, oil or hazardous substance spill, vessel accidents,
bridge, lock, or dock allusion and grounding incidents.
6) Emergency Response Procedures: AWO RCP states that a company is to: have emergency response
procedures for personal injury responses; develop a spill response plan and/or contingency plan; and
develop procedures for vessel accident response, onboard emergency response training, drill
procedures, and operator incapacitation procedures.
7) Internal Audit and Review Procedures: AWO RCP requires a company to establish procedures for
conducting annual internal audits, which include procedures to ensure compliance with applicable
Federal laws and regulations concerning marine safety and environmental protection, personal injury
investigation procedures, spill investigation procedures, vessel accident investigation procedures, and
communication procedures for disseminating lessons learned.
8) Vendor Safety: AWO RCP requires companies to establish procedures for the evaluation of
subcontractors and vendors providing services.
9) Organization and Levels of Authority: AWO RCP requires a company to have appropriate levels of
authority and accountability including vessel master and crew. In addition, the AWO RCP requires the
company to designate a person(s) ashore having direct access to the highest level of management.
10) Personnel Policies and Procedures: AWO RCP requires a company to have certain policies and
procedures regarding its employees including: a formal hiring policy; physical exams or a physical
standards policy; and a robust drug and alcohol policy, pursuant to 46 CFR 16.210.
In regards to Coastal Equipment and Inspections, AWO looks at many different aspects as part of its
requirements within the RCP, of particular note are:
1) Hulls
2) Machinery
3) Firefighting and Lifesaving Equipment (American Waterways Operators, 2013)
1) Hulls: AWO RCP requires documented inspections of each vessel operated by an RCP member
company by an appropriate company representative or third-party personnel. Such inspections are an
important component of sound vessel maintenance and a LCM system.
3) Firefighting and Lifesaving Equipment: AWO recommends through RCP that a check-off report should
be turned in or a log entry made at least quarterly verifying that the required firefighting and lifesaving
equipment is present and in proper working order.
All AWO carrier members are required to be in compliance with all applicable federal laws and
regulations concerning marine safety and environmental protection as a baseline. All company policies
and procedures should be consistent with applicable law and regulation and with the guidelines
provided in the Equipment and Inspection and Human Factors sections of the AWO RCP (American
Waterways Operators, 2013).
The RCP incorporates best industry practices in three areas: company management policies, vessel
equipment LCM and human factors. The comprehensive program requires companies undergo an audit
by an independent third party-auditor to verify compliance (American Waterways Operators, 2015).
4.3.1.5 Effectiveness
All RCP auditors were required to complete TVIB-led recertification training in 2013. By year’s end, 68
new and recertifying auditors had been trained, 23 AWO members received training in best practices for
internal auditing and 37 auditors completed Responsible Care Joint Audit Program training conducted by
the American Chemistry Council. TVIB also worked with the RCP Standards Board to develop a new RCP
management audit worksheet to assist auditors and AWO Members in preparing for an effective audit
(American Waterways Operators, 2013). There are 222 member organizations in the AWO. All member
organizations are RCP certified; 10 member organizations are operating on a 1st year provisional
certification, the remaining 212 member organizations are RCP certified from 2015 through 2019,
depending on their most recent certification audit.
Figure 7: RCP Audit Flow Chart (Towing Vessel Inspection Bureau, 2014)
4.3.1.7 Data
Companies maintain their own data from their system internally. AWO mandates audits of the system to
certify compliance with the RCP but does not collect or use the data. The audits are specifically
conducted to ensure compliance with the program.
4.3.1.8 Liabilities
Because the AWO is a trade association, the RCP is based on improving marine safety and environmental
protection rather than superseding USCG standards. Therefore, while the elements of the RCP may meet
or exceed USCG standards, each industry member has its own responsibility to determine their own
operational standards and therefore the liability is upon the various industry members and not on the
AWO or USCG. Unless Federal or state law were to lessen liability or exempt an AWO member in
compliance with the RCP, the full panoply of pre-existing environmental and maritime/shipping liability
laws and statutes apply to AWO members carrying out the RCP. Our extensive search of those Federal or
state laws found no lessening or exemption of potential liability. Because of time and cost constraints
and the small likelihood of finding anything on the state level, a full search of all state statutes in the 20+
states with waterways was not attempted to definitively answer this question.
AWO RCP, if fully followed by any particular company in the industry, may very likely lessen the
likelihood of non-compliance with these laws and of any illegal bilge release or oil spill, thus lessening
the likelihood of liability for that company. Yet the full panoply of potential civil and criminal penalty
liability remains, along with a myriad of potential maritime or common law tort litigation arising from
the private sector.
Environmental civil liability is often strict liability; it usually arises simply through the existence of the
environmental violation, without regard to what the responsible party knew about the matter.
Environmental criminal liability is triggered through the existence of some level of intent. Because of
this distinction, most of the environmental crimes that EPA investigates involve “knowing violations” of
the law, which are usually classified as felonies. A “knowing violation” is one in which the defendant is
aware of the facts that constitute the violation – an instance in which conscious and informed action
brought about the violation, rather than, as would be the case with a civil violation, an accident or
mistake. For example, an intentional decision to discharge oil or pollutants into a river could be a
“knowing violation,” and thus criminal, without regard to the defendants knowledge of the law.
Any voluntary industry sponsored compliance and self-inspection regime that a company has a track
record of following could arguably tip the balance in any litigation or administrative determination
toward a finding of “an accident or mistake” where conflicting evidence may not fully convince an
administrator, judge, or jury of a “willful and knowing” violation. Thus, a self-inspection or voluntary
compliance regime like the RCP could lessen the potential liability of criminal penalties or criminal
negligence.
4.3.2.1 History
ABS Consulting has identified three API sets of standards which pertain to LCM. These are: API 16AR –
API Monogramed Parts, API Q1 – Quality Management Specifications for Manufacturing Organizations
and API Q2 – Quality Management Specifications for Service Organizations. As a general principal, API
standards are revised with regular frequency. For example, API 16AR was recently revised in 2013 and
API 14B was revised in 2012. Similarly, API standards for LCM – Standards Q1 and Q2 – were updated in
June 2014 and December 2011, respectively.
While the term ‘Life Cycle Management System’ is not explicitly used in API Q2, the actions it
recommends, including preventative maintenance, change management and risk assessment, are all
part of a comprehensive LCM program (American Petroleum Institute, 2011).
4.3.2.5 Effectiveness
In order to determine the effectiveness of API’s programs, ABS Consulting spoke with our in-house
Subject Matter Experts (SMEs). In general, the SMEs reported that API does not conduct formal scientific
studies of the effectiveness of their programs, but instead rely on the committee system to update and
revise as needed.
However, industry feedback on API standards does come through the API committees’ process. The API
committees consist of industry members who participate in the development and updating of the
standards. The committee forms the voice of all interested stakeholders, including the industry. It is an
ongoing process, receiving feedback, comments and issues. If the standard is already published,
feedback can be communicated to API’s industry representatives, who then pass the information along
to the committee chairman for discussion at the next committee meeting. If the committee is no longer
active, API maintains a small group of individuals responsible for collecting and addressing inquiries and
feedback from industry.
In addition, API has a quality management system which tracks and updates their standards setting
process. All API standards are subject to review every five years. As part of this review, API frequently
checks on all of the standards that are active to see what the status is and if there any questions or
comments from the industry that need to be addressed. Part of the five year review is making sure that
all comments from industry are addressed, or at least discussed (John, American Bureau of Shipping Oil
and Natural Gas Senior Engineer, 2014).
4.3.2.6 Liability
Since API standards are voluntary and provide standards that meet or exceed legal requirements, API
will, most likely, not be held liable in case of a failure of an operator’s LCM system. Given that API is
setting a standard, the liability of compliance will be on the operator to implement the guidelines and
parameters provided in the standard.
While API 16AR, Q1 and Q2 accreditation is likely a marker for good LCM practices, BSEE should consider
supplementing API life cycle standards with additional metrics, reporting requirements, or regulatory
stipulations to counteract any potential tendency of industry operation management to merely “go
through the motions.”
4.3.3.1 History
The IADC mission is to improve performance for the drilling industry while increasing safety. Since 1940,
IADC has exclusively represented the worldwide O&G drilling industry. With the broad mission of
improving performance for the drilling industry, membership is open to any company involved in O&G
exploration, drilling, production, or well servicing (IADC, 2014).
In addition to these Asset and Reliability and KSA programs, this section will focus on the most widely
used IADC LCM system, Health, Safety, and Environment Case Guidelines. In January 2014, the IADC
issued Health, Safety, and Environment Case Guidelines for both Mobile Offshore Drilling Units (MODU)
and Land Drilling. While the IADC explicitly states, “the Guideline is not compulsory, its use is
recommended as a demonstration of good industry practice for Drilling Contractors.” Therefore, while
not an authoritative or mandatory interpretation of universal international drilling regulations, both
onshore and offshore, these guidelines serve as a general framework upon which drilling contractors
develop a Health, Safety, and Environment case tailored to their individual practices. As the IADC is an
international body, the varying jurisdictions its members may fall under is acknowledged with a strong
The IADC proposes a series of expectations and possible demonstrations a contractor may undertake in
order to prove it possesses an effective Health, Safety, and Environment case. The guideline states that
“the scope and arrangements for providing assurance internally and a demonstration externally [is] that:
• “There is an effective Health, Safety, and Environmental management in place for managing
major hazards, other workplace hazards, and environmental aspects;
• “All potential hazards have been identified; and
• “Risks associated with these hazards have been identified, assessed, and managed with any
residual risks reduced to tolerable levels” (IADC, 2014, pp. Section 1, Page 3).
While the guideline defines major hazards, various types of risk, and other similar vocabulary, it does
not give a qualitative or quantitative measure on perceived effectiveness. Once again, as IADC members
interact with different regulators and experience non-uniform policies and legislation, the guideline
emphasizes that, in terms of regulatory requirements, “arrangements for monitoring and confirming
that effective Health, Safety, and Environment management has been implemented and maintained …
[in] compliance with applicable regulatory requirements” must be pursued (IADC, 2014, pp. Section 1,
Page 6).
The lack of explicitly stated standards of effectiveness or success of a particular Health, Safety, and
Environment case proves the biggest drawback of these guidelines. While the IADC has made
considerable efforts in standardizing the creation and implementation of a Health, Safety, and
Environment case, the relative capabilities of these cases do not have a baseline against which they can
be assessed. The guidelines nevertheless offer a thorough framework and enable a large degree of
flexibility when developing a Health, Safety, and Environment case to suit the contractor’s needs. That
being said, in order to assure consistency in execution amongst its members, the IADC must issue a
complementary report that measures successful and unsuccessful practices.
Risk Management is defined in the guidelines as, “the coordinated activities to direct and control an
organization or activity with regard to risk” (IADC, 2014, pp. Section 4, Page 8). Refining this broad
The Emergency Response section of the guidelines offers a generalized approach that emphasizes
proper management, effective communications and an emergency command hierarchy, as well as
proper training of workers and an evacuation plan. None of these suggestions cite any regulatory
policies in particular, and rely heavily on the contractor to develop specific practices and plans in order
to effectively respond. While this, yet again, does allow for tailoring to suit the need, it seems the IADC
also relies on regulatory agencies to enforce certain specifics in regards to the overall response process.
According to ISO, ISO 14001 “sets out the criteria for an environmental management system and can be
certified to. It does not state requirements for environmental performance, but maps out a framework
that a company or organization can follow to set up an effective environmental management system”
(International Organization For Standardization, 2014). The fact that the IADC faltered in stating explicit
requirements and standards for Health, Safety, and Environment case effectiveness appears more
justified, as even the ISO has not stringently defined baseline standards.
ISO 17776 pertains mostly to the Risk Management section of the guidelines. The ISO states,ISO 17776
“describes some of the principal tools and techniques that are commonly used for the identification and
assessment of hazards associated with offshore O&G exploration and production activities…. It provides
guidance on how these tools and techniques can be used to assist in development of strategies both to
prevent hazardous events and to control and mitigate any events that may arise” (International
Organization For Standardization, 2014).
The guidelines state that the Risk Management section therefore, “provides a step-by-step guide to
applying a risk management process based on ISO Standard 17776.” Additionally, while no specific
requirements are listed, the guidelines also state that the Risk Management Process “has been
developed to comply with requirements of International Maritime Organization (IMO) [and]
International Safety Management Code” (IADC, 2014, pp. Section 4, Page 3).
Appendix 4 of the Health, Safety, and Environment case guideline attempts to delineate a country-by-
country approach for the regulatory authorities in:
• Australia
• Netherlands
• Denmark
• Italy
• U.K.
• Norway
• Germany
• New Zealand
Copious amounts of legislation are cited and detailed in Appendix 4. For the purposes of relative brevity,
this report will discuss the regulatory authority legislation for Australia, Netherlands, Denmark, U.K.,
Norway, and New Zealand, as these agencies were of particular interest in Task 1.
Australia’s regulatory body is the National Offshore Safety Authority (NOPSA). NOPSA stipulates that “in
order for a safety case to be accepted by NOPSA, it must be submitted to NOPSA by the operator. The
safety case may relate to one or more of the ‘stages of life of the facility,’ which means one or more of
construction, installation, operation, modification, and decommissioning.” Additionally, NOPSA “must
accept the Safety Case if there are reasonable grounds for believing that it is appropriate to the facility,
it complies with requirements and that any validation meets the legislative requirements.” The relevant
Australian legislation for safety case requirements are Petroleum (Submerged Lands) Management of
The Netherlands’ regulatory body is the State Supervision of Mines. The health and safety cases
submitted to the State Supervision of Mines undergo a three-part review to assess adequacy. Upon
submission, “the first phase is an administrative overview to ensure the document is complete and
generally complies with legislation. The second phase is a detailed technical review to ensure the
demonstrated case for safety is robust. The third phase is the on-site/location verification that the
written word is put into practice.” The primary legislation that guides this process of health and safety
case adequacy is Working Conditions Act 1998. While environmental cases are not explicitly addressed,
the IADC asserts that “integrated Safety, Health, and Environment management system[s] … are also
commonplace” for the Netherlands (IADC, 2014).
Denmark’s regulatory body is the Ministry of Climate, Energy, and Building in the Danish Energy Agency
(DEA). Health and safety cases must be “submitted to the DEA as part of the documentation needed for
the application for an operation permit.” Additionally, all health and safety cases must have plans
“covering major hazards, occupational health and safety hazards, and other health conditions.” While
“an environmental case is not required … an environmental emergency response plan for oil spills is
required.” The main requirements for a health and safety case are detailed in the Offshore Safety Act,
Consolidated Act no. 520 on Safety (IADC, 2014).
The U.K.’s regulatory body is the Health and Safety Executive. While it does not require environmental
cases, nor does it seem to provide guidelines for such cases, the health and safety case must be
approved prior to obtaining a permit of operations. Following the Offshore Installation (Safety Case)
Regulations, 2005, the safety case must:
• Provide enough information to show the required demonstrations have been made. These
demonstrations are in addition to the descriptions and other details required by the relevant
schedules to the Regulations
• Show that the installation owner’s management system is adequate to ensure compliance with
the law in respect of matters within his control; and to ensure the satisfactory management of
arrangements with contractors and subcontractors
• Show that adequate arrangements for audit, and for making audit reports, have been
established
• Show that there is an effective safety management system which ensures the organizational
arrangements in place, if fully implemented, will enable the installation owner to comply with all
the relevant health and safety laws
• Show that hazards, with the potential to cause a major accident, have been identified and that
the risks arising from those hazards are, or will be, adequately controlled” (A4-58) (IADC, 2014).
As previously discussed in Section 4.2.2, Norway’s regulatory body is the PSA. Health and safety cases
submitted to the PSA must obtain an Acknowledgement of Compliance (AOC), which the contractor
As previously discussed in Section 4.2.1, New Zealand’s regulatory body is New Zealand Petroleum and
Minerals. Under the legislation titled Health and Safety in Employment Amendment Act, health and
safety requirements stipulate that the case must provide an overview of the arrangements in place for:
• Monitoring performance in relation to the management of major accident hazards and
other workplace hazards;
• Reporting, analyzing, and learning from incidents and work-related illness;
• Independent and competent persons to audit the management of major accident hazards
and other workplace hazards;
• Independent and competent persons to verify that safety-critical elements remain effective;
• The periodic assessment of the installation’s integrity; and
• Periodically reviewing the effectiveness and suitability of the major accident policy and
safety management system (New Zealand Legislation, 2013).
Additionally, operators are required to maintain an emergency response plan that, “must take into
account the operating and environmental conditions,” though no specific environmental case is required
(New Zealand Legislation, 2013).
4.3.3.5 Effectiveness
The IADC published Version 3.6 of the Health, Safety, and Environmental Case Guidelines for Mobile
Offshore Drilling Units (MODU) in January 2015 and version 1.0.1 of Health, Safety, and Environmental
Case Guidelines for Land Drilling Units in July 2009. As a measure of the guidelines’ effectiveness, the
IADC received the Carolita Kallaur Award for Outstanding International Safety Leadership in December
2007, presented by International Regulators Forum. “The award recognized IADC’s contribution to
improving safety in drilling operations, through the development of the Health, Safety, and Environment
Case Guidelines” (IADC, 2014).
The IADC’s guidelines have been adopted by the ten regulators (IADC, 2014). From our research
conducted on the regulatory bodies discussed above, in addition to the IADC guidelines, effectiveness is
gauged on a pass/fail or accept/reject system, namely that the Health, Safety, and Environment case is
adequate.
4.3.3.6 Outcomes
The IADC’s LCM system can be measured by the continual increase in members and decrease in the
frequency of both injuries and operational failures in the participating drilling industry. The decrease in
injuries can be seen via either the worldwide Lost Time Accident rate or IADC’s own Incidents Statistics
Program (ISP), which identifies causes and trends of drilling industry injuries. The previous section
4.3.3.7 Data
In regards to the program's effectiveness as it relates to the avoidance of safety-related consequences,
IADC manages an ISP that tracks the frequency and incidence rate for lost time on the job due to safety
related occurrences. According to IADC's Five Year Summary Report, the incidence and frequency rate
of reported lost time for the industry as a whole has decreased significantly from 2009 (FREQ = 1.88,
INCD = 0.37) to 2013 (FREQ = 1.29, INCD = 0.26) (IADC, 2014) (Refer to the Task 3 Report: Appendix E).
The use of IADC's Safety Alerts and other Health, Safety, and Environment case guidelines have aided in
the reduction of these rates and an overall increase in safety for the drilling industry.
4.3.3.8 Liabilities
The Statutory/Regulatory Elements section above details the Health, Safety, and Environment case
requirements for the regulatory bodies of Australia, Netherlands, Denmark, U.K., Norway, and New
Zealand. All six adhere to IADC guidelines as mandatory practice, so the Health, Safety, and
Environment case guidelines are, effectively, the generalized legislation for drilling contractors in these
respective areas. While the IADC states that the case guidelines, “represent a voluntary, core set of
principles which can be applied to any drilling unit regardless of geographic location” (IADC, 2014), the
association may risk being liable should a domestic or international regulator find its guidelines
inaccurate or incomplete. However, our research did not find any instance of the IADC being liable for
any drilling incident. Rather, the IADC is often portrayed as actively defending its members in the
drilling industry against private and public critics and lobbying in the interest of the drilling industry.
4.3.4.1 History
The ISO is an industry standard setting organization. 6 Under the current regulatory environment many
of their standards are adopted into regulatory law by BSEE. In general, the ISO updates their standards
every five years (International Organization For Standardization, 2014).
ISO 20815 – Petroleum, Petrochemical and Natural Gas Industries – Production Assurance and
Reliability Management
ISO 20815 introduces the concept of production assurance within the systems and operations associated
with exploration drilling, exploitation, processing and transport of petroleum, petrochemical and natural
gas resources. It focuses on production assurance of O&G production, processing and associated
activities and provides guidelines for the analysis of reliability and maintenance of the components.
ISO 20815 also provides processes and activities, requirements and guidelines for systematic
management, effective planning, execution and use of production assurance and reliability technology.
This is to achieve cost-effective solutions over the life cycle of an asset-development project structured
around production-assurance, management for optimum facility economy through all of its life cycle
phases, while also considering health, safety, planning, execution and implementation of reliability
technology and operation improvement (International Organization For Standardization, 2014).
6
The API also has industry advocacy goals and statistical reporting functions in addition to standard setting roles.
ISO/TS 29001 also calls for a “Plan-Do-Check-Act” (PDCA) to be applied to all processes. PDCA can be
briefly described as follows:
• Plan: Establish the objectives and processes necessary to deliver results in accordance with
customer requirements and the organization's policies.
• Do: Implement the processes.
• Check: Monitor and measure processes and product against policies, objectives and
requirements for the product and report the results.
• Act: Take actions to continually improve process performance (International Organization For
Standardization, 2014).
ISO 15926 – Industrial Automation Systems and Integration—Integration of Life Cycle Data for Process
Plants Including O&G production
Unlike ISO 20185 and ISO/TS 29001, ISO 15926 is a series of documents containing both published
standards and technical specifications. It contains a number of substantive standards as well as a
number of ancillary and supporting documents. The overall objective of ISO 15926 is to provide a
common lingua franca so large petrochemical organizations have a uniform basis for data management
to support the life cycle activities and processes of production facilities. Briefly summarized, the key
components of this series are:
• Part 1: Overview and Fundamental Principles
• Part 2: Data Model (International Organization For Standardization, 2014)
• Part 3: Reference data for geometry and topology
• Parts 4, 5 and 6: Use and definition of reference data for process plants
• Part 7: Implementation methods for the integration of distributed systems: Template
methodology (International Organization For Standardization, 2014)
• Part 8: Implementation methods for the integration of distributed systems: Web Ontology
Language (OWL) implementation (International , 2014)
• Part 9: Implantation standards for web servers, facades and security
• Part 10: Test Methods
• Part 11: Industrial Usage Guidelines (International Organization For Standardization, 2014).
Because petrochemical processing plants can contain a large number of parts and systems, ISO 15926
focuses on a highly generic, conceptual data model designed to be used in conjunction with reference
ISO 15663 Petroleum and Natural Gas Industries – Life Cycle Costing
ISO 15663 outlines an important element of LCM, cost estimation. Similar to other ISO published
documentation ISO 15663 comes in three parts. Part 1 (ISO 15663-1) contains information on
methodology, Part 2 provides guidance on application of methodology and calculation methods, and
Part 3 provides implementation guidelines.
ISO 15663 pertains to LCM as cost is a key aspect of LCM in the private sector. In general, ISO 15663 has
broad application to management decisions including: defining process concepts, equipment siting
locations, project execution strategies, weighing health, safety and environmental factors, system
concept and sizing, selecting equipment types, implementing equipment configurations, maintenance
and operational strategies, determining staffing levels, facility modification decisions and asset
reuse/disposal decisions (International Organization for Standardization, 2014) (International
Organization For Standardization, 2014) (International Organization for Standardization, 2014).
7
See http://15926.org/index.php for a user based discussion of ISO 20185 implementation.
4.3.4.5 Effectiveness
ABS Consulting’s review of ISO life cycle standards suggests at least one possible concern with ISO
standards, which is the definition of “quality” is not definitive. Some LCM systems in compliance with
ISO standards could simply gauge whether processes are being followed, instead of whether processes
are the correct process or in need of improvement. Furthermore, when unique technical solutions are
involved in the creation of a new part, ISO does not validate the robustness of the technical solution,
which is a key part of advanced quality planning. ISO accreditation is an important indicator of quality,
but does not necessarily guarantee high quality parts.
4.3.4.6 Liability
ISO standards face the same liability issues as API standards, as discussed in Section 4.2.3.6 Liabilities. As
a voluntary standard, industry members would bear the liability of a failure or the capture of data
according to their implementation of the ISO standard.
Industry is in need of clear and specific definitions and levels for critical systems, critical components,
and critical equipment. There are multiple variations and interpretations of similar definitions developed
and used by other industry entities. These variations in definitions cause confusion, making it difficult for
industry to have a clear understanding of the terms, how they are applied, and to what the definitions
apply to. Specific, clear definitions developed by BSEE and vetted by industry will give a clear lexicon
from which regulators and industry can follow. These definitions, once developed, should be included in
any new or updated regulatory frame work. This will provide a clear understanding of terminology; a
foundation from which industry can develop LCM and Failure Reporting System programs; a baseline for
BSEE to develop and update new and current regulations, policies and programs; and a baseline for
industry and BSEE to conduct a risk assessment to identify high risk critical systems, critical components
and critical equipment.
There are no regulations requiring LCM systems in the O&G industry. Because these programs are not
required, many of the smaller industry organizations do not have programs, nor do they desire to start
them. It is believed that only the larger O&G companies are using integrated LCM and Failure Reporting
System programs to enhance their business case, but the smaller organizations have a “run things until
There is a strong sense of wariness in the O&G industry, both within the industry itself and towards
regulators. Industry competitors fear sharing LCM information can lead to loss of competitive
advantage. Fear of retribution by regulators for reporting failures or accidents is prevalent throughout
the industry, though some reports are made for minor issues. This is a significant issue for
subcontractors as well. Their concerns are if they report issues, they could lose their contract and be
replaced by another organization. Because of this, most subcontractors may not make reports of any
kind. Because of this mistrust, using a third party unbiased independent organization to gather
information as required by regulatory requirements could serve several purposes:
1. It could serve as a clearing house of information, which would relieve BSEE of the resource
constraints of managing, organizing, and responding to potentially massive amounts of data,
and eliminating the perception of a lobbying group pressuring regulators.
2. It could alleviate any actual or perceived biases industry currently holds.
3. The third party organization would track and ensure industry organizations meet and follow all
regulatory requirements. The independent third party would be under contract and make
reports to BSEE and industry as required, and would provide transparency and develop trust
between industry and regulators.
Industry does not want to report information if there will be no timely feedback on the information
provided. Industry does not have the time or resources to spend on collecting information, sending it to
BSEE, and then not receiving feedback in a useful time frame. Receiving feedback from data collected six
months, one year, or two years later provides industry with limited useable or valuable feedback. A third
party organization would provide BSEE with the resources to quickly vet actionable issues and provide
industry with feedback in a reasonable and acceptable time frame. One potential obstacle could be
receiving authorization from the Office of Management and Budget to use a third party organization to
manage a regulated data collection and dissemination program. It is believed, however, that industry
would be receptive of BSEE using a third party organization for this purpose.
Industry would want to know specifically what new regulatory requirements would be considered, and
specifically how these requirements would be enforced. For example, new regulations would be
required that identify specific data reporting requirements and what specific data would be required to
be submitted. Reporting information that is considered high risk is extremely important and should be
collected as long as the information is handled according to Confidential Business Information (CBI),
Sensitive Security Information (SSI), and any other regulated protocols. Establishing high risk reporting
criteria would require a risk assessment to identify specific critical components and processes that both
BSEE and industry agree should be considered high risk and reportable.
In order for industry to provide any form of accurate or useable data, BSEE will have to develop specific
regulations with specific reporting requirements. These reporting requirements will need to be
prescriptive enough to gather specific information and focused on high risk issues. They should not
require reporting on issues of lessor risk or importance. Working with industry to identify those areas
that could be considered high risk and reportable would be very valuable and provide significant
industry input into the requirements. In order for industry to fully comply with these requirements, BSEE
will have to mandate these requirements in regulations.
4.3.5.1 Liabilities
Government regulators will always have liability and responsibility of enforcing laws and regulations.
Ensuring industry adheres to regulatory requirements where health, safety and environmental risk are
factors is the biggest challenge. Resource constraints where regulators may not be capable of meeting
the enforcement requirements could have a significant impact on government liability in the event of a
significant incident.
Industry shares in liability as well. Industry has the responsibility to manage health, safety and
environmental risk by adhering to regulatory requirements. In the event of a catastrophic event where
human life is lost, significant injuries occur and/or a major environmental incident occurs, industry will
share, if not be totally liable for the incident.
5. Findings
LCM has been in use in the O&G industry since the 1960s. However, there appears to be little
consistency in the application of LCM principles.
Agencies like the Nuclear Regulatory Commission (NRC) and the Pipeline and Hazardous Materials Safety
Administration (PHMSA) have taken an approach that lends toward detailed regulatory criteria for the
development of LCM systems, but nevertheless with some elements of risk-based criteria. Towards the
middle of the spectrum is the USCG, which has regulations that are in equal parts prescriptive and risk-
based, in an approach that strongly resembles an LCM. However, the USCG’s approach is less
comprehensive and has a less coherent application when compared to the NRC’s and PHMSA’s LCM
systems.
Alternatively, at the other end of the spectrum is Norway’s PSA, the New Zealand’s Petroleum and
Minerals agency, and the U.K.’s HSE “Safety Case” approach. This approach constructs an LCM
framework through the perspective of Health, Safety, and/or Environmental goals. These agencies also
utilize approaches that are more dependent on risk-based guidance than on specific regulations. For
example, the “Safety Case” approach requires the operator of an offshore facility to identify the hazards
and risks and then leaves it to the operator to describe how they control risks.
These findings make sense when viewed in the context of a holistic risk spectrum. The NCR and PHMSA
regulate industries that deal with exceptionally hazardous materials and processes that have the
potential for serious consequences to large populations. As a result of the associated dangers, these
activities are highly scrutinized. Consequently, industry’s willingness to strictly adhere to regulation and
guidance may appear diminished when compared to the nuclear and hazardous materials industries.
The variation noted in the prescriptiveness or flexibility in LCM systems reflects the regulatory bodies’
attempts to maximize compliance from industry.
The following are some of the best practices that are common to many of the LCM systems reviewed.
These best practices are not specific to any one element (phase) of an LCM. Any of these best practices
could support any one of the LCM elements (phases) described above. LCM systems that approach
“management” beyond just maintenance or safety are better suited to BSEE’s goals. The more
comprehensive LCM systems include the following elements:
Asset integrity: The systematic implementation of activities, such as inspections and tests necessary
to ensure that important equipment will be suitable for its intended application throughout its life.
Specifically, work activities related to this element focus on (1) preventing a catastrophic release of a
hazardous material or a sudden release of energy and (2) ensuring high availability (or
dependability) of critical safety systems that prevent or mitigate the effects of these types of events.
This element primarily involves (1) inspections, tests, preventive maintenance, predictive
The primary objective of the asset integrity is to help ensure reliable performance of the equipment
designed to contain, prevent, or mitigate the consequences of a hazardous incident. Although
proper execution of work activities associated with this element requires a high level of human
performance, the ultimate goal of asset integrity is reliable and predictable equipment operation.
An effective asset integrity program depends on management ensuring:
• The equipment and systems are properly designed, fabricated, and installed
• The unit is operated within the design limits of the equipment
• Inspections are conducted by trained and qualified individuals using approved procedures
and completed as scheduled
• Repair work conforms to design codes, engineering standards, and manufacturer’s
recommendations
• Appropriate actions are taken to address deficiencies, regardless of how they are discovered
(Center for Chemical Process Safety, n.d.).
Audit Regimes: Audits are intended to evaluate whether or not an LCM system is performing as
intended. An audit is a systematic, independent review to verify conformance with prescribed
standards of care. A LCM system audit is the systematic review used to verify the suitability of the
system and its effective, consistent implementation. Audits are important control mechanisms
within the overall management of a LCM system. Additionally, audits can provide other benefits
such as the identification of opportunities for improved operability, increased safety awareness, and
greater confidence regarding compliance with regulatory requirements. Audits are conducted
throughout the development and implementation of the LCM system. The nature and frequency of
the audits are governed by factors such as the current life cycle stage of an offshore facility and the
maturity or degree of implementation of the LCM system. Audits should occur during all life cycle
stages, but primarily focus on the operational phase. While they can be scheduled on an as-needed
Corrective and Preventive Action (CAPA) systems: The purpose of a CAPA system is to collect and
analyze information, identify and investigate problems and take appropriate and effective corrective
and preventive action to prevent their recurrence. CAPA should be viewed as an umbrella system
that allows a company to assess its entire program. The scope of any corrective and preventive
action system must include the verification or validation of corrective and preventive actions.
Additional elements include communicating corrective and preventive action activities to those
responsible, providing relevant information for management review and documenting those
activities. These activities are essential in dealing effectively with problems, preventing their
recurrence and preventing system or equipment failures. A CAPA system generally follows these
steps:
• Documentation of the identified problem
• Assign appropriate personnel to investigate the problem and identify root causes
• Share finding of investigation with departments whose activities may be impacted by the
investigation and corrective action implementation
• Identify root causes and corrective action
• Verify corrective action is implemented
• Document corrective action information in a database for future analysis
• Apply lessons learned from investigation and corrective actions to other similar activities
• Implement similar corrective actions to prevent the occurrence of similar conditions
• Verify implementation and effectiveness
• Document preventive action for entry into the database for analysis
Hazard Identification and Risk Analysis (HIRA): HIRA is a collective term that encompasses all
activities involved in identifying hazards and evaluating risk at facilities, throughout their life cycle,
to make certain that risks to employees, the public, or the environment are consistently controlled
within the organization’s risk tolerance. These HIRA typically address three main risk questions to a
level of detail commensurate with analysis objectives, life cycle stage, available information, and
resources. The three main risk questions are:
• Hazard – What can go wrong?
• Consequences – How bad could it be?
• Likelihood – How often might it happen?
HIRA encompasses the entire spectrum of risk analysis, from qualitative to quantitative. HIRA
reviews may be performed at any stage in the life cycle, to include: conceptual design, preliminary
design, detailed design, construction, ongoing operation, decommissioning, or demolition. In
general, the earlier a hazard is identified (e.g., during conceptual design), the more cost-effectively it
can be eliminated or managed. HIRA is typically performed by a team of qualified experts in the
processes, the materials, and the work activities. Personnel who have formal training on risk analysis
methods usually lead these teams, applying the selected analysis technique(s) with SMEs from
engineering, operations, maintenance, and other disciplines as needed. The results of risk studies
are normally kept for the life of the process and are communicated to those who may be affected
(Center for Chemical Process Safety, 2015).
MOC procedures: MOC procedures help ensure changes to a process do not inadvertently introduce
new hazards or unknowingly increase the risk of existing hazards. MOC procedures include a review
and authorization process for evaluating proposed adjustments to facility design, operations,
organization, or activities prior to implementation to make certain that no unforeseen new hazards
are introduced and that the risk of existing hazards to employees, the public, or the environment is
not unknowingly increased. MOC procedures also includes steps to help ensure that potentially
affected personnel are notified of the change and that pertinent documents, such as procedures,
process safety knowledge, and so forth, are kept up–to-date. MOC reviews are conventionally done
for operating facilities, but are increasingly done throughout the process life cycle. MOC reviews
start when qualified personnel determine that potentially adverse risk impacts could result from a
change and suggest additional measures to manage risk. Based on the review, the change is either
Contractor Management: Industry often relies upon contractors for very specialized skills and
sometimes to accomplish particularly hazardous tasks, often during periods of intense activity, such
as maintenance turnarounds. Such considerations, coupled with the potential lack of familiarity that
contractor personnel may have with facility hazards and operations, pose unique challenges for the
safe utilization of contract services. Contractor management is a system of controls to ensure that
contracted services support both safe facility operations and the company’s process safety and
personal safety performance goals. The use of contractors can place personnel who are unfamiliar
with the facility’s hazards and protective systems into locations where they could be affected by
process hazards. Conversely, as a result of their work activities, the contractors may expose facility
personnel to new hazards. Also, their activities on the site may unintentionally defeat or bypass
facility safety controls. Thus, companies must recognize and address new challenges associated with
using contractors. For example, training and oversight requirements will be different from those for
direct-hire employees. Thus, companies need to carefully select contractors and apply prudent
controls to manage their services. Contractor management begins well before the issuance of any
service contract. Systems should be established for qualifying candidate firms based upon not only
their technical capabilities, but also their safety programs and safety records. Orientation and
training of contractor personnel should be accomplished before they begin work. Responsibilities
for this training should be defined, with some training provided by the contract employer and some
by the contracting company. The boundaries of authority and responsibilities should be clearly set
for any contractor that works at the facility. Periodic monitoring of contractor safety performance
and auditing of contractor management systems is required. At the end of each contract period,
evaluation of a contractor’s safety performance should help determine whether the particular
contractor is retained or considered for future work. While some responsibilities for implementing
the contractor management element are assigned to contractor personnel, many tasks are assigned
to company staff at either the offshore facility or corporate level. Specific delegation of
responsibilities between a contractor, corporate, and offshore facility personnel needs to be
The scope of contracted services can encompass a broad spectrum, ranging from contracting with
an individual to provide a very specialized service to contracting with a large firm (perhaps with
many subcontractors) who will provide hundreds of workers with diverse skills for a major
construction project or maintenance turnaround. A contracting firm could be on site for only a few
hours and never to return, or could have a continuing presence at an offshore facility for decades.
Some contractors will be directly exposed to the process and its hazards, while in other situations,
such as new project construction adjacent to an operating unit, effective controls will be required to
isolate the contractors from hazards. Finally, some contract service companies have a very stable
workforce while others have a high rate of turnover. The contractor management program should
be well-defined and flexible enough to handle this gamut of potential circumstances. The
responsibilities and procedures for implementing these activities should be documented in a written
program description with specific criteria for screening and selecting contract service providers
(Center for Chemical Process Safety, 2015).
Management Review and Continuous Improvement: Management review is the routine evaluation
of whether management systems are performing as intended and producing the desired results as
efficiently as possible. It is the ongoing “due diligence” review by management that fills the gap
between day-to-day work activities and periodic formal audits. The management review process
provides regular checkups on the health of safety management systems in order to identify and
correct any current or emerging deficiencies before they might be revealed by an audit or incident.
The depth and frequency of each management review should be governed by factors such as the
current life cycle stage of the offshore facility, the maturity or degree of implementation LCM
system, and the level of management performing the review. Most of the management review
effort will be focused on operating offshore facilities. While they can be scheduled on an as-needed
Training and Performance Assurance: A consistently high level of human performance is a critical
aspect of any LCM system. Without an adequate training and performance assurance program, an
offshore facility can have no confidence that LCM tasks will be consistently completed to minimum
acceptable standards in accordance with accepted procedures. Training is defined as practical
instruction in job and task requirements and methods. It may be provided in a classroom or
workplace, and its objective is to enable workers to meet some minimum initial performance
standards, to maintain their proficiency, or to qualify them for promotion to a more demanding
position. Performance assurance is the means by which workers demonstrate that they have
understood the training and can apply it in practical situations. Performance assurance is an ongoing
process to ensure workers meet performance standards and to identify where additional training is
required. Training takes place both in the workplace and the classroom, and it should be completed
before a worker is allowed to work independently in a specific job position. Refresher training is
provided on an ongoing basis thereafter as needed. Ideally, training is based on a needs analysis that
defines the minimum acceptable KSAs required for a worker in a specific position. The analysis also
includes any requirements imposed by regulations, codes, industry standards, or company policies.
The training program should then be developed to bridge the gap between what is demanded of a
qualified job applicant (e.g., basic reading and writing skills) and what is required to succeed in a
specific job. The performance assurance system then tests the trained workers initially, and
periodically thereafter, to demonstrate that they possess the required KSAs and are qualified to
work independently. A training record should be provided for each worker showing that person’s
training needs, the dates on which initial training and any refresher training was satisfactorily
completed, and a schedule of future training classes (Center for Chemical Process Safety, 2015).
The following are lessons learned and observations about the implementation of LCM Systems:
For example, in New Zealand, regulations are in place that prescribe the development of a SMS under
the Health, Safety and Environmental laws. Organizations seeking permission to conduct business must
develop an SMS and most organizations will be required by the regulations to develop a Safety Case to
specifically describe how the organization will conduct business, describe safety measures to protect
employees and the environment, and describe how the operation will be maintained from start-up to
decommissioning or closure. Each of these specific requirements must be clearly described in the Safety
Case, which must be approved by the government regulatory authority prior to beginning operations,
and made available for audit and inspection as defined in the regulations.
This same basic process and concept is applicable to the LCM system and requirements in the U.K. and
Norway where Safety Cases are required. There may be subtle differences in the actual regulatory
language, but conceptually the programs are similar. The U.K. HSE and Norway’s PSA rely heavily on
industry input when developing specific regulations and guidelines for their Safety Case approaches. For
example, the U.K. HSE sought to address issues particular to O&G operations on mature fields, as several
industry members operated on the U.K. Continental Shelf (UKCS) with equipment that approached or
exceeded life cycle expectancy under their initial LCM-based programs. The U.K. HSE, in response, then
developed the KP3 and KP4 programs to adapt to the unique concerns of operators under its regulatory
jurisdiction, while still upholding the goals of its Safety Case approach.
In most cases, industry organizations rely heavily on ISO and API standards, recommendations, and best
practices, in addition to IADC guidelines, when developing LCM systems. In some cases, industry
standards are incorporated by reference in regulatory frame work, and industry must then apply those
standards when developing an LCM system if required. At a minimum, in the case of the U.K., Norway
and New Zealand, if these standards are incorporated by reference in the regulatory framework, then
the specific standards must be addressed when developing their Safety Case. In the U.S., where LCM
systems are not required, industry relies heavily on the ISO and API standards and best practices and
IADC guidelines to develop programs that address safe working environments for employees and
attempt to meet or exceed environmental safety practices.
Another important role industry plays is providing feedback and recommendations to regulators.
Feedback is particularly important as regulatory changes are proposed, training requirements change,
For example, Oil and Gas UK is a not-for-profit organization where organizations working within the
O&G industry can become members and work together with regulators to address issues that are
relevant to the UKCS and the offshore O&G industry. This consortium provides a direct link to regulatory
organizations and as a 500 plus member group, a powerful voice.
As mentioned earlier, the PSA in Norway also engages with industry extensively through a similar
process in its Regulatory Forum. This Forum provides a space for representatives of the industry to
address current issues with PSA representatives, discuss goals, and ultimately establish an agreement on
the direction of new regulations and guidelines through mutual cooperation.
Another important role of industry is to provide data to regulators. In order for the data to be useful
however, it must be accurate. The importance of factual data is critical and very valuable to regulators
for identifying trends. These trends can lead to necessary regulatory updates; the identification of gaps
in training; the identification of safety, security and risk issues; and potentially provide an overall
economic state of the industry. However, industry has been resistant to supplying some data,
particularly data that is not required by regulations, data that may be used for enforcement purposes or
data that identifies possible safety issues or violations.
Accurate incident reporting is an important part of the data collection process as well. In all cases, each
regulatory agency researched for this project has incident reporting requirements included in their
regulations. Industry is required to submit incident reports if they involve serious injury or loss of life,
incidents involving major structural damage, and incidents involving damage to the environment.
Reporting requirements vary depending on the nature of the incident and its severity. The following are
examples of required reports from the PHMSA. PHMSA regulations require industry organizations to
make reports on any leak where conditions exist that present a danger to life or property. There are
three required reports: 1) within the first three hours of an incident, operators must report the incident
to the National Response Center (NRC); 2) an incident report must be submitted to PHMSA within 30
days; and 3) operators are required to submit an annual report by mid-March each year.
The NRC employs a somewhat different approach with its Licensee Event Report (LER) program (see
Task 3 Report). While it has separate incident and emergency reporting programs, LERs specifically
correspond to non-emergency incidents where threats to human safety could have been realized. LER
The primary role of industry is to develop programs, processes and systems as prescribed in applicable
regulatory requirements. These programs, processes and systems must provide a framework for a safe
working environment for employees and ensure operations are conducted to prevent adverse
environmental impact. Significant deviation from regulatory requirements in the form of accidents or
incidents must be reported and it is industry’s responsibility to ensure required reports are accurate and
delivered within the prescribed regulatory timelines.
Another area of future concern is how to address critical equipment when the equipment lasts longer
than expected. An LCM system should be flexible and adaptable enough to capture additional
information that might be of use later.
A key component is responsiveness of data. Industry is concerned about the benefit to and outcome of
providing information to regulators and more specifically, the time it takes to receive feedback on the
information provided. Responsive analysis of the data provides the industry the reason and rationale for
the continued provision of data to BSEE. If there is a long temporal gap between data collection and
data utilization, then the value to the industry is diminished. If there are no actionable increases in
safety, then there may be little value provided to the industry from the data provided.
In addition to the definitions, clear and understood penalties will aid in the understanding of the
requirements as well as improve compliance with a regulated system.
Some of the LCM systems examined encourage the users to measure effectiveness in terms of improved
process performance, increasing operational efficiency and effectiveness, minimizing risk, improving
safety, improving compliance, or reducing costs. But these systems do not define standards by which to
benchmark measurements of effectiveness. Standards or guidelines developed by the ISO, API and the
IADC fall into this category.
In the international arena, determining effectiveness of specific LCM systems was very difficult. There
are several reasons for this difficulty. For example, in the U.K. and New Zealand regulatory requirements
for organizations wishing to conduct business in the O&G industry require the company to develop and
seek government approval of a Safety Case. The Safety Case regulations do not stipulate requirements
to track the effectiveness of individual organizations’ LCM systems. Since there are no stipulations to
track LCM systems, there is no data available to determine agency or company LCM effectiveness
directly. Anecdotally, it can be assumed that larger organizations have used LCM systems effectively as
they typically have the personnel and resources to effectively manage these programs, whereas smaller
companies may or may not employ LCM systems due to resource constraints, financial reasons, or a
business philosophy of “run it until it fails and replace it.”
The one overarching theme of all the models is the goal of reducing the loss of human life, injuries, and
incidents of hazardous materials spills that result in environmental damage. As such, the clear linkage
between LCM systems and failure reporting is essential. Failure reporting information is used to feed the
LCM process so organizations can track trends and identify potential areas for improvement.
One observation regarding effectiveness is that clear and open communications between regulators and
industry is critical for program effectiveness. When regulatory entities provide industry with the
opportunity to provide feedback about regulations, policy decisions and process, industry is more willing
to trust and work with regulators to establish effective and functional regulations. For example, in the
U.K., Oil and Gas UK serves as an effective consortium of more than 500 industry and government
representatives that work together to identify potential regulatory updates or changes and collaborate
on lessons learned on issues including safety, security, supply chain, training, and contractor and
subcontractor relations issues. Similarly, the PSA in Norway chairs a Regulatory Forum to meet and
discuss current issues and regulatory development with industry representatives.
The one definitive statement that can be made is that the more comprehensive an LCM system, the
greater the potential for its effectiveness. LCM systems that include asset integrity, audit regimes,
corrective and preventive action, hazard identification and risk analysis, contractor management,
management review and continuous improvement, and training and performance assurance elements
are the most effective.
5.6 Liability
All the organizations evaluated for this study may bear the potential effects of legal liabilities associated
with the implementation of a LCM system. What distinguishes them is the degree to which they may be
subject to those legal burdens. Operators of offshore facilities may be exposed to adverse legal action
from a countless number of organizations or individuals following a significant incident. Any LCM system
in use will be the subject of a high degree of scrutiny from a host of potential actors. Implementing an
industry organization standard from ISO, API, IADC, or others that provide LCM models would show a
good faith effort in achieving a higher standard of safety. Standards Organizations may also find
themselves the target of unwelcomed litigation, but the likelihood is significantly less. The good news
for any of these organizations is that a properly implemented, or designed, LCM system could be an
important asset rather than a liability.
For example, offshore operators that implement an LCM system may realize substantial mitigation of
potential liabilities because LCM systems provide offshore operators with the ability to make proactive
and methodical management decisions about critical and potentially hazardous operations. Therefore,
LCM systems may have the effect of limiting organizational liability and increasing compliance with legal
requirements. LCM systems provide operators with a degree of defense because having a system in
place demonstrates due diligence. It may be easier for operators to diminish their culpability because
they can prove that they use the systematic decision methodologies and documentation procedures
provided by an LCM system. LCM systems are by no means a panacea for all the potential liabilities an
offshore operator will face. However, the ability to prove that important decisions are comprehensively
evaluated before they are made could be invaluable if there is a substantial incident.
Still, there is a glaring potential gap that could render useless the potential liability limiting effects of an
LCM system. This potential gap lies in the relationship between operators and subcontractors in deep
In addition to legal liabilities, offshore operators are subject to substantial financial liability. Because
there are no insurance requirements under Oil Pollution Action 90, many large drilling firms are self-
insured. This practice has come under heavy criticism, and has sparked much debate about establishing
a mandatory system of insurance for offshore drilling operations. However, mandating insurance may
have unintended consequences. For example, it is possible that a company that has purchased insurance
may to some degree be de-incentivized to maintain the highest standards of safety because it is now
financially covered in the case of an oil spill. To overcome this situation, an insurer might institute a
system of risk-based pricing so that firms with higher risk exposures pay higher rates, thereby creating
an incentive to reduce risk. Additionally, insurers may increase the level of their oversight. Insurers will
very likely focus on assessing the safety cultures of operators. The adoption of a strong safety culture
could become one of the key benchmarks by which liability caps are set. In such a case, offshore
operators who have implemented effective LCM systems will most likely realize substantial financial
benefits from reduced insurance rates. On the other hand, if market forces keep the liability caps low,
insurer’s monitoring incentive may not be very strong. In this case, there would fewer incentives for
offshore operators to voluntarily adopt LCM systems. Without the pressure of keeping insurance rates
low, there will be operators who will not perceive the benefits of LCM systems and choose not to
implement such systems in an effort to keep down cost. In this scenario, the government is best suited
to encourage, or if need be mandate, the implementation of LCM systems (Cohen, Gottlieb, Linn, &
Richardson, 2011).
Other countries have implemented the IADC’s guidelines for LCM as part of their Safety Case approach
to regulation. Given the legal structure of the U.S., BSEE would be held as potentially negligent if this
approach were selected. The liability issues that confront BSEE are different than those posed to the
regulated industry. If BSEE mandates an LCM system, liability would shift from the industry to BSEE for
the effectiveness and compliance with the regulations. If a company is in compliance with the
regulations, but an event still occurs, then BSEE’s regulations could be viewed as an issue.
BSEE would also face a liability issue if data from LCM systems are collected. If the data is too
transparent, then industry organizations might file suit, particularly if a Freedom of Information Act is
requested and company proprietary data are released. Additionally, an excessive data request could
result in an undue burden to the company and to the industry, particularly if the industry does not
perceive the benefit of compliance with data requests.
For an LCM system, liability issues should not be a main issue for the industry. An LCM system should be
implemented to take advantage of Best Practices, many of which are already adopted within the
5.7 Data
Effective data management plays an important role in improving the performance of any LCM system.
Collecting, analyzing, interpreting, and acting on data for specific performance measures allows LCM
managers to identify where systems are falling short, to make corrective adjustments, and to track
outcomes. The best decisions are evidence-based and data-driven. LCM systems that control hazardous
processes or critical equipment must have access to accurate data to improve the organization's
performance. As a result, data quality is an essential requirement for any performance improvement
initiative. The following are some key points about effective data management for LCM systems:
• The data collection process should ensure data being collected are useful, reliable, and
resource-efficient
• The data collection will be influenced by the areas needing improvement
• The data being collected should have quality measurements
• A standardized data collection procedure is critical for consistency and data quality
• Data collection systems that inform Original Equipment Manufacturer (OEM) providers are
desirable
The collection of relevant and accurate data is one of the most important aspects in an effective LCM
system. Most of the regulatory agencies surveyed dictate a format for reporting to ensure some level of
consistency. However, the level of detail collected and scope of definitions for the reporting
requirements vary widely between agencies. Many of the agencies and organizations studied placed the
burden of collecting data on the offshore owner/operator. This more decentralized model of data
collection increases the amount of data that can be gathered, while reducing the cost to regulatory
agencies like BSEE. For example, FHWA relies on individual state’s DOT to gather necessary data for its
PMS, BMS, and SMS. This is the model that most of the European regulatory agencies follow. One
significant exception is the USCG, which places the burden of data collection and analysis entirely on
USCG employees.
One issue BSEE will have to meet head-on in advance of imposing any LCM system model on the
offshore industry is the potential availability of data collected by LCM systems. BSEE will have to artfully
balance the need to collect and preserve the data without unintentionally disclosing data that could be
harmful to those who are providing the data, with BSEE’s desire to use the data to communicate risk and
educate the industry and the public. Very early on, BSEE will need to develop clear processes and rules
for handling such data to strike that balance. Another issue that must be addressed before
implementation is determining what data from an LCM system need to be collected. Indiscriminate
collection of data could have potential adverse effects. If too much data is required, it will impose a
significant resource burden on those who have to provide the data and also on BSEE, who will have to
analyze the data. Additionally, the collection of superfluous data may create a liability for both the
Even the standards best aligned with the offshore industry (i.e., ISO, API, and IADC), will require some
augmentation to meet the goals of an inclusive regulatory regime. For example, the API and ISO lack an
industry-wide failure reporting data repository, and there are no mechanisms for user/operators,
manufacturers or associated subcontractors to garner lessons learned. API standards for LCM lack any
control mechanism, so BSEE would have to supplement these standards with additional metrics and
reporting requirements. Additionally, ISO life cycle standard’s definition of “quality” is somewhat
elusive. Subsequently, the LCM systems may merely measure whether processes are being followed,
not whether processes are achieving acceptable results. ISO accreditation may be an indicator of
quality, but it is not a guarantee. Heavy oversight will be required because there can be no assumption
that ISO LCM certification significantly lowers risk. The IADC standards are very comprehensive in
dealing with Health, Safety, and Environment cases for drilling contractors. The IADC standards allow
flexibility in tailoring the Health, Safety, and Environment cases for specific operations of varying scales,
and in doing so, promote efficiency and avoid redundancy and unnecessary paperwork. However, the
IADC standards lack satisfactory measurements of safety or reliability.
Additionally, the extensive adoption of ISO, API, and IADC standards presents political realities that
could be a potential minefield for BSEE. Specifically, it could be argued that the ISO, API and IADC
standards have already been proven inadequate to regulate offshore drilling. The basis of this argument
is rooted in the fact that: (1) prior to the Deepwater Horizon oil spill, BP met, or in many cases may have
exceeded, all the applicable API and IADC standards in place at the time of the oil spill, and (2) at the
time of the Deepwater Horizon oil spill BP was ISO 9001:2008 and ISO 14001:2004 certified and had
been so since the year 2000. Many investigations in the wake of the Deepwater Horizon oil spill
criticized the Outer Continental Shelf Lands Act for having too few standards to assure protection of
Looking to other domestic regulatory agencies for LCM models to emulate may offer some best
practices, but nothing resembling a full-blown regulatory model for LCM systems. Culturally and
jurisdictionally, BSEE and the USCG have the most in common. There is much that BSEE could learn from
the USCG; unfortunately, the USCG does not have a regulatory model that can be readily adopted as a
LCM system model. As noted, the USCG’s enforcement of Title 46 is in fact a LCM system that is already
applicable to the OCS. More specifically, the model provided by 46 CFR Subchapter Q could serve as a
framework for a regulatory system that gives BSEE greater control over critical systems being installed
on offshore installations. This framework could allow BSEE to establish their own standards or
incorporate by reference widely accepted industry standards and best practices. Likewise, BSEE could
consider using their existing regulations to develop “USCG-like” maintenance requirements. In 30 CFR
250.10(a)(2), 30 CFR 250.130(b), and 30 CFR 250.401(e), BSEE could develop regulations that are
modeled after USCG regulations for lifesaving, firefighting, pollution prevention, engineering, electrical
and structural systems. The USCG does have some internal LCM policies that may be instructive; chief
among them is Commandant Instruction M9000.6, Naval Engineering Manual. In this policy, the USCG
outlines its application of RCM methodology for the vessels it operates. However, the USCG has no
single methodology or policy that speaks to the agency-wide application of LCM. Instead, the USCG uses
multiple policies that address the various aspects of LCM. In truth BSEE would have to build a model
from the pieces of authorities, processes, and reporting systems that the USCG has somewhat
haphazardly developed over the last 80 years.
The other Federal regulatory agencies examined for this report have some useful structures, but these
structures do not form a coherent LCM model that BSEE could easily modify for their use. For example,
PHMSA, NRC, FHWA and the Department of Defense all address LCM systems but describe the elements
and phases of the LMC system to focus narrowly on their regulatory responsibilities. For example, some
of the LCM systems begin with conception and design, while other LCM system models do not start until
procurement or construction. Also, there is an inconsistency in the language to describe the elements
or phases of the LCM systems. Therefore, there is no single Federal model that would constitute a
workable LCM system model that would fit BSEE’s needs, leaving BSEE to single out the useful elements
to create a new conceptual model that ties these different elements into a holistic and workable model.
There are some European regulatory agencies that offer more comprehensive LCM models that could be
explored more in–depth, but even these models would need to be modified to accommodate BSEE’s
existing jurisdictional boundaries. The European approaches to regulating LCM systems in the offshore
industry tend to be less prescriptive and are industry led and risk-based. The U.K. HSE’s KP4 broader
scope program looks beyond strictly material safety to include leadership and preparedness, audits, and
data management, and it holds out promise as a model. The U.K. HSE and PSA’s LCM plans and Failure
Reporting Systems are thorough and comprehensive. The U.K. HSE and PSA’s models also allow
Our review of these entities has led us to conclude that a perfect comparable LCM system was not
identified to present a fully developed conceptual framework that is suitable for BSEE’s challenges.
However, there are opportunities for BSEE to use aspects or elements of these other models to develop
regulatory frameworks of its own. Choosing to build on these existing regulatory frameworks will
probably involve less risk and take fewer resources to design and implement and possibly take less time.
The price for choosing such an approach, however, is the resulting model may be less than optimal.
6. Recommendations
The following recommendations are based on information collected during the research of the above
organizations. Our review also shows that many offshore petrochemical industry participants are
currently engaged in LCM and have robust systems in place. ABS Consulting’s review shows that
regulatory approaches can be displayed on a spectrum of less to more industry engagement as shown in
Figure 8, with “prescriptive” regulations being characterized by command and control regulations, heavy
inspection schedules and onerous reporting requirements for industry. These may or may not align with
existing industry practices. Examples of this include PHMSA’s regulation of pipeline transportation
companies. In contrast, systems based on industry involvement and consensus standards are generally
performance-based and tend to allow industry more flexibility in defining the compliant system that
would meet both their operational needs and the safety and data needs of the Government. In terms of
the LCM systems, these are deemed “Industry Involved (Industry Standards)” and are exemplified by the
IADC, API or ISO LCM programs. A “Hybrid” LCM approach would be a blend of both prescriptive and
industry involved LCM models.
Prescriptive Regulations
Industry-based
Feasibility is a key consideration in developing recommendations that may actually lead to successful
implementation. Defining a regulatory framework that meets the needs of the government yet provides
enough flexibility to accept industry input is a significant policy challenge but one that readily eases
implementation and industry acceptance. Since much of industry has already implemented a LCM
Industry will likely seek to have input based on current business practices and lessons learned to help
mold any new regulations into those that make sense, enhance safety and performance and are
relatively easy to implement. Industry will also desire an effective feedback mechanism that will provide
them shared information and results based on any data they are required to report.
ISO and API standards are already in use by industry, thus any implementation of an LCM program
should begin with a consideration of current industry standards and best practices. BSEE’s approach to
incorporating API Q2 and Q3 will provide a basis for development of a system, and with additional
regulatory guidelines, industry can develop their programs within that framework. By incorporating
these standards by reference, it is likely that BSEE can improve regulatory acceptance as a first step.
6.1 Definitions
A key finding from industry is that if BSEE were to implement any sort of LCM system, regardless of
incorporation of standards or the development of a new standard, BSEE needs to set clear and
understandable definitions and guidelines.
One observation that has been made repeatedly throughout this process is how vital definitions are. In
the review, agencies with clear and comprehensible definitions tended to have better compliance by
their industry since the program was better understood. Industry repeatedly and clearly identified
definitions to be a key issue for them. Industry feedback requested that definitions be: clear, uniform,
plain English, understandable, comprehensible, and specific.
Identifying the pieces of equipment whose failure could result in a catastrophic event is essential to a
risk-based LCM approach. This could ultimately have impacts beyond maintenance and failures, to
design criteria and minimum standards of acceptable conditions. It is critical for LCM systems to clearly
define what needs to be part of an LCM system and what should be recorded and reported. Examples of
this clear definition approach include the USCG which provides a list of components to be checked as
part of a maintenance requirement, and PHMSA which provides broader types of systems to be
incorporated into a LCM system.
Therefore, we recommend that any LCM requirements developed by BSEE place a priority on developing
clear and understandable definitions of what constitutes critical systems. This recommendation is
applicable to LCM in defining clear and concrete reporting thresholds. In addition to what systems are to
be reported and what qualifies as a reportable event, who receives the report is also critical. If the piece
of equipment requires excessive maintenance or fails in a way which could affect safety, this should
In mandating an LCM system, BSEE may not be concerned about the specific maintenance levels of all
the components on a facility. Nor would BSEE need to care about the efficiency or improvements in
operations that an operator would be looking for in an LCM system. These are typically the reasons
industry develops and implements their own LCM systems. The regulatory authority would be more
concerned about the maintenance and performance of critical equipment and systems, which if not
properly maintained, might result in an incident should a failure occur. Definitions of what criteria make
systems critical, such as safety related functions, will be key in reducing the documentation
requirements of the operator. Industry recommends that BSEE define what their “Top 10” critical
equipment or systems concerns are, and focus on the collection of data for those items specifically. This
way, BSEE avoids placing burdens on industry for the collection and reporting of all data, since much of
the data may not be of value.
Due to varying definitions already in place in the industry, standardization, guidance and clear
definitions is a necessary step. OEMs, industry members, industry support, and industry organizations’
definitions of criticality, critical equipment and critical systems have wide variance.
Given the example of a gas detection system, there will be many sensors and different configurations
that may be unique to each OCS unit. Each company may set a different level and different
determination of whether a sensor, a group of sensors, or the entire gas detection system is critical.
Ideally, a LCM system will allow for that flexibility and variation between facilities.
A key issue with a prescriptive approach is that the regulatory guidance may become too specific. With
the diversity of the companies in the industry and the large variety of systems and equipment, finding a
one-size fits all prescriptive approach may have a high likelihood of failure. Many companies already
have implemented custom LCM systems with varying levels of sophistication and detail tailored to suit
their operational needs. This was typically done for business purposes to enhance production and better
manage maintenance costs. Data outputs and inputs may be unique to the company and may not be
comparable to another software solution.
Given that several members of the industry have already invested significant time and resources for
custom-built asset management software solutions (which may incorporate LCM and Failure Reporting
along with maintenance planning and requirements like Safety and Environmental Management
Systems [SEMS]), the O&G industry may present strong pushback on an approach they deem to be too
prescriptive, particularly if it is seen to be duplicative of current systems in use by industry.
The USCG’s maintenance and inspection requirements could be a useful prescriptive framework for
BSEE to consider adopting. The USCG does not have a specific LCM system as part of their regulations;
however, the USCG does maintain a list of specific critical equipment as part of their Subchapter Q and
operators are expected to maintain their vessels and equipment properly. This list is a culmination of
decades of accident history, which points to a key weakness in this approach: the list is not predictive,
but reactive. Much of Subchapter Q is predicated on maintaining a certain standard for critical
equipment and sets an interval period for inspection. For example, BSEE should consider developing
maintenance requirements in 30 CFR 250.10(a)(2) and 30 CFR 250.130(b), 30 CFR 250.401(e) and any
other sections of BSEE regulations for particular components that have been associated with incidents
or failures that have impacted health, safety, property, and the environment. This would be akin to the
USCG’s mandated maintenance requirements for components associated with lifesaving, firefighting,
pollution prevention, engineering, electrical and structural systems.
Under a Safety Case regime, the company would outline what their activity will be, how to implement a
program, and how the company will operate. Regulations would provide the structure and guidelines for
what should be included in the program and how the facility can meet or exceed these requirements.
This approach would shift the role of the regulator from an inspection body to an auditing body. Many
regulators allow industry to create and implement their internal program, with the regulating agency
acting as a validator or auditor of the plan.
BSEE should endeavor to ensure (when applicable) that required LCM reporting does not have punitive
consequences for industry participants when submitting required reports. In this regard a review of the
Oil and Gas UK’s Industry Mutual Hold Harmless (IMHH) agreement may be useful to help develop a
regulatory or legal structure which places limits on industry participant liability. Inspections and auditing
of the LCM program must also be specifically addressed in the LCM section of the safety case.
Communications are a critical element as well. The LCM portion of the safety case should include
reporting requirements (i.e., paperwork, data uploads, telephone notifications) that are easy and quick
to submit.
While this approach reduces the operational load of the regulator, it also limits the agency's ability to
control and affect change throughout the industry. BSEE would need to develop the common standards,
but would provide the industry latitude in the implementation of a process to meet those minimum
common standards.
ISO and API standards are already in use in much of the industry, thus the assessment and
understanding of industry standards will be a key first step. In order to use industry standards to
establish LCM across the industry, BSEE must also secure industry participation. By incorporating these
standards by reference into its regulations, BSEE can facilitate regulatory compliance among industry.
BSEE’s approach to incorporating API Q2 and 18 LCM would provide a basis and starting point for
development of a system, and with additional regulatory guidelines, the industry can gauge how well
their existing programs align with the minimum requirements as defined by BSEE.
Communication and cooperation are critical for a program of this nature to be effective. There must be
an effective feedback loop with exchange of information for required data input requirements. One way
to ensure industry and BSEE communicate openly and routinely would be to establish a program or
forum similar to that of Oil and Gas UK’s PILOT program. PILOT is an O&G taskforce which is a unique
partnership between the U.K. O&G industry. It involves operators, contractors, suppliers, trade unions,
SME’s and government working in cooperation. In order to have an effective and functional relationship
between industry and BSEE, a program or forum such as PILOT could foster trust, open communications,
functional perspective and direct feedback for both industry and BSEE. A third party organization like the
In order for industry to provide accurate information, there would have to be a non-retribution process
in which to make reports, especially if self-reporting is possible. If industry feels they will be subject to
negative impacts from data collected, they will not make accurate reports. BSEE could incorporate into
regulations a process similar to that of the FAA and its third party certification, audit, and self-reporting
systems. The FAA Voluntary Disclosure Reporting Program allows air carriers and regulated entities to
self-report apparent violations. Under this program, a certificate holder or owner will receive a letter of
correction in lieu of a civil penalty for self-reporting violations, apparent violations, or instances of non-
compliance. The FAA believes that a cooperative and advisory approach to violations or issues will
enhance and promote safety.
The Environmental Protection Agency’s (EPA) Audit Policy includes a self-reporting program where by
industry organizations can report environmental violations. This program provides incentives that
encourage regulated entities to voluntarily come into compliance with federal regulations. The EPA
program includes a confidentiality process where-by, when a submitter self-discloses violations, if they
claim the material is CBI, the EPA must follow the CBI regulations.
Such a hybrid solution does offer a number of practical advantages including industry collaboration,
monitoring efficiency and regulatory adaptability. We also note that BSEE has already taken some
preliminary steps in this direction by adopting API guideline Q1.
The API standard Q1 and Q2 already provides a structure with standardized forms that industry can fill
out in order to participate. If applied across the industry, API standards can help standardize the
reporting of data, thus increasing the functionality and ease of analysis once collected.
The incorporation of industry standards like IADC or API standards would likely face less resistance from
industry than a prescriptive approach, particularly industry-accepted and practiced standards. By having
clear, understandable, and uniform definitions and reporting requirements, this should result in safety
or risk metrics that BSEE can use as indicators to show the trends over time in safety. While a zero
incident goal might not be achieved immediately, capturing comparable data and using that data to
improve safety and increase compliance should provide percentage improvements over time.
BSEE is faced with a decision as to the type of LCM system it chooses to implement. While a prescriptive
approach may reduce liability for specific systems and components, BSEE would need to identify what
the components are to be included in the LCM system, and whether they are being properly maintained.
As such, an LCM system would contain a significant amount of information not typically collected by the
agency and may generate proprietary data concerns with agency databases. BSEE needs to determine if
these data would need to be submitted to the agency or simply maintained by industry and be subject
to inspection by BSEE. Such a prescriptive system would not address any systems or equipment not
previously identified. In addition, BSEE may have difficulty maintaining the currency of a prescriptive list
of critical components due to advances in technology and changes in designs. Finally, a prescriptive
approach that does not align with the current industry LCM systems is likely to meet with stiff resistance
from industry, especially if compliance with it significantly increases the regulatory burden. Therefore, a
BSEE-mandated, prescriptive LCM system for the offshore industry will require a significant policy effort
on BSEE’s part to both build consensus and ensure compliance.
BSEE is likely to have greater success in establishing LCM system requirements by adapting current
industry best practices into an industry-based, performance standard. By focusing on the objectives and
performance of the LCM system, rather than the specific methods, equipment, and data reporting
mechanisms, BSEE’s role would transition to one of monitoring and auditing the LCM system. This would
provide each operator the leeway to define their own critical systems and to implement the LCM system
they deem appropriate. This would typically involve the application of risk-based decision-making tools
like FMECA, bowtie analysis, risk identification, or other approaches to identify critical systems and
equipment that should be addressed in the LCM system. Similar to the existing Safety and
Environmental Management System approach, BSEE would review industry documentation and records
indicating the existence and effectiveness of the LCM system while not actually collecting the data. This
approach addresses the industry concerns about sharing data and greatly enhances the likelihood of
successful implementation.
Introduction
PROGRAM HISTORY
How long has the program(s) been in place?
Task 3, 2.3.5.1 - Are failures reporting systems utilized by regulatory bodies? If so, which regulators use
them? What types of systems? How long have they been utilized?
Task 3, 2.3.5.7 - Identify any commercial, for profit failure reporting systems that are available on the
open market and to which industries they are associated with. Evaluate such systems and report on
their cost to participate and their historical performance.
Task 2, 2.3.4.5 - Do any of the groups evaluated under this contract make use of industry standards,
recommended practices, specifications, etc. which address the contents of a LCM program? If
appropriate, identify the document being used.
Task 3, 2.3.5.4 - Has the data generated from a failure reporting system ever been used by an
equipment manufacturer to redesign or change equipment specifications? Provide a detailed accounting
of how this process has worked for any identified occurrence.
PROGRAM EFFECTIVENESS
How do regulators assess the effectiveness of their program(s)?
Task 2, 2.3.4.4 - How effective are the various LCM programs? How is effectiveness/performance of
these programs measured? How long have these programs been in existence?
Task 3, 2.3.5.5 - How are failure reporting systems structured in regards to use of proprietary data/trade
secrets in regards to equipment covered under a system, company anonymity when participating in
such a system (is anonymous reporting effective and how is it achieved? If anonymous reporting is not
used can such a system still be effective?) and how is data from the system distributed and utilized by a
company or a regulator to mitigate risk.
Task 3, 2.3.5.6 - Are safety/environmental incidents included in a failure reporting system or just
equipment malfunctions/upsets? If not, are they reported separately? If they are part of the failure
reporting system include in assessment of them.
Task 3, 2.3.5.8 - Define the associated data analysis requirements required in a failure reporting system
and specify what data needs to be collected for regulatory purposes.
PROGRAM OUTCOMES
How do regulators evaluate outcomes and satisfaction with their program(s)?
Task 3, 2.3.5.9 - Develop chart flow diagrams of failure reports from origin back to OEM, service
providers, and the regulatory body for any systems evaluated.
EFFECTIVENESS DATA
Task 3, 2.3.5.10 - Identify examples of OEM and service provider utilization of such failure reports in
product assessment and improvement and report on how well it has worked.
Provide available data on the program’s effectiveness based on the prevalence or avoidance of various
consequences.
LIABILITIES
Determine the effect, if any, of each program example on the legal liabilities of the government
regulatory and the members of the regulated industry.
American Association of State Highway Officials. (2005, January 1). AASHTO - Programs . Retrieved
February 26, 2015, from http://www.transportation.org/Pages/Default.aspx:
http://www.transportation.org/Pages/Programs.aspx
American Institute of Aeronautics and Astronautics. (2014, January 1). About AIAA. Retrieved September
30, 2014, from www.aiaa.org: http://www.aiaa.org/secondary.aspx?id=153
American National Standards Institute, American Petroleum Institute. (2007, December 1). ANSI/API
Spec Q1. Retrieved September 26, 2014, from http://www.mambocert.com:
http://www.mambocert.com/assets/downloads/20120523/20120523120312707.pdf
American Petroleum Institute. (2004, May 1). API RP 75, 3rd edition. Retrieved September 27, 2014,
from www.techstreet.com: http://www.techstreet.com/products/1157045
American Petroleum Institute. (2006, April 1). API RP 2FB, 1st edition. Retrieved September 27, 2014,
from www.techstreet.com: http://www.techstreet.com/products/1262245
American Petroleum Institute. (2007, May 1). API RP 2D, 6th edition. Retrieved September 28, 2014,
from www.techstreet.com: http://www.techstreet.com/products/1503805
American Petroleum Institute. (2009, November). API RP 574. Retrieved January 2, 2015, from
https://global.ihs.com/doc_detail.cfm?document_name=API%20RP%20574#abstract
American Petroleum Institute. (2011, December 00). API Spec Q2, 1st edition, Rev.1. Retrieved
September 28, 2014, from global.ihs.com:
https://global.ihs.com/doc_detail.cfm?&item_s_key=00579726&item_key_date=890631
American Petroleum Institute. (2011). Specification for Quality Management System Requirements for
Service Supply Organizations for thePetroleum and Natural Gas Industries. American Petroleum
Institute. Retrieved December 11, 2014
American Petroleum Institute. (2012, March 1). API Spec 2C, 7th edition. Retrieved September 28, 2014,
from www.techstreet.com: http://www.techstreet.com/products/1830968
American Petroleum Institute. (2013, December 5). API RP 571 Damage Mechanisms. Retrieved January
2, 2015, from http://www.api.org/events-and-training/api-u-training/api-u-calendar/2013-
events/12-03-13-dmech
American Petroleum Institute. (2013, April 1). Critical Equipment. Recommended Practice for
Development of a Safety and Environmental Management Program for Offshore Operations and
Facilities(3rd). Houston, TX, USA: American Petroleum Institute.
American Petroleum Institute. (2013, September). Managing System Integrity for Hazardous Liquid
Pipelines. Retrieved January 5, 2015, from http://www.api.org/publications-standards-and-
statistics/standards/whatsnew/publication-updates/new-pipeline-publications/api_rp_1160
American Petroleum Institute. (2013). Specification for Wellhead and Christmas Tree Equipment.
Washington, DC: American Petroleum Institute. Retrieved December 30, 2014
American Petroleum Institute. (2014, October 12). FAQs and Inquiries. Retrieved October 12, 2014, from
www.api.org: http://www.api.org/publications-standards-and-statistics/standards/faqs-and-
inquiries
American Petroleum Institute. (2014). Specification for Drill-through equipment repair and
remanufacturing. Washington, D.C.: American Petroleum Institute. Retrieved December 9, 2014,
from http://mycommittees.api.org/standards/ecs/sc16/TG7/Shared%20Documents/API-
16AR%20Drill%20Through%20Equipmenr%20Repair%20and%20Remanufacturing%20V1%20-
%2016AR%20meeting%20notes.pdf
American Petroleum Institute. (2014). Specification for Quality Management System Requirements for
Manufacturing Organizations for the Petroleum and Natural Gas Industry. Washington, DC:
American Petroleum Institute. Retrieved October 9, 2014
American Petroleum Institute. (2014, December 5). Spills & Accidental Response. Retrieved December 5,
2014, from http://www.api.org/environment-health-and-safety/clean-water/oil-spill-
prevention-and-response/spills-and-releases
American Waterways Operators. (2013). 2013 Annual Report. Arlington, Virginia: American Waterways
Operators. Retrieved January 6, 2015, from
http://www.americanwaterways.com/media/annual-reports/awo-annual-reports
American Waterways Operators. (2013, October 9). Responsible Carrier Program 2013. Responsible
Carrier Program 2013. Arlington, Virginia, United States: American Waterways Operators.
Retrieved January 6, 2015, from http://www.americanwaterways.com/join/carrier
American Waterways Operators. (2013, January 1). Towing Vessel Inspection Bureau - TVIB-RCP Audit
Flowchart. Retrieved January 5, 2015, from http://www.thetvib.org/awo-responsible-carrier-
program/tvib-rcp-audit-documents/: http://www.americanwaterways.com/initiatives/safety-
and-environment/responsible-carrier-program
American Waterways Operators. (2015, January 1). Safety and Environment, Responsible Carrier
Program. Retrieved January 5, 2015, from
http://www.americanwaterways.com/initiatives/safety-and-environment/responsible-carrier-
program: http://www.americanwaterways.com/search/node/RCP
American Waterways Operators. (2015, January 1). Safety and Environment, Responsible Carrier
Program. Retrieved January 26, 2015, from
http://www.americanwaterways.com/initiatives/safety-and-environment/responsible-carrier-
program: http://www.americanwaterways.com/initiatives/safety-and-
environment/responsible-carrier-program
Amtrak. (2014, September 23). Programs. Retrieved September 23, 2014, from
http://www.amtrak.com/servlet/BlobServer?blobcol=urldata&blobtable=MungoBlobs&blobkey
=id&blobwhere=1249200716867&blobheadervalue1=attachment;filename=Amtrak_UpdateKeyI
TPrograms-092009.pdf
Anonymous. (2015, January 20). Senior Oil and Gas Industry Participant. (B. L. Iddins, Interviewer)
Apache Corporation. (2013). Form 10-Q (Quarterly Report). Houston, Texas: Apache Corporation.
Retrieved December 7, 2014, from
http://www.otcmarkets.com/edgar/GetFilingPdf?FilingID=9598691
API. (2012). Global Chemical Management | API Supporting SAICM. Retrieved September 25, 2014, from
API.org: http://www.api.org/environment-health-and-safety/health-safety/global-chemical-
management/~/media/Files/EHS/Process-Safety/RASA-Brochure-ForWeb-HiRes.ashx
Auditor General New Zealand. (2004, January 1). Part 5: Life cycle costing analysis-Office of the Auditor-
General New Zealand. Retrieved September 19, 2014, from www.oag.govt.nz:
http://www.oag.govt.nz/2004/lav/part5.htm
Aviation Safety Reporting System. (2014, September 30). Aviation Safety Reporting System. (A. S.
System, Producer) Retrieved September 30, 2014, from Aviation Safety Reporting System:
http://asrs.arc.nasa.gov/
Boman, K. (2014, August 12). BSEE: Better Standards Needed to Address Bolt, Connector Performance.
Retrieved December 5, 2014, from Rigzone.com:
https://www.rigzone.com/news/oil_gas/a/134500/BSEE_Better_Standards_Needed_to_Addres
s_Bolt_Connector_Performance/?all=HG2
(2014). BPA Call Order No. E14PB00045. Herdon, VA: Bureau of Safety and Environmental Enforcement
(BSEE).
Brad Edwards, J. G. (1999, April ). Effectiveness of ISO 14001 in the United States. University of California
Santa Barbara: Donald Bren School of Environmental Science And Management.
Bradley, D. (2015, January 29). NatGas Pipe Incidents in Populated Areas Not Declining Under PHMSA
Program. Retrieved January 30, 2015, from http://www.naturalgasintel.com:
http://www.naturalgasintel.com/articles/101194-natgas-pipe-incidents-in-populated-areas-not-
declining-under-phmsa-program
Bureau of Environmental Safety and Enforcement. (2013). Investigation of November 16, 2012,
Explosion, Fire and Fatalities at West Delta Block 32 Platform E. Bureau of Environmental Safety
and Enforcement. Retrieved December 7, 2014
Bureau of Land Management. (2001, April 18). Resource Notes. Retrieved from Bureau of Land
Management: http://www.blm.gov/nstc/resourcenotes/respdf/RN45.pdf
Bureau of Safety and Environmental Enforcement. (2013). Boom Hoist Wire Rope Line Failure Results in
Fatality High Island Area Block A557, Platform “A”,. New Orleans: Bureau of Safety and
Environmental Enforcement. Retrieved December 7, 2014, from
http://www.bsee.gov/uploadedFiles/BSEE/Enforcement/Accidents_and_Incidents/Panel_Investi
gation_Reports/HI-A557%20Panel%20Report%20-%20FINAL%20(1).pdf
Bureau of Safety and Environmental Enforcement. (2014, September 1). About BSEE. (B. o. Enforcement,
Producer) Retrieved September 1, 2014, from Bureau of Safety and Environmental Enforcement:
http://www.bsee.gov/About-BSEE/index/
Canada, Newfoundland & Labrador Offshore Petroleum Board. (2014, September 30). About C-NLOPB.
(N. L. Canada, Producer) Retrieved September 30, 2014, from Canada, Newfoundland& Labrador
Offshore Petroleum Board: http://www.cnlopb.ca/abt_mandate.shtml
Canada-Nova Scotia Offshore Petroleum Board. (2014, September 30). About Us. (C.-N. S. Board,
Producer) Retrieved September 30, 2014, from Canda-Nova Scotia Offshore Petroleum Board:
http://www.cnsopb.ns.ca/about-us/about-us
Canada-Nova Scotia Offshore Petroleum Board. (2014, September 30). Incident Reporting. (C.-N. S.
Board, Producer) Retrieved September 30, 2014, from Canada-Nova Scotia Offshore Petroleum
Board: http://www.cnsopb.ns.ca/health-and-safety/incident-reporting
Canada-Nova Scotial Offshore Petroleum Board. (2014, September 30). Life Cycle Approach. (C.-N. S.
Board, Producer) Retrieved September 30, 2014, from Canada-Nova Scotial Offshore Petroleum
Board: http://www.cnsopb.ns.ca/about-us/what-we-do/life-cycle-approach
CCD Health Systems. (n.d.). About CCD Systems. Retrieved September 30, 2014, from
http://www.ccdsystems.com/AboutCCD/HowtoReachUs.aspx
Center for Chemical Process Safety. (2015). Introduction to Auditing. Retrieved 4 28, 2015, from
http://www.aiche.org/ccps/topics/elements-process-safety/learn-
experience/auditing/introduction
Center for Chemical Process Safety. (2015). Introduction to Contractor Management. Retrieved 4 28,
2015, from http://www.aiche.org/ccps/topics/elements-process-safety/manage-
risks/contractor-management/introduction
Center for Chemical Process Safety. (2015). Introduction to Hazard Identification and Risk Analysis.
Retrieved 4 28, 2015, from http://www.aiche.org/ccps/topics/elements-process-
safety/understand-hazard-risk/hazard-identification-and-risk-analysis/introduction
Center for Chemical Process Safety. (2015). Introduction to Management of Change. Retrieved 04 28,
2015, from http://www.aiche.org/ccps/topics/elements-process-safety/manage-
risks/management-change/introduction
Center for Chemical Process Safety. (2015). Introduction to Management Review and Continuous
Improvement. Retrieved 4 28, 2015, from http://www.aiche.org/ccps/topics/elements-process-
safety/learn-experience/management-review-and-continuous-improvement/introduction
Center for Chemical Process Safety. (n.d.). Introduction to Asset Integrity and Reliability. Retrieved 04 28,
2015, from http://www.aiche.org/ccps/topics/elements-process-safety/manage-risks/asset-
integrity-and-reliability/introduction
Centers for Disease Control. (2013, April 26). Morbidty and Mortality Weekly Report - Fatal Injuries in
Offshore Oil and Gas Operations — United States, 2003–2010. Retrieved December 31, 2014,
from www.cdc.gov: http://www.cdc.gov/mmwr/preview/mmwrhtml/mm6216a2.htm
Centers for Disease Control and Prevention. (2014, April 14). About CDC. Retrieved September 30, 2014,
from CDC.gov: http://www.cdc.gov/about/organization/mission.htm
Centers for Disease Control and Prevention. (2014, 14 April). Mission, Role , and Pledge. Retrieved from
Centers for Disease Control and Prevention:
http://www.cdc.gov/about/organization/mission.htm
Code of Federal Regulations (CFR). (2013, April 5). What hazards analysis criteria must my SEMS
program meet? 30 CFR 250.1911.
Cohen, M., Gottlieb, M., Linn, J., & Richardson, N. (2011). Deepwater Drilling: Law, Policy, and Economics
of Firm Organization and Safety. Vanderbilt Law Reveiw, 1853-1916.
(2014). Commandant Instruction 16000.7B, Marine Safety Manual Volume II, Materiel Inspection.
Washington D.C. : U.S. Coast Guard .
(2013). Commandant Instruction 3501, Casualty Reporting (CASREP) Procedures (Materiel) Manual.
Washington D.C. : U.S. Coast Guard .
(2007). Commandant Instruction M10550.25, Electronics Manual. Washington D.C. : U.S. Coast Guard .
(2014). Commandant Instruction M11011.11, Civil Engineering Manual . Washington D.C. : U.S. Coast
Guard.
(2008). Commandant Instruction M16000.10A, USCG Marine Safety Manual, VOLUME V Investigation
and Enforcement. Washington D.C. : U.S. Coast Guard .
(2013). Commandant Instruction M4500.5D., Personal Property Management Manual. Washington D.C.:
U.S. Coast Guard.
(2013). Commandant Instruction Manual 5000.10C Major Systems Aquisition Manual. Washington D.C. :
U.S. Coast Guard.
ConocoPhillips. (2014, September 24). Life Cycle Thinking. Retrieved September 24, 2014, from
ConocoPhillips: http://www.conocophillips.com/sustainable-
development/environment/Pages/life-cycle-thinking.aspx
ConocoPhillips. (2015, January 21). Life Cycle Thinking. Retrieved January 21, 2015, from
http://www.conocophillips.com/sustainable-development/environment/Pages/life-cycle-
thinking.aspx
ConocoPhillips. (n.d.). Life Cycle Thinking. Retrieved January 21, 2015, from
http://www.conocophillips.com/sustainable-development/environment/Pages/life-cycle-
thinking.aspx
Cooke, R. R. (2011). Precursor Analysis for Offshore Oil and Gas Drilling:From Prescriptive to Risk-
Informed Regulation. Resources for the Future, Washington, D.C. Retrieved November 15, 2014,
from http://www.rff.org/RFF/documents/RFF-DP-10-61.pdf
Crowley. (2014). About Us. Retrieved September 30, 2014, from http://www.crowley.com/About-
Us/Company-Overview
Curry, T. (2015, February 3). Members Fume Over Delayed Oil Tank Car Rule. Washington, District of
Colombia, U.S.A. Retrieved February 5, 2015, from http://blogs.rollcall.com/the-
container/members-fume-over-delayed-oil-tank-car-rule/?dcz=
Defence Acquisition University. (2011, June 14). DoD LCM and PSM Rapid Deployment Training.
Retrieved September 17, 2014, from United States Department of Defense:
www.dau.mil/homepage documents/PSM RDT (v10 TTailored 14 Jun 11).pdf
Department of Defense. (1985, July 24). Military Standard 2155. Retrieved December 18, 2014, from
http://www.halthass.co.nz/wp-content/uploads/standards/mil_std_2155.pdf
Department of Transportation. (2015, February 12). Moving Ahead for Progress in the 21st Century Act
(MAP-21). Retrieved February 26, 2015, from http://www.dot.gov/map21:
http://www.dot.gov/map21
Department of Transportation FHWA. (1999, April 8). FEDERAL-AID POLICY GUIDE, Transmittal 25.
Retrieved February 26, 2015, from
http://www.fhwa.dot.gov/legsregs/directives/fapg/0500bsup.htm:
http://www.fhwa.dot.gov/legsregs/directives/fapg/0500bsup.htm
Department of Transportation FHWA. (2014, July 8). Strategic Highway Safety Plan (SHSP). Retrieved
February 26, 2015, from http://safety.fhwa.dot.gov/hsip/shsp/:
http://safety.fhwa.dot.gov/hsip/shsp/
Devaney, T. (2014, November 11). Business groups brace for deluge of regs. Retrieved January 30, 2015,
from thehill.com: http://thehill.com/regulation/223769-biz-groups-brace-for-deluge-of-
regulation
Devlin, G. (2014, June 27). Product Life Cycle Management. Cameron. Retrieved September 25, 2014,
from
http://www.google.com/url?sa=t&rct=j&q=&esrc=s&frm=1&source=web&cd=2&cad=rja&uact=
8&ved=0CDAQFjAB&url=https%3A%2F%2F1.800.gay%3A443%2Fhttp%2Fmycommittees.api.org%2Fstandards%2Fecs%2Fsc18%
2FMeeting%2520Materials%2F2013%2FWashington%2520Meeting%2520-
%2520June%25202013%2FAttachment%2
Dunmade, I., & Rosentrater, K. (2009). A Treatise on the Application of Life Cycle Management Principles
in Agriculture & Biological Engineering. ASABE Annual International Meeting (pp. 1-2). Reno, NV:
American Society of Agricultural and Biological Engineers. Retrieved September 23, 2014, from
http://naldc.nal.usda.gov/naldc/download.xhtml?id=40065&content=PDF
Eaton, C. (2013, November 13). Feds cite Houston firm, contractors in fatal Gulf blast. Retrieved
December 7, 2014, from Fuelfix.com: http://fuelfix.com/blog/2013/11/13/safety-agency-cites-
houston-firm-contractors-in-fatal-platform-blast/
Energy Division of HSE’s Hazardous Installations Directorate. (2014). Key Programme 4 (KP4): Ageing and
life extension programme. Health and Safety Executive.
Environmental Protection Agency. (1993, January). Life Cycle Design Guidance Manual. Retrieved
January 12, 2015, from http://nepis.epa.gov/Adobe/PDF/30002PR5.PDF
Eriksson, S. (2014, January 29). Use of Standards in Regulations to Accomplish PSA Regulatory Objectives.
Retrieved April 20, 2015, from http://www.bsee.gov/Regulations-and-
Guidance/Standards/2014/4-Regulatory-Policy-Needs-2-Eriksson-Svein/
European Environment Agency. (2015, February 25). Major accident reporting system (MARS). Retrieved
January 8, 2015, from http://www.eea.europa.eu/data-and-maps/data/external/major-
accident-reporting-system-mars
Executive Office of Health and Human Services Department of Public Health Bureau of Healthcare Safety
and Quality. (2011, April 4). User Manual Health Care Facility Monitoring System. Retrieved
September 30, 2014, from http://www.mass.gov/eohhs/docs/dph/quality/healthcare/hcfrs-
user-manual.pdf
Executive, S. E. (2014, October 8). Chief Executive Officer. (J. C. Hendrickson, Interviewer)
ExxonMobil. (2014). Up close: life cycle assessment. Retrieved September 30, 2014, from
http://corporate.exxonmobil.com/en/community/corporate-citizenship-report/managing-
climate-change-risks/up-close-life-cycle-assessment?parentId=c7582d41-5b74-4e12-928d-
643cd1ec8813
Fausset, R. a. (2010, September 2). Los Angeles Times. Retrieved December 7, 2014, from Oil platform
explodes off Louisiana: http://articles.latimes.com/2010/sep/02/nation/la-na-oil-explosion-
20100903
Federal Aviation Administration. (2014, September 29). About FAA. (F. A. Administration, Producer)
Retrieved September 29, 2014, from Federal Aviation Administration:
http://www.faa.gov/about/
Federal Aviation Administration. (2014, September 29). FAA Aviation Safety Analysis and Sharing. (F. A.
Administration, Producer) Retrieved September 29, 2014, from Federal Aviation Administration:
http://www.asias.faa.gov/pls/apex/f?p=100:1:14119288055667:::::
Federal Highway Administration. (2004, April 16). Highway Performance Monitoring System (HPMS), Vol.
18. (The Urban Transportation Monitor) Retrieved February 10, 2015, from
http://www.fhwa.dot.gov/policyinformation/hpms/volumeroutes/ch2.cfm#a37:
http://www.fhwa.dot.gov/policyinformation/hpms/volumeroutes/
Federal Highway Administration. (2014, October 15). Highway Safety Improvement Program. Retrieved
February 10, 2015, from http://safety.fhwa.dot.gov/safetealu/guides/guide051509.cfm:
http://safety.fhwa.dot.gov/safetealu/guides/guide051509.cfm
Federal Highway Administration. (2014, September 29). No-Federal Applications of the Highway
Performance Monitoring System. (F. H. Administration, Producer) Retrieved September 29,
2014, from Federal Highway Admisitration: No-Federal Applications of the Highway
Performance Monitoring System
Federal Highway Administration. (2015, January 1). About Highway Performance Monitoring System
(HPMS). Retrieved February 11, 2015, from
http://www.fhwa.dot.gov/policyinformation/hpms/abouthpms.cfm:
http://www.fhwa.dot.gov/policyinformation/hpms.cfm
Federal Highway Administration. (2015, January 1). Highway Performance Monitoring System (HPMS).
Retrieved February 10, 2015, from http://www.fhwa.dot.gov/policyinformation/hpms.cfm:
http://www.fhwa.dot.gov/ohim/hpmsarch.cfm
Federal Highway Administration. (2015, January 1). Highway Performance Monitoring System (HPMS).
Retrieved February 10, 2015, from
http://www.fhwa.dot.gov/policyinformation/hpms/hpmsprimer.cfm:
http://www.fhwa.dot.gov/policyinformation/hpms.cfm
Federal Highway Administration. (2015, April 20). Pavement Management Primer. Retrieved from
fhwa.dot.gov: http://www.fhwa.dot.gov/infrastructure/asstmgmt/pmprimer.pdf
Federal Railroad Administration. (2007, October). Collision Hazard Analysis Guide: Commuter and
Intercity Passenger Rail Service. Washington, District of Columbia, U.S.A. Retrieved from
http://www.fra.dot.gov/Elib/Details/L03191
FHWA. (2012, July 17). A Summary of Highway Provisions - MAP-21 - Moving Ahead for Progress in the
21st Century. Retrieved February 10, 2015, from
http://www.fhwa.dot.gov/map21/summaryinfo.cfm.
FHWA. (2012, July 17). A Summary of Highway Provisions - MAP-21 - Moving Ahead for Progress in the
21st Century. Retrieved February 10, 2015, from
http://www.fhwa.dot.gov/map21/summaryinfo.cfm:
http://www.fhwa.dot.gov/map21/summaryinfo.cfm
Finn, F. (1998, July). Pavement Management Systems — Past, Present, and Future, Public Roads: 80
Years Old, But the Best Is Yet to Come. Retrieved from
http://www.fhwa.dot.gov/publications/publicroads/98julaug/pavement.cfm
Five Winds International. (2004, August). Gas to Liquids Life Cycle Assessment Synthesis Report.
Retrieved January 14, 2015, from
http://www.sydneypeakoil.com/davek/GTL_LCA_Synthesis_Report.pdf
Foss. (2014). About Us. Retrieved September 30, 2014, from http://www.foss.com/about-us/
Freeby, G. A. (2013, August 23). Bridge Inspection Manual. Retrieved from Chapter 7, Section 4: Bridge
Management System:
http://onlinemanuals.txdot.gov/txdotmanuals/ins/bridge_management_system.htm
Fuetsch, M. (2015, January 22). DeFazio Blasts DOT Over Failure to Finalize Tank Car Rule, Calls for
PHMSA Audit. Transportation Topics: The Newspaper of Trucking and Freight Transportation.
Washington, District of Colombia. Retrieved February 5, 2015, from
http://www.ttnews.com/articles/basetemplate.aspx?storyid=37125
GL Noble Denton. (2010, December). Review and Comparison of Petroleum Safety Regulatory Regimes
for the Commission for Energy Regulation. Retrieved February 16, 2015, from
https://www.cer.ie/docs/000458/cer11015.pdf
Glossary of Defense Acquisition Acronyms and Terms. (2015, January 7). Retrieved from Department of
Defense, Defense Acquisition University: https://dap.dau.mil/glossary/Pages/Default.aspx
Gordon R. Toevs, J. J. (2011, August). Assesment, Inventory, and Monitoring Strategy For Integrated
Renewable Resources Management. Retrieved from Bureau of Land Management:
http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/polic
y/ib_attachments/2012.Par.53766.File.dat/IB2012-080_att1.pdf
Government Accounting Office. (2011, April 1). 23 CFR 500.108 - SMS. Retrieved February 26, 2015,
from http://www.gpo.gov/fdsys/granule/CFR-2011-title23-vol1/CFR-2011-title23-vol1-sec500-
108: http://www.gpo.gov/fdsys/granule/CFR-2011-title23-vol1/CFR-2011-title23-vol1-sec500-
108
Graham, D. a. (2012). Experiences of Test Automation: Case Studies of Software Test Automation. Upper
Saddle River, NJ : Addison-Wesley.
Habich, N. (2001, April 18). Ecological Site Inventory Query (Inventory Data System). Resource Notes, pp.
1-2.
Health and Safety Executive. (2014). KP4 Programme. Retrieved September 23, 2014, from Health and
Safety Executive: http://www.hse.gov.uk/offshore/ageing/kp4-programme.htm
Health and Safety Executive. (2014). Offshore Installations and Wells (design and construction, etc)
Regulations 1996. Retrieved from Health and Safety Executive:
http://www.hse.gov.uk/offshore/notices/on_37.htm
Health and Safety Executive. (2014). RIDDOR - Reporting of Injuries, Diseases and Dangerous
Occurrences Regulations 2013. Retrieved from Health and Safety Executive:
http://www.hse.gov.uk/riddor/
Health and Safety Executive. (2014). Types of reportable incidents. Retrieved from Health and Safety
Executive: http://www.hse.gov.uk/riddor/reportable-incidents.htm
Homeland Security Institute. (2009). Independent Evaluation of United States Coast Guard Prevention
Programs-Marine Safety and Marine Environmental Protection. Arlington: Homeland Security
Institute. Retrieved from
http://www.uscg.mil/MarineSafetyProgram/docs/USCG_Prevention_Task_08-
53%2025%20April%2009.pdf
Hudson, B. G. (2010, November). Extending the life of an ageing offshore facility, Society of Petroleum
Engineers 138654. Retrieved January 6, 2015, from
http://www04.abb.com/global/seitp/seitp202.nsf/0/001a63cdd274a7d5c12577d60026c217/$fil
e/ADIPEC+paper+-+Extending+the+life+of+an+ageing+offshore+facility.pdf
IADC. (2014, September 30). About. Retrieved September 30, 2014, from http://www.iadc.org/about/
IADC. (2014, January 1). Appendix to Health, Safety and Environment Case Guidelines for Offshore
Drilling Contractors, 3.5. Retrieved December 31, 2014, from http://www.iadc.org/wp-
content/uploads/doc-MODU-HSE-Case-Guidelines-Appendices.pdf
IADC. (2014, January 1). Health, Safety, and Environmental Case Guideline for Mobile Offshore Drilling
Units, 3.5. Retrieved December 19, 2014, from HSE Guidelines: http://www.iadc.org/wp-
content/uploads/doc-MODU-HSE-Case-Guidelines.pdf
Ib Larsen, K. N. (2013, May 13). Consolidated Act on Safety, etc. for Offshore Installations for
Exploration, Extraction and Transport of Hydrocarbons (Offshore Safety Act). Netherlands.
(2009). Independent Evaluation USCG Prevention Program. Arlington, VA: Homeland Security Institute.
Info Mimet. (2015, Febuary 25). Databases Proprietary. Retrieved January 8, 2015, from Major Hazard
Incident Data Service: http://w3.cetem.gov.br/infomimet/vercadastro1_en.asp?count=131
Institute of Asset Management. (2008). What is PAS55? Retrieved January 6, 2015, from
https://theiam.org/products-and-services/pas-55/what-pas55
Institute of Asset Management. (2008, January 6). What is PAS55? Retrieved January 6, 2015, from
https://theiam.org/products-and-services/pas-55/what-pas55
International . (2014, December 31). ISO/TS 15926-8:2011 - Industrial automation systems and
integration -- Integration of life-cycle data for process plants including oil and gas production
facilities -- Part 8: Implementation methods for the integration of distributed systems: Web
Ontolog. Retrieved December 31, 2014, from www.iso.org:
http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=52456
International Association of Drilling Contractors. (2009, July 27). Health, Safety, and Environmental Case
Guidelines for Land Drilling Units. Retrieved December 19, 2014, from IADC HSE Guidelines:
http://www.iadc.org/wp-content/uploads/doc-Land-Drilling-HSE-Guidelines.pdf
International Association of Drilling Contractors. (2012, February 20). CCGD8 Marine Safety Bulletin
dated 6 February 2012, Reporting Requirements – Failure of Critical Systems. Retrieved
December 17, 2014, from http://www.iadc.org/wp-content/uploads/20120220-to-CCGD8-on-
MSIB.pdf
International Association of Drilling Contractors. (2014, December 19). Drilling Lexicon. Retrieved
December 19, 2014, from Near-Miss: http://www.iadclexicon.org/near-miss/
International Association of Drilling Contractors. (2014). Drilling Lexicon. Retrieved December 19, 2014,
from Near-Miss: http://www.iadclexicon.org/near-miss/
International Association of Drilling Contractors. (2014, Decemeber 31). HSE Management Objectives.
Retrieved December 31, 2014, from IADC Drilling Lexicon: http://www.iadclexicon.org/hse-
management-objectives/
International Association of Drilling Contractors. (2014). IADC Incidents Statistics Program (ISP).
Retrieved December 16, 2014, from http://www.iadc.org/isp/
International Association of Drilling Contractors. (2014). MODU HSE Case. Retrieved December 31, 2014,
from IADC Drilling Lexicon.
International Association of Drilling Contractors. (2014, May 21). Well Control Committee Meeting.
Retrieved December 16, 2014, from http://www.iadc.org/wp-content/uploads/2014/09/21-
May-2014-Well-Control-Cmte.-Mtg.-Approved-Minutes.pdf
International Association of Drilling Contractors. (2015, February 27). IADC HSE Case Guidelines.
Retrieved December 16, 2014, from http://www.iadc.org/iadc-hse-case-guidelines/
International Association of Oil and Gas Producers. (2010, March). Regulators' Use of Standards.
Retrieved February 16, 2015, from http://www.ogp.org.uk/pubs/426.pdf
International Atomic Energy Agency. (2015, January 12). IRS - International Reporting System. Retrieved
January 12, 2015, from IAEA.org: http://www-ns.iaea.org/reviews/op-safety-
reviews.asp?s=2&l=15#irs
International Business Machines. (2014, December 15). IBM Maximo Asset Management solutions for
the oil and gas industry (Brochure-USEN). Retrieved December 15, 2014, from http://www-
01.ibm.com/common/ssi/cgi-
bin/ssialias?infotype=PM&subtype=BR&appname=SWGE_TI_EA_USEN&htmlfid=TIB14011USEN
&attachment=TIB14011USEN.PDF
International Business Machines. (2014, October 15). Maximo for Oil and Gas. Retrieved October 15,
2014, from http://www-03.ibm.com/software/products/en/maximo-for-oil-and-gas
International Business Machines. (2015, January 21). Maximo Spatial Asset Management. Retrieved
January 21, 2015, from http://www-03.ibm.com/software/products/en/maxispatassemana
International Business Machines. (n.d.). View Pricing and Buy. Retrieved December 15, 2015, from
https://www-
112.ibm.com/software/howtobuy/buyingtools/paexpress/Express?P0=E1&part_number=D0GZB
LL,D0GZFLL,D0GZHLL,D0GZLLL ,D0S8ZLL
International Organization for Standardization. (1997, June 15). ISO 14040. Retrieved January 28, 2015,
from Environmental Management - Life cycle assessment - Principles and framework:
http://web.stanford.edu/class/cee214/Readings/ISOLCA.pdf
International Organization for Standardization. (2000, March 15). ISO 14041. Retrieved January 30,
2015, from Environmental management—Life cycle assessment—Examples of application to
goal and scope definition and inventory analysis: http://www.pqm-
online.com/assets/files/standards/iso_tr_14049-2000.pdf
International Organization for Standardization. (2006, July 1). ISO 14044. Retrieved January 28, 2015,
from Environmental Management - Life cycle assessment - Requirements and Guidelines:
http://www.bae.uky.edu/montross/bae506/ISO%20EN%2014044-2006.pdf
International Organization For Standardization. (2007). Petroleum Petrochemical and Natural Gas
Industries - Collection and Exchange of Reliability and Maintenance Data for Equipment. Geneva:
International Organization For Standardization. Retrieved December 29, 2014
International Organization for Standardization. (2008). ISO 9001 - Quality Management Systems
Requirements. Geneva: International Organization For Standardization. Retrieved December 29,
2014
International Organization For Standardization. (2014, October 12). How Does ISO Develop Standards?
Retrieved October 12, 2014, from http://www.iso.org/:
http://www.iso.org/iso/home/standards_development.htm
International Organization for Standardization. (2014, Decemeber 30). ISO 14000 - Environmental
management. Retrieved December 30, 2014, from ISO Management System Standards:
http://www.iso.org/iso/iso14000
International Organization For Standardization. (2014, October 31). ISO 15926-2:2003 - Industrial
automation systems and integration -- Integration of life-cycle data for process plants including
oil and gas production facilities -- Part 2: Data model. Retrieved October 31, 2014, from
http://www.iso.org:
http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=29557
International Organization for Standardization. (2014, December 31). ISO 17776:2000. Retrieved
December 31, 2014, from http://www.iso.org/iso/catalogue_detail.htm?csnumber=31534
International Organization For Standardization. (2014, December 30). ISO 20815:2008 Petroleum,
petrochemical and natural gas industries -- Production assurance and reliability management.
International Organization For Standardization. (2014, December 31). ISO/TS 15926-7:2011 - Industrial
automation systems and integration -- Integration of life-cycle data for process plants including
oil and gas production facilities -- Part 7: Implementation methods for the integration of
distributed systems: Template met. Retrieved December 31, 2014, from www.iso.org:
http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=52455
International Organization for Standardization. (2014, December 31). Online Browing Platform (OBP) ISO
15663-3:2001(en) Petroleum and natural gas industries — Life-cycle costing — Part 3:
Implementation guidelines. Retrieved December 31, 2014, from www.iso.org:
https://www.iso.org/obp/ui/#iso:std:iso:15663:-3:ed-1:v1:en
International Organization for Standardization. (2014, December 31). Online Browsing Platform (OBP)
ISO 15663-1:2000(en) Petroleum and natural gas industries — Life cycle costing — Part 1:
Methodology. Retrieved December 31, 2014, from www.iso.org:
https://www.iso.org/obp/ui/#iso:std:28625:en
International Organization For Standardization. (2014, December 31). Online Browsing Platform (OBP)
ISO 15663-2:2001(en) Petroleum and natural gas industries — Life-cycle costing Part 2: Guidance
on appilication of methodology and calculation methods. Retrieved December 31, 2014, from
www.iso.org: https://www.iso.org/obp/ui/#iso:std:iso:15663:-2:ed-1:v1:en
International Organization For Standardization. (2014, December 30). Online Browsing Platform: ISO/TS
29001:2010 -Petroleum, petrochemical and natural gas industries -- Sector-specific quality
management systems -- Requirements for product and service supply organizations. Retrieved
December 30, 2014, from www.iso.org: https://www.iso.org/obp/ui/#iso:std:55499:en
International Organization For Standardization. (2014, December 31). Technology Moves On - What
about ISO Standards? Retrieved December 31, 2014, from www.iso.org:
http://www.iso.org/iso/home/faqs/faqs_standards.htm
International Organization for Standardization. (2015, February 27). ISO 14000 - Environmental
management. Retrieved December 30, 2014, from ISO Management System Standards:
http://www.iso.org/iso/iso14000
International Organization for Standardization. (2015, February 27). ISO 17776:2000. Retrieved
December 31, 2014, from http://www.iso.org/iso/catalogue_detail.htm?csnumber=31534
ISO. (2006, July 7). ISO Standards for Life Cycle Assessment. Retrieved September 25, 2014, from
http://www.iso.org/iso/home/news_index/news_archive/news.htm?refid=Ref1019
ISO. (2010). ISO 14040:2006Environmental Management -- Life Cycle Assessment -- Principles and
Framework. Retrieved September 24, 2014, from
http://www.iso.org/iso/catalogue_detail?csnumber=37456
ISO. (2014, September 30). About ISO. Retrieved September 30, 2014, from International Organization of
Standards: http://www.iso.org/iso/home/about.htm
John, S. (2014, December 16). American Bureau of Shipping Oil and Natural Gas Senior Engineer. (M.
Sculley, Interviewer) Retrieved 2014
John, S. (2014, December 16). American Bureau of Shipping Oil and Natural Gas Senior Engineer. (M.
Sculley, Interviewer)
Joy Global. (2014). About Us. Retrieved September 30, 2014, from http://www.joyglobal.com/Joy-
Global/About-Joy-Global.htm
Joy Mining. (2014, September 26). Joy's Life Cycle Management. Retrieved September 26, 2014, from
http://www.joy.com/JoyMining/PerspectivesMagazine/Perspectives_Vol11no1.pdf
Kusnetz, N. (2011, February 9). EPA Wants to Look at Full Lifecycle of Fracking in New Study. Propublica.
Retrieved September 30, 2014, from http://www.propublica.org/article/epa-wants-to-look-at-
full-lifecycle-of-fracking-in-new-study
Lawton, R. H. (1992, 9 March). Report of Undesirable Events. Retrieved from Bureau of Land
Management:
http://www.blm.gov/pgdata/etc/medialib/blm/mt/blm_programs/energy/oil_and_gas/operatio
ns/ntls.Par.47937.File.dat/ntl3mt.pdf
Lawton, R. H. (1992 Robert H. Lawton). Report of Undesirable Events. UNITED STATES DEPARTMENT OF
THE INTERIOR BUREAU OF LAND MANAGEMENT Montana State Office. Retrieved from
http://www.blm.gov/pgdata/etc/medialib/blm/mt/blm_programs/energy/oil_and_gas/operatio
ns/ntls.Par.47937.File.dat/ntl3mt.pdf
Liming, J. (2015, February 13). NRC Regulatory Q&A Call. (R. I. Brandon Lee, Interviewer) Retrieved 2015
Liming, J. (2015, February 13). The Nuclear Regulatory Commission's Oversight Landscape. (B. Lee,
Interviewer)
Massachusetts Department of Public Health. (2014, September 30). Department of Public Health. (M. D.
Health, Producer) Retrieved September 30, 2014, from Executive Office of Health and Human
Services: http://www.mass.gov/eohhs/gov/departments/dph
Mine Safety and Health Administration. (2014, September 24). Equipment Safety and Health Concerns.
Health Related Accidents. Retrieved September 24, 2014, from Mine Safety and Health
Administration: http://www.msha.gov/equipmentsafety/equipmentaccidents.asp
Mine Safety and Health Administration. (2014, September 29). Hazard Communication Final Rule Single
Source Page. Retrieved September 29, 2014, from Mine Safety and Health Administration:
http://www.msha.gov/hazcom/hazcom.htm
Minmier, J. (2014). Featured Remarks for the 2014 IADC Asset Integrity and Reliability Conference. IADC
Asset Integrity and Reliability Conference (p. n. pag.). Houston: IADC. Retrieved September 25,
2014, from http://www.iadc.org/wp-content/uploads/2014/08/IADC-2014-Chairman-Jay-
Minmier-Featured-address-for-IADC-Asset-Integrity-Reliability-Conference_Slides.pdf
National Energy Board. (2014, September 25). 2000-2013 Pipeline Incident Reporting. Retrieved
September 25, 2014, from http://www.neb-one.gc.ca/clf-
nsi/rsftyndthnvrnmnt/sfty/pplnncdntgrprtng/pplnncdts/pplnncdts-eng.html
National Energy Board. (2014, September 25). The NEB's Lifecycle Approach to Protecting the
Environment. Retrieved September 25, 2014, from http://www.neb-one.gc.ca/clf-
nsi/rsftyndthnvrnmnt/nvrnmnt/lfcclpprch/lfcclpprch-eng.html
National Energy Board. (2014, September 25). Who We Are & Our Governance. Retrieved September 25,
2014, from NEB-one.gc.ca: http://www.neb-one.gc.ca/clf-
nsi/rthnb/whwrndrgvrnnc/whwrndrgvrnnc-eng.html
National Highway Traffic Safety Administration. (2014, September 29). Fatality Analysis Reporting
System. (N. H. Administration, Producer) Retrieved September 29, 2014, from National Highway
Traffic Safety Administration: http://www.nhtsa.gov/FARS
National Highway Traffic Safety Administration. (2014, September 29). Trucks in Fatal Accidents and
Buses in Fatal Accidents. (N. H. Administration, Producer) Retrieved September 2014, 2014,
from National Highway Traffic Safety Administrsation: http://www.nhtsa.gov/FARS
National Highway Traffic Safety Administration. (2014, 29 September). Trucks in Fatal Accidents and
Buses in Fatal Accidents. (National HighwayTraffic Safety Administration) Retrieved September
29, 2014, from National Highway Traffic Safety Administration:
National Offshore Petroleum Safety Authority. (2008, May 27). FACILITY INTEGRITYTOPSIDES
MAINTENANCE SYSTEM ONSHORE INTERVIEWS. Retrieved September 26, 2014, from
www.nopsema.gov.au: http://www.nopsema.gov.au/assets/Forms/N-06100-FM0435-Prompt-
Sheet-Topsides-maintenance-system-onshore-interviews.pdf
National Transportation Safety Board. (2014, September 30). Accident Reporting. (N. T. Board, Producer)
Retrieved September 30, 2014, from National Transportation Safety Board:
http://www.ntsb.gov/investigations/reports.html
Naval Educational And Training Professional Development Center. (2013, May). Electronics Technicial
Supervisor. Pensacola, Florida: Naval Educational And Training Professional Development
Center. Retrieved February 17, 2015, from
http://navybmr.com/study%20material%203/NAVEDTRA%2014347.pdf
Netherlands Oil and Gas Exploration Production Association. (2014, September 30). Download
Guidelines. (N. O. Association, Producer) Retrieved September 30, 2014, from Netherlands Oil
and Gas Exploration Production Association: http://www.nogepa.nl/en-us/download-
guidelines/
New Zealand Audit Office. (2010, April 21). Asset management for public entities: Learning from local
government examples. Retrieved Septemeber 19, 2014, from auditnz.govt.nz:
http://www.auditnz.govt.nz/publications-resources/assurance/asset-management/asset-
management-for-public-entities/publications-resources/assetmanagement.pdf
New Zealand Government Parlimentary Council Office. (2013, June 5). Health and Safety in Employment
(Petroleum Exploration and Extraction) Regulations 2013. Retrieved November 24, 2014, from
www.legislation.govt.nz:
http://www.legislation.govt.nz/regulation/public/2013/0208/15.0/DLM5202524.html
New Zealand Legislation. (2013, May 20). Health and Safety in Employment . Wellington , New Zealand.
Retrieved September 30, 2014, from
file:///C:/Users/AnDe/Downloads/Health%20and%20Safety%20in%20Employment%20Petroleu
m%20Exploration%20and%20Extraction%20Regulations%202013%20(1).pdf
New Zealand Legislation. (2013, May 20). Health and Safety in Employment (Petroleum Exploration and
Extraction) Regulations 2013. Retrieved December 31, 2014, from
http://legislation.govt.nz/regulation/public/2013/0208/latest/whole.html#DLM5202524
Nine Key Considerations When Selecting a Pavement Management System. (n.d.). Retrieved 4 29, 2015,
from http://www.agileassets.com/9-key-considerations-when-selecting-a-pavement-
management-system/
NL Olie- en Gasportaal. (2014, September 30). Welcome. Retrieved September 30, 2014, from
http://www.nlog.nl/
NOGEPA. (2014). Download Guidelines. Retrieved September 30, 2014, from http://www.nogepa.nl/en-
us/download-guidelines/
NOLAND v. ENERGY RESOURCES TECHNOLOGY, INC., Civil Action No. 3:12-CV-00330. (United States
District Court, S.D. Texas, Galveston Division. January 16, 2013).
NOPSEMA. (2014, January 1). nopsema-jurisdiction. Retrieved September 26, 2014, from
www.nopsema.gov.au: http://www.nopsema.gov.au/about/nopsema-jurisdiction/
Nuclear Regulatory Commission. (2000, October). Event Reporting Guidelines 10 CFR 50.72 and 50.73.
Retrieved February 6, 2015, from http://www.nrc.gov/reading-rm/doc-
collections/nuregs/staff/sr1022/r2/sr1022r2.html
Nuclear Regulatory Commission. (2000, December). NRC Form 361. Retrieved February 11, 2015, from
Reactor Plant Notification Worksheet: http://www.nrc.gov/reading-rm/doc-
collections/forms/nrc361.pdf
Nuclear Regulatory Commission. (2007, September). Common-Cause Failure Database and Analysis
System: Event Data Collection, Classification, and Coding. Retrieved February 2015, from
NUREG/CR-6268, Rev. 1: http://pbadupws.nrc.gov/docs/ML0729/ML072970404.pdf
Nuclear Regulatory Commission. (2010, September 30). Fire Event Data from Licensee Event Reports.
Retrieved February 6, 2015, from http://catalog.data.gov/dataset/fire-event-data-from-
licensee-event-reports
Nuclear Regulatory Commission. (2011, March 4). Easy Searching for Licensee Event Reports. Retrieved
February 6, 2015, from http://public-blog.nrc-gateway.gov/2011/03/04/easy-searching-for-
licensee-event-reports/
Nuclear Regulatory Commission. (2013, September 23). Common Cause Failure Database. Retrieved
February 6, 2015, from http://nrcoe.inel.gov/resultsdb/CCFDB/
Nuclear Regulatory Commission. (2014, July 10). 10 CFR 50.72. Retrieved February 6, 2015, from
Immediate notification requirements for operating nuclear power reactors:
http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-0072.html
Nuclear Regulatory Commission. (2014, July 10). 10 CFR 50.73. Retrieved February 6, 2015, from
Licensee event report system: http://www.nrc.gov/reading-rm/doc-
collections/cfr/part050/part050-0073.html
Nuclear Regulatory Commission. (2014, September 26). About Emergency Response. Retrieved February
9, 2015, from http://www.nrc.gov/about-nrc/emerg-preparedness/respond-to-emergency.html
Nuclear Regulatory Commission. (2014, February ). NRC Form 366. Retrieved February 6, 2015, from
Licensee Event Report (LER) : http://www.nrc.gov/reading-rm/doc-
collections/forms/nrc366info.html
Nuclear Regulatory Commission. (2015, February 25). Common-Cause Failure Database and Analysis
Software and Reliability and Availability Data System. Retrieved February 6, 2015, from
https://nrcoe.inel.gov/secure/ccfdb/index.cfm
Nuclear Regulatory Commission. (2015, February 11). Licensee Event Report Search (LERSearch) .
Retrieved February 6, 2015, from https://lersearch.inl.gov/Entry.aspx
Nuclear Regulatory Commission. (2015, January 28). NRC Regulations: Title 10 Code of Federal
Regulations. NRC Regulations. Washington, District of Colombia, USA. Retrieved Februrary 17,
2015, from http://www.nrc.gov/reading-rm/doc-collections/cfr/
Nuclear Regulatory Commission. (May, 2014 15). List of Power Reactor Units. Retrieved February 11,
2015, from http://www.nrc.gov/reactors/operating/list-power-reactor-units.html
Occupational Health and Safety Administration. (2009, May 20). Oil and Gas Well Drilling and Servicing
eTool. Retrieved September 24, 2014, from www.osha.gov:
https://www.osha.gov/SLTC/etools/oilandgas/index.html
Occupational Health and Safety Management (U.K.). (2014, Decemeber 31). BS OHSAS 18001
Occupational Health and Safety Management. Retrieved December 31, 2014, from British
Standards Institute: http://www.bsigroup.com/en-GB/ohsas-18001-occupational-health-and-
safety/
Occupational Safety and Health Administration. (2014, September 20). About OSHA. Retrieved
September 20, 2014, from OSHA: https://www.osha.gov/about.html
Occupational Safety and Health Administration. (n.d.). Establishment Search. (O. S. Administration,
Producer) Retrieved September 29, 2014, from Occupational Safety and Health Adminstration:
https://www.osha.gov/pls/odi/establishment_search.html
Office of the Auditor-General New Zealand. (2014, September 23). Part 5: Life cycle costing analysis -
Office of the Auditor-General New Zealand:. Retrieved September 19, 2014, from
www.oag.govt.nz: http://www.oag.govt/nz/2004/lav/part5.htm
Oil and Gas UK. (2010, January 1). HS022 - Asset Integrity Toolkit (2006). (Oxford Web Applications)
Retrieved December 1, 2014, from
http://www.oilandgasuk.co.uk/publications/viewpub.cfm?frmPubID=225:
http://www.oilandgasuk.co.uk/AssetIntegrity.cfm
Oil and Gas UK. (2013, January 23). Supply Chain Code of Practice. Retrieved December 1, 2014, from
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/68823/2819-
pilot-supply-chain-code-of-practice-sccop.pdf: https://www.gov.uk/government/groups/105
Oil and Gas UK LOGIC. (2014, January 1). Governance for Standard Industry Solutions IMHH. Retrieved
December 2, 2014, from http://www.logic-oil.com/imhh: http://www.logic-oil.com/master-
deed
Petroleum Safety Authority. (2010). Trends in Risk Level in Petroleum Activity. Retrieved February 16,
2015, from
http://www.ptil.no/getfile.php/PDF/RNNP%202010/Summary_Report_2010_rev1a1.pdf
Petroleum Safety Authority. (2014, September 24). About Us. Retrieved September 24, 2014, from
Petroleum Safety Authority: http://www.psa.no/about-us/category877.html
Petroleum Safety Authority. (2014). Framework HSE. Retrieved September 30, 2014, from
http://www.psa.no/framework-hse/category403.html
Petroleum Safety Authority. (2014, December 16). Guidelines Regarding the Management Regulations.
Retrieved February 16, 2015, from
http://www.psa.no/management/category406.html#_Toc377973133
Petroleum Safety Authority. (2014, September 24). Management. Retrieved September 24, 2014, from
Petroleum Safety Authority: http://www.psa.no/management/category406.html#p20
Petroleum Safety Authority. (2014, September 24). Regulations. Retrieved September 24, 2014, from
Petroleum Safety Authority: http://www.psa.no/regulations/category216.html
Petroleum Safety Authority. (2014, December 16). Regulations Relating to Management and the Duty to
Provide Information in the Petroleum Activities and at Certain Oshore Facilities. Retrieved
February 16, 2015, from http://www.psa.no/management/category401.html
Petroleum Safety Authority. (2015). The Regulatory Forum. Retrieved April 20, 2015, from The
Regulatory Forum brings together companies, unions and government in a “tripartite”
collaboration on health, safety and the environment (HSE) in the petroleum sector.:
http://www.psa.no/regulations/regulatory-forum-article9524-216.html
Petroleum Safety Authority. (n.d.). Confirming the notification/report of hazards and accidents (offshore
and on land). Retrieved February 18, 2015, from http://www.psa.no/report-about-situation-of-
hazard-and-accident/category935.html
PHMSA. (2015, February 26). Pipeline and Hazardous Materials Safety Administration. Retrieved from
Integrity Management Program (IMP): http://primis.phmsa.dot.gov/gasimp/
Prevention, C. f. (2014, April 14). Mission, Role and Pledge. Retrieved from Centers for Disease Control
and Prevention: http://www.cdc.gov/about/organization/mission.htm
Reidel, J. (2014, October 8). New Study Examines Role of Government in Deepwater Horizon Oil Spill.
Retrieved December 7, 2014, from Doctoral Programs in Educational Leadership and Policy
Studies:
http://www.uvm.edu/~cess/doctoral/?Page=news&storyID=19337&category=ucommall
Reliability Analysis Center (RAC). (2008, November 26). FRACAS Section 1: The Generic FRACAS
(Abbreviated Section) . FRACAS Section 1: The Generic FRACAS (Abbreviated Section) . Rome,,
New York, United States. Retrieved February 10, 2015, from
https://src.alionscience.com/pdf/RAC-1ST/FRACAS_1ST.pdf:
https://src.alionscience.com/pdf/RAC-1ST/FRACAS_1ST.pdf
(2006). Reliability Centered Maintenance (RCM) Process Guide, CGTO PG-85-00-30 . Washington D.C. :
U.S. Coast Guard .
ReliaSoft. (2014). Reliability, Software, Training and Services. Retrieved September 30, 2014, from
http://www.reliasoft.com/corporate/index.htm
ReliaSoft. (2015, January 25). XFRACAS System Features. Retrieved December 15, 2014, from
http://www.reliasoft.com/xfracas/features1.htm
Rigzone. (2008, April 17). PSA Norway Issues Report On Life Extension For Aging Facilities. Retrieved
January 6, 2015, from http://www.rigzone.com/news/article.asp?a_id=60477&rss=true
Roger R. Hill, J. A., & Dr. Allan S. Benjamin and James Linsday, A. C. (2008). Wind Turbine Reliability: A
Database and Analysis Approach. Albquerque: Sandia National Laboratories. Retrieved January
23, 2015, from http://prod.sandia.gov/techlib/access-control.cgi/2008/080983.pdf
Safety Status and Signals. (2012, February 14). The Regulatory Forum. Retrieved April 20, 2015, from A
purposeful commitment turned employer-employee relations in Norway’s petroleum industry
from conflict to cooperation. But all sides must accept a responsibility if this success is to
continue.: http://www.psa.no/news/understanding-roles-article8330-878.html
Schnoll, L. (2001, 11). Corrective and Preventive Action In Medical Device Manufacturing. Retrieved 4 28,
2015, from http://asq.org/quality-progress/2001/11/standards-outlook/corrective-and-
preventive-action-in-medical-device-manufacturing.html
SME, S. O. (2014, December 8). Interview with senior Oil And Natural Gas Subject Matter Expert. (J. C.
Hendrickson, Interviewer)
Smith, E. (2013, October 31). BSEE Regulatory Developments. Retrieved December 7, 2014, from
https://www.haynesboone.com/files/Uploads/Documents/OFSR-BSEE-10-31-2013.pdf
State of California. (2010, January 1). Project Life Cycle Framework. Retrieved September 29, 2014, from
www.bestpractices.osi.ca.gov:
http://www.bestpractices.osi.ca.gov/sysacq/projectlifecycle.shtml
State of California. (2014, January 1). California Laws for Conservation of Petroleum and Gas.
PUBLICATION NO. PRC01. Sacramento, California, United States. Retrieved September 29, 2014,
from ftp://ftp.consrv.ca.gov/pub/oil/laws/PRC01.pdf
Susan Olenchuk, J. C. (2012). The Potential Impact of New Pipeline Safety Laws on PHMSA's Regulatory
Initiatives. Pipeline and Gas Journal, 239(4). Retrieved January 27, 2015, from
http://www.vnf.com/693
Swinney, J. S. (2010). Enterprise Resource Management System Implementation - A Sewer District Case
Study. Proceedings Of the Water Environment Federation (pp. 5233-5236). Alexandria, VA:
Water Environment Federation. Retrieved December 19, 2014
The Marine Board of the National Research Council. (1984). Safety Information and Management on the
Outer Continental Shelf. Washington, D.C.: National Academy Press.
The National Archives. (2014). The Offshore Installations and Wells (Design and Construction, etc.)
Regulations 1996. Retrieved September 23, 2014, from legislation.gov.uk:
http://www.legislation.gov.uk/uksi/1996/913/contents/made
The Times-Picayune. (2013, March 26). Oil platform owner sued over Nov. 16 explosion. Retrieved
December 7, 2014, from www.nola.com:
http://www.nola.com/business/index.ssf/2013/03/oil_platform_owner_sued_over_n.html
The U.K. Oil and Gas Industry Association. (2010, January 1). Oil and Gas UK, About Us, Subsidiaries.
(Oxford Web Applications) Retrieved December 1, 2014, from
http://www.oilandgasuk.co.uk/aboutus/subsidiaries.cfm:
http://www.oilandgasuk.co.uk/publications/viewpub.cfm?frmPubID=252
The UK Oil and Gas Industry Association. (2010, January 1). Oil and Gas UK, About Us. (Oxford Web
Applications) Retrieved December 1, 2014, from
The UK Oil and Gas Industry Association. (2010, January 1). Oil and Gas UK, About Us, Subsidiaries.
(Oxford Web Applications) Retrieved December 1, 2014, from
http://www.oilandgasuk.co.uk/aboutus/subsidiaries.cfm:
http://www.oilandgasuk.co.uk/publications/viewpub.cfm?frmPubID=252
Toevs, G. R., MacKinnon, W. C., & Bobo, M. R. (2011, August). Assessment, Inventory, and Monitoring
Strategy: For integrated renewable resources management. Washington, D.C.: U.S. Department
of Interior Bureau of Land Management. Retrieved September 29, 2014, from
http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/polic
y/ib_attachments/2012.Par.53766.File.dat/IB2012-080_att1.pdf
Towing Vessel Inspection Bureau. (2014). TVIB-RCP Audit Flow Chart. Retrieved from TVIB:
http://www.thetvib.org/awo-responsible-carrier-program/tvib-rcp-audit-documents/
Transportation Research Board. (2003). Safety Management Systems: A Synthesis of Highway Practice.
Retrieved January 1, 2015, from
https://books.google.com/books?id=ryLyQk_b7A0C&source=gbs_navlinks_s
Transportation Research Board. (2003). Safety Management Systems: A Synthesis of Highway Practice.
Retrieved from https://books.google.com/books?id=ryLyQk_b7A0C&source=gbs_navlinks_s
Transportation Research Board. (2003). Safety Management Systems: A Synthesis of Highway Practice.
Retrieved from
https://books.google.com/books?id=ryLyQk_b7A0C&printsec=frontcover&source=gbs_ge_sum
mary_r&cad=0#v=onepage&q&f=false
Transportation Research Board of the National Acadamies. (2009). Hazardous Materials Transportation
Incident Data for Root Cause Analysis. Colombus, OH: BATTELLE MEMORIAL INSTITUTE.
TREASURY, N. S. (2012, August 20). www.treasury.nsw.gov.au. Retrieved September 18, 2014, from
www.treasury.nsw.gov.au: http://www.treasury.nsw.gov.au/ data/assets/pdf
file/0005/5099/life cycle costings.pdf
U.K. Government. (2014, December 2). PILOT. Retrieved December 2, 2014, from
https://www.gov.uk/government/groups/105: https://www.gov.uk/government/groups/105
U.K. Health and Safety Executive. (2003). RR076 - Machinery and rotating equipment integrity inspection
guidance notes. Retrieved January 2, 2015, from
http://www.hse.gov.uk/research/rrhtm/rr076.htm
U.K. Health and Safety Executive. (2004). RR253 - Piping Systems Integrity: Management review.
Retrieved January 2, 2015, from http://www.hse.gov.uk/research/rrhtm/rr253.htm
U.K. Health and Safety Executive. (2006). RR509 - Plant ageing: Management of equipment containing
hazardous fluids or pressure. Retrieved January 2, 2015, from
http://www.hse.gov.uk/research/rrhtm/rr509.htm
U.K. Health and Safety Executive. (2006). RR509 - Plant ageing: Management of equipment containing
hazardous fluids or pressure. Retrieved January 2, 2015, from
http://www.hse.gov.uk/research/rrhtm/rr509.htm
U.K. Health and Safety Executive. (2012, September). KP4 Technical Policies. Retrieved January 2, 2015,
from http://www.hse.gov.uk/offshore/ageing/kp4-technical-policy.pdf
U.K. Health and Safety Executive. (2014, October). Background Quality Report: Injury statistics as
reported under RIDDOR. Retrieved January 8, 2015, from
http://www.hse.gov.uk/statistics/pdf/riddor-background-quality-report.pdf
U.K. Health and Safety Executive. (2014, May). Key Programme 4 (KP4) Ageing and life extension
programme. Retrieved December 31, 2014, from http://www.hse.gov.uk/offshore/ageing/kp4-
report.pdf
U.K. Health and Safety Executive. (2014, January 1). Managing Ageing Plant: A Summary Guide.
Retrieved January 2, 2015, from http://www.hse.gov.uk/offshore/ageing/ageing-plant-
summary-guide.pdf
U.S Department of Transportation - Pipeline and Hazardous Materials Safety Administration. (2015,
January 28). Gas Transmission Integrity Management: Fact Sheet. Retrieved January 28, 2015,
from http://primis.phmsa.dot.gov/: http://primis.phmsa.dot.gov/gasimp/fact.htm
U.S. Coast Guard. (2014, October 31). Equipment Approval Information. Retrieved from Lifesaving and
Fire Safety Division: http://www.uscg.mil/hq/cg5/cg5214/eqpt_approval.asp
U.S. Department of Defense. (2014, September 29). About the Department of Defense. (U. D. Defense,
Producer) Retrieved September 29, 2014, from U.S. Department of Defense:
http://www.defense.gov/about/#mission
U.S. Department of Energy. (2014, September 29). Mission. Retrieved September 29, 2014, from U.S.
Department of Energy: http://www.energy.gov/mission
U.S. Department of Transportation - Hazardous Materials and Safety Administration. (2015, January 28).
DIMP Introduction. Washington, District of Colombia, United States. Retrieved January 28, 2015,
from http://www.phmsa.dot.gov/staticfiles/PHMSA/flash/chapter1.html
U.S. Department of Transportation - Hazardous Materials and Safety Administration. (2015, January 28).
Hazardous Liquid Integrity Management: Fact Sheet. Retrieved January 28, 2015, from
http://primis.phmsa.dot.gov: http://primis.phmsa.dot.gov/iim/fact.htm
U.S. Department of Transportation - Hazardous Materials and Safety Administration. (2015, January 27).
Instructions for Completing the Hazardous Materials Incident Report − Department of
Transportation Form F 5800.1. Retrieved January 27, 2015, from
https://hazmatonline.phmsa.dot.gov/:
https://hazmatonline.phmsa.dot.gov/incident/Details0.htm
U.S. Department of Transportation - Pipeline and Hazardous Materials Safety Administration. (2014, July
23). U.S. DOT Announces Comprehensive Proposed Rulemaking for the Safe Transportation of
Crude Oil, Flammable Materials. Retrieved January 29, 2015, from http://www.dot.gov/briefing-
room/: http://www.dot.gov/briefing-room/us-dot-announces-comprehensive-proposed-
rulemaking-safe-transportation-crude-oil
U.S. Department of Transportation - Pipeline and Hazardous Materials Safety Administration. (2015,
January 20). FAQs. Retrieved January 20, 2015, from PHMSA and Pipelines FAQs - What is
Integrity Management of Pipelines:
http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.6f23687cf7b00b0f22e4c6962d9c878
9/?vgnextoid=ea758c3936f40110VgnVCM100000762c7798RCRD&vgnextchannel=f7280665b91
ac010VgnVCM1000008049a8c0RCRD
U.S. Department of Transportation - Pipeline and Hazardous Materials Safety Administration. (2015,
January 28). Gas Distribution Integrity Management Program. Retrieved January 28, 2015, from
http://primis.phmsa.dot.gov/: http://primis.phmsa.dot.gov/dimp/index.htm
U.S. Department of Transportation - Pipeline and Hazardous Materials Safety Administration. (2015,
January 20). Mechanical Fitting Failure Data from Gas Distribution Operators. Retrieved January
20, 2015, from phmsa.dot.gov:
http://phmsa.dot.gov/portal/site/PHMSA/menuitem.6f23687cf7b00b0f22e4c6962d9c8789/?vg
nextoid=06cc95f181584410VgnVCM100000d2c97898RCRD&vgnextchannel=3430fb649a2dc110
VgnVCM1000009ed07898RCRD&vgnextfmt=print
U.S. Department of Transportation - Pipeline and Hazardous Materials Safety Administration. (2015).
Operation Safe Delivery Update. U.S. Department of Transportation - Pipeline and Hazardous
Materials Safety Administration.
U.S. Department of Transportation - Pipeline Safety and Hazardous Materials Safety Administration.
(2015, January 30). Mission and Goals. Retrieved January 30, 2015, from
http://www.phmsa.dot.gov: http://www.phmsa.dot.gov/about/mission
U.S. Department of Transportation Maritime Administration. (2014, September 29). About Us.
(Maratime Administration) Retrieved September 29, 2014, from Maritime Administration:
http://www.marad.dot.gov/about_us_landing_page/about_us_landing_page.htm
U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration. (2014, April
7). PHMSA's Proposed Pipeline Penalties Hit All-Time High; Serious Pipeline Incident Count Hits
All-Time Low. Retrieved January 5, 2015, from http://www.phmsa.dot.gov/:
http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.6f23687cf7b00b0f22e4c6962d9c878
9/?vgnextoid=9c7c87c1a3e25410VgnVCM100000d2c97898RCRD&vgnextchannel=d248724dd7d
6c010VgnVCM10000080e8a8c0RCRD&vgnextfmt=print
U.S. Department of Transportations Pipeline and Hazardous Materials Safety Administration. (2015,
February 5). Data and Statistics. Retrieved February 5, 2015, from http://phmsa.dot.gov/:
http://phmsa.dot.gov/resources/data-stats
U.S. Food and Drug Administration. (2014, September 17). MedWatch: The FDA Information and Adverse
Event Reporting Program. Retrieved from U.S. Food and Drug Administration:
http://www.fda.gov/Safety/MedWatch/default.htm
U.S. Food and Drug Administration. (2014, August 5). What we do. Retrieved from U.S. Food and Drug
Administration: http://www.fda.gov/AboutFDA/WhatWeDo/default.htm
UK Health and Safety Executive. (2014, October). Health and Safety Statistics 2013/2014: Annual Report
for Great Britain. Retrieved January 8, 2015, from
http://www.hse.gov.uk/statistics/overall/hssh1314.pdf
UK Health and Safety Executive. (2014). Managing Ageing Plant: A Summary Guide. Retrieved January 2,
2015, from http://www.hse.gov.uk/offshore/ageing/ageing-plant-summary-guide.pdf
UK Health and Safety Executive. (2014, January 1). Types of reportable incidents. Retrieved January 5,
2015, from http://www.hse.gov.uk/riddor/reportable-incidents.htm
UK Health and Safety Executive. (2014). Types of reportable incidents. Retrieved January 5, 2015, from
http://www.hse.gov.uk/riddor/reportable-incidents.htm
UK Health and Safety Executive. (n.d.). How to Make a RIDDOR report. Retrieved January 8, 2015, from
http://www.hse.gov.uk/riddor/report.htm
United States Coast Guard. (2006). RELIABILITY-CENTERED MAINTENANCE PROCESS GUIDE CGTO PG-85-
00-30. Elizabeth City: U.S. Department of HOmeland Security. Retrieved from
http://cglog2.net/Attach%5CCGTO%20PG-85-00-30%20RE~3504~.pdf
United States Coast Guard. (2012). Improvements to Reduce Human Error and Near Miss Incidents.
Homeland Security.
United States Coast Guard. (2012, March 23). Letter to the IADC. Retrieved December 17, 2014, from
http://www.iadc.org/wp-content/uploads/20120323-USCG-D8dp-response-to-MSIB-Ltr.pdf
United States Coast Guard. (2013, August 15). Casualty Reporting (CASREP) Tactics, Techniques, and
Procedures (TTP). Washington, Distric of Columbia, United States: United State Coast Guard.
Retrieved September 30, 2014, from http://www.uscg.mil/forcecom/ttp/pubs/CGTTP_6-
01_3_CASREP.pdf
United States Coast Guard. (2014, November 25). Reporting Marine Casualties. Retrieved Feburary 17,
2015, from http://www.uscg.mil/: http://www.uscg.mil/acteur/reporting.asp
United States Coast Guard. (n.d.). Coast Guard Reporting in the Artic and in Western Alaska (west of
148*26). Retrieved Feburary 17, 2015, from
http://www.uscg.mil/d17/sectoranchorage/docs/reporting.pdf
United States Department of Defence. (1995, December 11). DEPARTMENT OF DEFENSE HANDBOOK,
FAILURE REPORTING, ANALYSIS AND CORRECTIVE ACTION TAKEN. FAILURE REPORTING,
ANALYSIS AND CORRECTIVE ACTION TAKEN, Mil-SId-2 155(AS). Washington, District of Columbia,
United States: Department of Defence. Retrieved February 9, 2015, from
http://everyspec.com/MIL-HDBK/MIL-HDBK-2000-2999/MIL-HDBK-2155_21714/
United States Department of Health and Human Services. (2012, July 18). Enterprise Performance Life
Cycle Performance Framework. Retrieved from Centers for Disease Control and Prevention:
http://www2a.cdc.gov/cdcup/library/hhs_eplc/EPLC_Framework_09-18-12.pdf
United States Environemental Protection Agency. (2014, July 31). Report Environmental Violations. (U. S.
Agency, Producer) Retrieved September 29, 2014, from United States Environmental Protection
Agency: http://www2.epa.gov/enforcement/report-environmental-violations
United States Environmental Protection Agency. (2014, September 30). US Environmental Protection
Agency. (U. E. Agency, Producer) Retrieved September 30, 2014, from United States
Environmental Protection Agency: http://epa.gov/
United States Nuclear Regulatory Committee. (2014, September 8). Licensee Event Report Search.
(United States Nuclear Regulatory Committee) Retrieved September 30, 2014, from United
States Nuclear Regulatory Committee: https://lersearch.inl.gov/Entry.aspx
USDA.gov. (2014, April 15). Mission Statement | USDA. Retrieved September 23, 2014, from United
States Department of Agriculture :
http://www.usda/gov/wps/portal/usda/usdahome?navid=MISSION_STATEMENT
Venkatramam, V. (2015, January 22). Genesis Solitions Marketing and Sales Senior Director. (J.
Hendrickson, Interviewer)
Vivastream. (2014, September 26). Transportation MUG: How Amtrak Is Utilizing Maximo Mobile across
the Asset Lifecyle to Ensure Accuracy, Safety and Compliance. Retrieved September 26, 2014,
from https://www.vivastream.com/events/pulse2013/sessions/2048
Weibull. (2011, April). Reliability Basics. Retrieved January 12, 2015, from Weibull.com:
http://www.weibull.com/hotwire/issue122/relbasics122.htm
Wintle, J., & Sharp, J. (2008, January). Requirements for Life Extension of Ageing Offshore Production
Installations. Retrieved January 6, 2015, from
http://www.ptil.no/getfile.php/PDF/Requirements%20for%20Life%20Extension%20of%20Agein
g%20Offshore%20Production%20Installations.pdf
Wintle, J., Kenzie, B., Amphlett, G., & Smalley, S. (2008, January 6). Best practice for risk based inspection
as a part of plant integrity management. Retrieved January 6, 2015, from
http://www.hse.gov.uk/research/crr_pdf/2001/crr01363.pdf
Wintle, J., Kenzie, B., Amphlett, G., & Smalley, S. (2008). Best practice for risk based inspection as a part
of plant integrity management. Retrieved January 6, 2015, from
http://www.hse.gov.uk/research/crr_pdf/2001/crr01363.pdf