Transcript TJAG MasterSlides - Tulane University Law School

Executing the Mission
Delivering Legal Services
Tulane Admiralty Law Institute
March 11 – 13, 2015
New Orleans, Louisiana
Executing the Mission
Delivering Legal Services
Government Regulations & Class Society
Rules Post-Deepwater Horizon
RADM Steven D. Poulin
Judge Advocate General
U.S. Coast Guard
Executing the Mission
Delivering Legal Services
Background
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Joint Investigation Team Report of Investigation
on MODU Deepwater Horizon
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Volume I: U.S. Coast Guard Final
Action Memo (FAM)
Volume II: BOEMRE (now-BSEE)
OCS Area Matrix Team (OCSAMT)
Chartered May 2011
 Multi-unit, multidisciplinary team
 Identify needs in standards, regulations,
policies, and proficiencies
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OCSAMT Target Areas
Standards
•Regulations
•Policies
•Voluntary Guidelines
Outreach
•Active engagement with
industry associations and
partnerships
•Close coordination with
BSEE and NOSAC
Competency
•Enhanced Training
Programs
•Updated Personal
Qualification Standards
Oversight
•OCS OCMI
•Increased Resources
•Risk-Based Targeting
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Standards: Regulatory Projects
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Regulatory Projects (continued)
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Standards: Policies & Guidance
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Accommodation Service Provided on Vessels Engaged in OCS
Activities
 Feb 2012, 77 FR 5039
Dynamic Positioning (DP) Operations Guidance for nonMODUs on OCS
 Oct 2012, 77 FR 62247
Lifesaving & Firefighting Equipment and Drills for Offshore
Facilities & MODUs
 Nov 2012, 77 FR 70172
MODU DP Guidance
 May 2012, 77 FR 26562
MODU Electrical Equipment Certification
 Dec 2012, 77 FR 71607
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Standards: Recent Policies & Alerts
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Voluntary Reporting of DP Incidents Guidance
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Alternate Design & Equipment Standards for FOIs and
FPSO Units Guidance
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Jun 2013, CG-ENG Policy
Outer Continental Shelf Units—Fire and Explosion
Analyses
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Jun 2013, CG-INV Policy
May 2014, 79 FR 25139
Marine Safety Manual, Vol. II: OCS Section updated
Marine Safety Alert: DP System Failures
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Feb 2015
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Standards: International Efforts
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Recognized Organizations Code (RO Code)
Amendments to the Guidelines for vessels with dynamic
positioning (DP) systems
Proposed amendments to the 2009 MODU Code and related
instruments in light of the investigation reports of the 2010
DEEPWATER HORIZON incident
Review of the adequacy of the 2009 MODU Code, the LifeSaving Appliance (LSA) Code, and Measures to prevent
accidents with lifeboats in light of the investigations of the
2010 "Deepwater Horizon" incident
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Competencies on Prevention
Enhanced Personnel Qualification Standards
 OSV PQS
 Foreign MODU PQS
 OCS Inspector Course
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Intensive focus on core qualifications, including
instruction on drilling, well control, DP and cranes
 Review CG authorities, applicable regulations,
deficiency documentation, and issuance of certificates
 Future course: July 2015
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Competencies for
Pollution Response
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Instituted formal USCG training for Federal On
Scene Coordinator-Representatives (FOSC-R)
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Created a deployable Incident Management
Assistance Team (IMAT)
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Emphasis on smaller spills and building strong
baseline knowledge
Highly-specialized USCG personnel to provide ICS
support
Established permanent Regional Response
Team (RRT) Co-chairs
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Outreach on Prevention
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Bureau of Safety and Environmental Enforcement
(BSEE)
USCG-BSEE Prevention Working Group
 Updated USCG-BSEE Memorandum of Understanding
(MOU), signed 27 November 2012
 Also updating eight existing MOUs, and developing new
MOUs
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Industry Partners
Presence at Offshore Technology Conference (OTC)
 Active engagement with advisory committees (NOSAC)
 Partnerships to improve training
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Outreach on Response
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Interagency Coordinating Committee on Oil
Pollution Research (ICCOPR)
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Spill of National Significance/National Incident
Commander policy
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Focus on pollution response research and
development
Policy includes fortification through interagency
partnerships
USCG Incident Specific Preparedness Review
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Oversight
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OCS OCMI
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“One Shelf, One Standard”
Resource Proposals
Increased funding for regulatory and policy
development
 Increased funding to enhance inspections
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Risk-based oversight program for MODUs
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Policy Letter 11-06, Jul 2011, 76 FR 39885
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Area Contingency Plan Revisions
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Result of lessons learned with dispersants
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Endangered Species Act (ESA) national-level
workgroup on approaches to ACP consultation
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Future policy development on ESA Section 7 and other
laws
Central clearing house for Biological Assessment
inputs and examples
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Questions?
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