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Risk Assessment for

Life Cycle Management and

Failure Reporting Systems

Task 1 Report

Submitted to

The Bureau of Safety and Environmental Enforcement

(BSEE)

Submitted by

ABSG CONSULTING INC.

1525 Wilson Blvd., Suite 625

Arlington, VA 22209

(703) 351-3700

BPA Contract # E13PA00008


Task Order # E14PS00045
30 September 2014
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BSEE LCM and Failure Reporting Task 1 Draft Report i | Page


Executive Summary
The American Bureau of Shipping (ABS) Consulting prepared this report for the Bureau of Safety and
Environmental Enforcement (BSEE) to provide support in development of a risk management system.
The goal of the report is to enhance efficiency, effectiveness, and risk reductions in the regulated Oil &
Gas industry.

First, the report identified and reviewed potential agencies and companies, domestically and
internationally, that may have a Life Cycle Management system (LCM) or a Failure Reporting System
(FRS). ABS Consulting identified over fifty agencies and over eighty associated LCM or FRS programs.

ABS Consulting ranked each agency based on relevancy and applicability to BSEE.

Based on the review of each agency’s program, the ABS Consulting review team ranked each agency on
relevance and applicability to BSEE. ABS Consulting scored each of the fifty-three agencies for use in
Tasks 2 and 3, but did not rank the eighty-six programs. Each agency was reviewed and scored by the
review team. Based on the averaged score from each member of the review team, we recommend that
for Tasks 2 and 3, we analyze those agencies with a ranked score of 13 or higher. This includes two
domestic federal agencies, one domestic state agency, five international agencies, and two industry
associations. These nine agencies/ organizations represent twenty-two different programs: two
programs contain both LCM and FRS elements, thirteen LCM, and seven FRS programs.

LCM
Agency/Organization Acronym Program or FRS
Domestic: Federal
14.0 Department of Homeland Security DHS
U.S. Coast Guard USCG
Casualty Reporting (CASREP) System FRS
Notice of Marine Casualty FRS
Pollution Incident Reporting FRS
13.3 Environmental Protection Agency EPA
Plan to Assess Fracking LCM
Pollution Incident Reporting FRS
Domestic: State
14.3 California State Lands Commission CSLC
Accident Investigation and Reports FRS
International
14.0 Australia AU

National Offshore
Petroleum Safety and
Environmental Management
Authority NOPSEMA
Safety Case Life Cycle Management LCM
Asset Registry LCM
14.0 Canada CA

BSEE LCM and Failure Reporting Task 1 Draft Report ii | Page


LCM
Agency/Organization Acronym Program or FRS
National Energy Board NEB
14.0 Norway NO
Petroleum Safety Authority PSA
Individual Facility-Customized LCM Systems LCM
Registration, Review and Investigation of Hazard and Accident Situations FRS
13.3 New Zealand NZ
Department of Labour NZ DOL
Facility Safety Case - Safety Management System (SMS) FRS
Industry
14.7 American Petroleum Institute API
API RP 2D LCM
API RP 2FB LCM
API RP 75 LCM
API Q1 Both
API Q2 LCM
API Q3 Both
API 2C LCM
Life Cycle Management Plan (LMP) LCM
Strategic Approach to International Chemicals Management (SAICM) LCM
Reporting Process Safety Events FRS

13.7 International Organizations for


Standardization ISO

Life Cycle Assessment (LCA) LCM

This report approached identification of LCM and FRS programs with a ‘mile wide, inch deep’ mentality
in collecting applicable programs. Each of the top agencies identified also fit qualifications with the
guidelines set forth for Tasks 2 and 3: examination of LCM and the examination of FRS. After identifying
the various agencies across different industries, the recommended agencies for review provide a top
level review of applicability and relevance to BSEE for both LCM and FRS.

BSEE LCM and Failure Reporting Task 1 Draft Report iii | Page
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BSEE LCM and Failure Reporting Task 1 Draft Report iv | Page


Table of Contents
Executive Summary....................................................................................................................................... ii

1. Objectives and Purpose ...................................................................................................................... 13

2. Introduction ........................................................................................................................................ 13

3. Approach ............................................................................................................................................. 14

4. Findings ............................................................................................................................................... 15

4.1 Domestic Federal Agencies ......................................................................................................... 25

4.1.1 Department of Defense (DOD)............................................................................................ 25

4.1.2 Department of Energy (DOE) .............................................................................................. 25

4.1.3 Department of Health and Human Services (HHS) ............................................................. 26

4.1.3.1 Centers for Disease Control and Prevention (CDC)..................................................... 26

4.1.3.2 Food and Drug Administration (FDA) .......................................................................... 27

4.1.4 Department of Homeland Security (DHS) ........................................................................... 29

4.1.4.1 United States Coast Guard (USCG).............................................................................. 29

4.1.5 Department of the Interior (DOI) ........................................................................................ 30

4.1.5.1 Bureau of Land Management (BLM) ........................................................................... 30

4.1.5.2 Bureau of Safety and Environmental Enforcement (BSEE) ......................................... 31

4.1.6 Department of Labor (DOL) ................................................................................................ 32

4.1.6.1 Mine Safety and Health Administration (MSHA) ........................................................ 32

4.1.6.2 Occupational Safety and Health Administration (OSHA) ............................................ 32

4.1.7 Department of Transportation (DOT) ................................................................................. 33

4.1.7.1 Federal Aviation Administration (FAA) ....................................................................... 33

4.1.7.2 Federal Highway Administration (FHWA) ................................................................... 34

4.1.7.3 Federal Railroad Administration (FRA)........................................................................ 36

4.1.7.4 Federal Transit Administration (FTA) .......................................................................... 36

4.1.7.5 Maritime Administration (MARAD)............................................................................. 37

4.1.7.6 National Highway Traffic Safety Administration (NHTSA) .......................................... 38

4.1.7.7 Pipeline and Hazardous Materials Safety Administration (PHMSA) ........................... 39

4.1.8 Environmental Protection Agency (EPA)............................................................................. 40

4.1.9 National Aeronautics and Space Administration (NASA) .................................................... 41

4.1.10 Nuclear Regulatory Commission (NRC) ............................................................................... 42

BSEE LCM and Failure Reporting Task 1 Draft Report v | Page


4.1.11 National Transportation Safety Board (NTSB) .................................................................... 42

4.1.12 1United States Department of Agriculture (USDA) ............................................................ 43

4.2 Domestic State Agencies............................................................................................................. 44

4.2.1 Commonwealth of Massachusetts Department of Public Health (MA DHP) ..................... 44

4.2.2 State of California: California State Lands Commission, Other Offices .............................. 45

4.3 International Regulators ............................................................................................................. 46

4.3.1 Australia .............................................................................................................................. 46

4.3.1.1 Australia Asset Management Council ......................................................................... 46

4.3.1.2 National Offshore Petroleum Safety and Environmental Management Authority

(NOPSEMA) ................................................................................................................................. 47

4.3.1.3 Australian Transport Safety Bureau (ATSB) ................................................................ 48

4.3.1.4 Australian Treasury ..................................................................................................... 48

4.3.2 Brazil, National Agency of Oil, Gas and Biofuels (ANP) ....................................................... 48

4.3.3 Canada ................................................................................................................................ 49

4.3.3.1 National Energy Board (NEB) ...................................................................................... 49

4.3.3.2 Canada-Newfoundland & Labrador Offshore Petroleum Board (C-NLOPB) ............... 50

4.3.3.3 Canada-Nova Scotia Offshore Petroleum Board (CNSOPB) ........................................ 50

4.3.4 Denmark, Danish Energy Agency (DEA) .............................................................................. 51

4.3.5 Mexican National Hydrocarbons Commission (CNH) ......................................................... 52

4.3.6 Netherlands, State Supervision of Mines (SSM) ................................................................. 52

4.3.7 New Zealand, Department of Labor ................................................................................... 54

4.3.8 Norway, Petroleum Safety Authority (PSA) ........................................................................ 54

4.3.9 United Kingdom (UK) .......................................................................................................... 56

4.3.9.1 Health and Safety Executive (HSE) .............................................................................. 56

4.3.9.2 Oil & Gas UK ................................................................................................................ 57

4.3.10 International Atomic Energy Agency (IAEA) ....................................................................... 58

4.4 Industry ....................................................................................................................................... 59

4.4.1 Australia .............................................................................................................................. 59

4.4.1.1 Australia Asset Management Council ......................................................................... 59

4.4.1.2 National Offshore Petroleum Safety and Environmental Management Authority

(NOPSEMA) ................................................................................................................................. 59

4.4.1.3 Australian Transport Safety Bureau (ATSB) ................................................................ 60

BSEE LCM and Failure Reporting Task 1 Draft Report vi | Page


4.4.1.4 Australian Treasury ..................................................................................................... 60

4.4.2 Brazil, National Agency of Oil, Gas and Biofuels (ANP) ....................................................... 61

4.4.3 Canada ................................................................................................................................ 61

4.4.3.1 National Energy Board (NEB) ...................................................................................... 61

4.4.3.2 Canada-Newfoundland & Labrador Offshore Petroleum Board (C-NLOPB) ............... 62

4.4.3.3 Canada-Nova Scotia Offshore Petroleum Board (CNSOPB) ........................................ 63

4.4.4 Denmark, Danish Energy Agency (DEA) .............................................................................. 64

4.4.5 Mexican National Hydrocarbons Commission (CNH) ......................................................... 64

4.4.6 Netherlands, State Supervision of Mines (SSM) ................................................................. 65

4.4.7 New Zealand, Department of Labor ................................................................................... 66

4.4.8 Norway, Petroleum Safety Authority (PSA) ........................................................................ 67

4.4.9 United Kingdom (UK) .......................................................................................................... 68

4.4.9.1 Health and Safety Executive (HSE) .............................................................................. 68

4.4.9.2 Oil & Gas UK ................................................................................................................ 70

4.4.10 International Atomic Energy Agency (IAEA) ....................................................................... 71

5. Recommendations and Conclusions ................................................................................................... 71

6. References .......................................................................................................................................... 81

BSEE LCM and Failure Reporting Task 1 Draft Report vii | Page
List of Tables
Table 1: Agencies Reviewed ........................................................................................................................ 15

Table 2: Task 1 Programs ............................................................................................................................ 18

Table 3: Agency Review Scores ................................................................................................................... 72

Table 4: Agencies Sorted by Ranked Score ................................................................................................. 75

Table 5: ABS Consulting Recommended Agencies for Further Review ...................................................... 77

BSEE LCM and Failure Reporting Task 1 Draft Report viii | Page
List of Acronyms

AASHTO American Association of State Highway and Transportation Officials


AEMS® Adverse Event Management Suite
AI Asset Integrity
AIAA American Institute of Aeronautics and Astronautics
AIM Inventory and Monitoring Strategy –or– Asset Integrity Management
ANP National Agency of Oil, Gas and Biofuels (Brazil)
ANSI American National Standards Institute
AP Analytical Process
AGPMR Agricultural Property Management Regulation
API American Petroleum Institute
APTA American Public Transportation Association
ASIAS Aviation Safety Information Analysis and Sharing
ASME American Society of Mechanical Engineers
ASRS Aviation Safety Reporting System
ATSB Australian Transport Safety Bureau
AWO American Waterways Operators
BHCSQ Bureau of Health Care Safety and Quality
BIFA Buses in Fatal Accidents
BLM Bureau of Land Management
BSEE Bureau of Safety and Environmental Enforcement
BMS Bridge Management System
CASREP Casualty Report
CDC Centers for Disease Control and Prevention
CEP Component Exchange Program
CFR Code of Federal Regulations
C-NLOPB Canada-Newfoundland and Labrador Offshore Petroleum Board
CNSOPB Canada-Nova Scotia Offshore Petroleum Board
CIL Critical Items List
C&S Signal and Communication
DAFWII Days Away From Work
DART Days Away, Restricted, and Transfer (Case Rate)
DCACAS Data Collection Analysis and Corrective Action System
DCR Design and Construction
DEA Danish Energy Agency
DECC Department of Energy and Climate Change
DED Data Element Descriptions
DOD Department of Defense
DOE Department of Energy
DHHS Department of Health and Human Services

BSEE LCM and Failure Reporting Task 1 Draft Report ix | Page


DHS Department of Homeland Security
DOI Department of the Interior
DOL Department of Labor
CPT Cost per Ton
DRACAS Data Reporting, Analysis and Corrective Action System
EEC European Economic Community
EILSP Equipment/Systems Integrated Logistics Support Plan
EPA Environmental Protection Agency
EPLC Enterprise Performance Life Cycle
EPRI Electric Power Research Institute
ET Electronic Traction
FAA Federal Aviation Administration
FAR Federal Aviation Regulation
FARS Fatality Analysis Reporting System
FCIL Failed Equipment Critical Items List
FDA Food and Drug Administration
FHWA Federal Highway Administration
FIRS Failure and Inventory Reporting System
FMCSA Federal Motor Carrier Safety Administration
FMEA Failure Modes and Effects Analysis
FMECA Failure Modes, Effects and Criticality Analysis
FRA Federal Railroad Administration
FRACAS Failure Reporting, Analysis, and Corrective Action System
FRS Failure Reporting System
FSCAP Flight Safety-Critical Aircraft Part
FTA Federal Transit Administration
HAZID Hazard Identification
HAZOP Hazard and Operability Study
HCFRS Health Care Facility Reporting System
HFMEA® Healthcare Failure Mode and Effects Analysis
HHS Department of Health and Human Services
HPMS Highway Performance Monitoring System
HSE Health and Safety Executive (Britain)
KCIL Other Key Equipment Critical Items List
IADC International Association of Drilling Contractors
IAEA International Atomic Energy Agency
ICS Incident Command System
IDS Inventory Data System
IM Integrity Management
IMS Incident Management System
IRF International Regulators Forum
IRS Incident Reporting System

BSEE LCM and Failure Reporting Task 1 Draft Report x | Page


IRSRR Incident Reporting System for Research Reactors
ISO International Organization for Standardization
KP4 Ageing and Life Extension Inspection Program (HSE)
LCA Life Cycle Assessment
LCC Life Cycle Cost(ing)
LCI Life Cycle Inventory
LCIA Life Cycle Impact Assessment
LCM Life Cycle Management
LCMSP Life Cycle Management Service Provider
LER Licensee Event Report
LMP Life Cycle Management Plan
LTCCP Long-Term Council Community Plan
MA DHP Massachusetts Department of Public Health
MAP-21 Moving Ahead for Progress in the 21st Century Act
MARAD United States Maritime Administration
MASTREP Modernized Australian Ship Tracking and Reporting
MBIE Ministry of Business, Innovation and Employment
MIL-STD Military Standard
MML Mandatory Maintenance List
MMS Minerals Management Service
MODU Mobile Offshore Drilling Units
MPO Metropolitan Planning Organization
MSHA Mine Safety and Health Administration
NHTSA National Highway Traffic Safety Administration
NASA National Aeronautics and Space Administration
NEA Nuclear Energy Agency
NEB Canada-National Energy Board
NHC National Hydrocarbons Commission (Mexico)
NHS National Highway System
NIMS National Incident Management System
NOGEPA Netherlands Oil and Gas Exploration Production Association
NOPSEMA National Offshore Petroleum Safety and Environmental Management Authority
NRC Nuclear Regulatory Commission
NTL Notice to Lessees
NTSB National Transportation Safety Board
OCS Outer Continental Shelf
OEM Original Equipment Manufacturer
OHA Operating Hazard Analysis
OPR Onshore Pipeline Regulation
OSHA Occupational Safety and Health Administration
PHA Preliminary Hazard Analysis
PHMSA Pipeline Hazardous Materials Administration

BSEE LCM and Failure Reporting Task 1 Draft Report xi | Page


PMS Pavement Management System
PSA Petroleum Safety Authority (Norway)
RCA Root Cause Analysis
RCP Responsible Carrier Program
RIDDOR Reporting of Injuries, Diseases and Dangerous Occurrences
RP Recommended Practice
R&M Reliability and Maintainability
PRACAS Problem Reporting and Corrective Action System
SAICM Strategic Approach to International Chemicals Management
SEMATEC Semiconductor Manufacturing Technology Consortium
SEMP Safety and Environmental Management Program
SEMS Environmental Management System
SME Subject Matter Expert
SMS Safety Management System
SOAR Spacecraft Orbital Anomaly Report
SRE Serious Reportable Events
SSM State Supervision of Mines
SSPP System Safety Program Plan
TAM Transit Asset Management
TCR Total Case Rate
TIFA Trucks in Fatal Accidents
UK United Kingdom
UKCS United Kingdom Continental Shelf
UMTRI University of Michigan’s Transportation Research Institute
USCG United States Coast Guard
USDA United States Department of Agriculture
WBIRS Web-Based Incident Reporting System

BSEE LCM and Failure Reporting Task 1 Draft Report xii | Page
1. Objectives and Purpose
LCM and Failure Reporting provide a way for the oil and gas industry to monitor how well a piece of
equipment or any component on a piece of equipment performs its job. If failure occurs, failure
reporting provides a signal to other users of similar equipment/components of an exposed problem and
gives investigators the best chance to determine the root cause of an incident and make corrections.

In order to support the Bureau of Safety and Environmental Enforcement (BSEE) in development and
administration of an effective and efficient regulatory program based on risk management for Outer
Continental Shelf (OCS) oil and gas operations, this project will generate a base of knowledge from
existing regulations and private sector programs that define best practices in relevant arenas.

Domestic, international, and private industry programs will be analyzed for this Task 1. Evaluation will
focus on the following areas: 1) identification of established Life Cycle Management (LCM) concepts,
requirements and methodologies that have the potential to form a foundation for implementation of a
BSEE LCM program; 2) identification of established failure reporting system (FRS) concepts, tools, and
implementation programs that have the potential to form a foundation for implementation of a BSEE
FRS program; and 3) development of a working definition for “critical equipment” as it may be applied
to LCM and FRS programs for OCS oil and gas operations under BSEE jurisdiction.

2. Introduction
This report describes the results of inquiries and analyses in support of contract E14PS00084, to identify
LCM and Failure Reporting concepts for critical equipment used in OCS oil and gas operations and
recommend changes to 30 CFR 250. In keeping with the Bureau of Safety and Environmental
Enforcement’s (BSEE) mission, this Task 1 report provides a review of the Life Cycle Management
Systems (LCM) and Failure Reporting Systems (FRS) and recommendations on improvements that can be
implemented by BSEE. The project focuses on knowing who, what, when and why equipment and
components should be included in LCM and Failure Reporting, and the associated Risk, is a critical
challenge.

The report provides an overview of domestic agencies, international agencies, as well as industry
association and companies. Following the review of the agencies and their associated programs, ABS
Consulting will do a more in-depth review of the selected agencies. Each team researched the LCM and
FRS in use among these three groups, as well as equipment these groups define as critical, to identify
features that may be appropriate for BSEE to consider. The information gathered during this research
will be used to create an initial definition of critical equipment and to develop recommendations for
possible changes to BSEE’s regulations.

BSEE LCM and Failure Reporting Task 1 Draft Report 13 | Page


Our research and recommendations will be incorporated into a comprehensive report.
Recommendations are provided to BSEE to strengthen their regulatory-related risk management to
enable greater adaptability, flexibility, and effectiveness in regulating a complex and fast paced industry.

To support continued improvement of BSSE oversight of risk mitigation, BSEE should have readily
accessible information about how other agencies and firms are successfully managing risk with LCM and
FRS programs. BSEE can learn from authenticated and evolving best practices for LCM and FRS
programs for risk management of critical components.

BSEE currently incorporates American Petroleum Institute (API) Specification Q1, Eighth Edition
(Specification for Quality Management System Requirements for Manufacturing Organizations for the
Petroleum and Natural Gas Industry) into its regulations. This Specification addresses risk management
in manufacturer quality programs. Additionally, industry has developed API Specification Q2
(Specification for Quality Management System Requirements for Service Supply Organizations for the
Petroleum and Natural Gas Industries), which addresses risk management in service sector products and
services. API Specification Q3 is in the early stages of development and will specifically address LCM
from concept through decommission, and failure reporting, likely leveraging from API Specifications Q1
and Q2. As BSEE reviews LCM and FRS programs for applicability to BSEE jurisdiction, incorporation of
API Specification Q2 and Q3 will be considered for incorporation into its regulatory program.

3. Approach
For purposes of this project, BSEE outlines the scope of an LCM program to include the following as
related to a piece of equipment: design, fabrication, installation, repair and maintenance, failure
analysis, design modification/refurbishment/re-specification, and operation. ABS Consulting shall
research and identify the domestic and international bodies (regulatory, industry and trade) that have
either and LCM or FRS program in effect.

The ABS Consulting team was divided into three separate teams: Domestic Agencies, International
Agencies, and Industry. Each team was tasked with identifying appropriate agencies for initial analysis of
applicable programs. Each agency identified was reviewed for a Life Cycle Management System (LCM) or
a Failure Reporting System (FRS).

The teams will develop a detailed contact plan to ensure sufficient and relevant coverage of sources.
Each constituent contacted will be asked about: 1) their use of LCM processes; 2) Failure Reporting
requirements, methods, and systems; 3) Critical equipment.

The teams will use a standard template to review and collect standardized data for each identified
program to learn consistent information as a baseline. The collected information will be able to inform
the start of Tasks 2 and 3 and provide the BSEE requirements as applicable.

BSEE LCM and Failure Reporting Task 1 Draft Report 14 | Page


4. Findings
Each team identified potential agencies that may have an LCM or FRS implemented. An initial list was
created, and with further research, other agencies were identified for further analysis. Ultimately, the
teams identified fifty-three separate agencies for the initial research start for the project. Table 1 below
shows all the identified agencies that are identified for the Task 1 survey.

Table 1: Agencies Reviewed

Agency/Organization Acronym
Domestic: Federal
Department of Agriculture USDA
Department of Defense DOD
Department of Energy DOE
Department of Health and Human Services DHHS
Centers for Disease Control CDC
Food and Drug Administration FDA
Department of Homeland Security DHS
U.S. Coast Guard USCG
Department of the Interior DOI
Bureau of Land Management BLM
Bureau of Safety and Environmental Enforcement BSEE
Department of Labor DOL
Mine Safety and Health Administration MSHA
Occupational Safety and Health Administration OHSA
Department of Transportation DOT
Federal Aviation Administration FAA
Federal Highway Administration FHWA
Federal Motor Carrier Safety Administration FMCSA
Federal Rail Administration FRA
Federal Transit Administration FTA
Maritime Administration MARAD
National Highway Traffic Safety Administration NHTSA
Pipeline and Hazardous Materials Administration PHMSA
Environmental Protection Agency EPA
National Aeronautics and Space Administration NASA
Nuclear Regulatory Commission NRC
National Transportation Safety Board NTSB
Domestic: State
Massachusetts Department of Health MA DPH
California State Lands Commission CSLC

BSEE LCM and Failure Reporting Task 1 Draft Report 15 | Page


Agency/Organization Acronym
International
Australia AU
Asset Management Council AMC
National Offshore Petroleum Safety and Environmental Management
Authority NOPSEMA
Transportation Safety Bureau TSB
Treasury
Brazil BR
National Agency of Oil, Gas and Biofuels ANP
Canada CA
National Energy Board NEB
Newfoundland & Labrador Offshore Petroleum Board C-NLOPB
Nova Scotia Offshore Petroleum Board C-NSOPB
Denmark DK
Danish Energy Agency DEA
Mexico MX
National Hydrocarbons Commission CNH
Netherlands NL
State Supervision of Mines SODM
New Zealand NZ
Controller and Auditor-General Office
Department of Labour NZ DOL
Military
Norway NO
Petroleum Safety Authority PSA
United Kingdom UK
Health and Safety Executive HSE
Oil and Gas
International Atomic Energy Agency IAEA
Industry
American Institute of Aeronautics and Astronautics AIAA
American Petroleum Institute API
American Waterway Operators AWO
AMTRAK
CCD Health Systems
ConocoPhillips
Crowley
ExxonMobil

BSEE LCM and Failure Reporting Task 1 Draft Report 16 | Page


Agency/Organization Acronym
Foss
International Association of Drilling Contractors IADC
International Organizations for Standardization ISO
Joy Mining
ReliaSoft
SEMATEC

From this list, ABS Consulting identified applicable programs within each agency or industry. Several
agencies had multiple programs for their industries. Some programs identified were not applicable to
the scope of this project and other programs were not fully established or currently running. Eight
programs were identified as both LCM and FRS, with thirty-four additional LCM and forty-eight FRS
programs identified. In total, eighty-six programs were identified and initially reviewed for Task 1. In
Table 2 below, all identified programs are provided.

BSEE LCM and Failure Reporting Task 1 Draft Report 17 | Page


Table 2: Task 1 Programs
LCM
or
Agency/Organization Acronym Program FRS
Domestic: Federal
Department of Agriculture USDA
A Treatise on the Application of Life Cycle Management Principles in
Agriculture & Biological Engineering LCM
Department of Defense DOD
Failure Reporting, Analysis, and Corrective Action System FRS
Department of Energy DOE
Occurrence Reporting and Performance Analysis FRS
Occurrence Reporting and Processing of Operations Information FRS
Department of Health and Human
Services DHHS
Centers for Disease Control CDC
Enterprise Performance Life Cycle (EPLC) Framework LCM
Incident Management System (IMS) LCM
Food and Drug Administration FDA
MedWatch: The FDA Safety Information and Adverse Event Reporting Program FRS
Product Recalls, Including Removals and Corrections FRS
Department of Homeland Security DHS
U.S. Coast Guard USCG
Casualty Reporting (CASREP) System FRS
Notice of Marine Casualty FRS
Pollution Incident Reporting FRS
Department of the Interior DOI
Bureau of Land Management BLM
Inventory and Monitoring (AIM) Strategy LCM
Report of Undesirable Events, NTL-MSO-1-92 FRS

BSEE LCM and Failure Reporting Task 1 Draft Report 18 | Page


LCM
or
Agency/Organization Acronym Program FRS
Bureau of Safety and
Environmental Enforcement BSEE
Safety Device Failure and Inventory Reporting System (FIRS) FRS
Department of Labor DOL
Mine Safety and Health
Administration MSHA
Equipment Related Accidents - Fatalgrams and Accident Reports FRS
Hazard Communication (HazCom) FRS
Occupational Safety and Health
Administration OHSA
Oil and Gas Well Drilling and Servicing eTool FRS
Unnamed Data Initiative FRS
Department of Transportation DOT
Federal Aviation Administration FAA
Aviation Safety Information Analysis and Sharing (ASIAS) System FRS
Aviation Safety Reporting System (ASRS) FRS
Federal Aviation Regulation (FAR) Part 21 Section 3 FRS
Pre-Flight Problem/Failure Reporting Procedures FRS
Federal Highway Administration FHWA
Pavement Management System (PMS) LCM
Bridge Management System (BMS) LCM
Safety Management System (SMS) LCM
Highway Performance Monitoring System (HPMS) FRS
Federal Motor Carrier Safety delet
Administration FMCSA ed
Federal Rail Administration FRA
Collision Hazard Analysis / System Safety Program Plan (SSPP) LCM
Federal Transit Administration FTA

BSEE LCM and Failure Reporting Task 1 Draft Report 19 | Page


LCM
or
Agency/Organization Acronym Program FRS
National Transit Asset Management (TAM) System LCM
Maritime Administration MARAD
Comprehensive Management Plan for the Disposal of Non-retention Ships LCM
National Highway Traffic Safety
Administration NHTSA
Fatality Analysis Reporting System (FARS) FRS
Buses in Fatal Accidents (BIFA) FRS
Trucks in Fatal Accidents (TIFA) FRS
Pipeline and Hazardous Materials
Administration PHMSA
Integrity Management LCM
Incident Reports and Safety Related Condition Reports FRS
Mechanical Fitting Failure Report Form, PHMSA F 7100.1-2 FRS
Environmental Protection Agency EPA
Enhanced and Basic I/M Performance Standards LCM
Plan to Assess Fracking LCM
Pollution Incident Reporting FRS
National Aeronautics and Space
Administration NASA
Aviation Safety Reporting System (ASRS) FRS
Spacecraft Orbital Anomaly Report (SOAR) FRS
Pre-Flight Problem/Failure Reporting Procedures FRS
Problem Reporting and Corrective Action System (PRACAS) FRS
Nuclear Regulatory Commission NRC
Licensee Event Report Search FRS
Web-Based Incident Reporting System (WBIRS) FRS
National Transportation Safety Board NTSB
Domestic: State
BSEE LCM and Failure Reporting Task 1 Draft Report 20 | Page
LCM
or
Agency/Organization Acronym Program FRS
Massachusetts Department of Health MA DPH
Health Care Facility Reporting System (HCFRS) FRS
California State Lands Commission CSLC
Accident Investigation and Reports FRS
International
Australia AU
Asset Management Council AMC
Asset Life Cycle Management LCM
National Offshore Petroleum
Safety and Environmental Management
Authority NOPSEMA
Safety Case Life Cycle Management LCM
Asset Registry LCM
Transportation Safety Bureau TSB
Failure Investigations FRS
Treasury
Total Asset Management / Life Cycle Costing (LCC) LCM
Brazil BR
National Agency of Oil, Gas and
Biofuels ANP
Canada CA
National Energy Board NEB
Newfoundland & Labrador
Offshore Petroleum Board C-NLOPB
Nova Scotia Offshore Petroleum
Board C-NSOPB
Life Cycle Approach LCM
Incident Reporting and Investigation Guidelines FRS

BSEE LCM and Failure Reporting Task 1 Draft Report 21 | Page


LCM
or
Agency/Organization Acronym Program FRS
Denmark DK
Danish Energy Agency DEA Documentation of Management Plans LCM
Mexico MX
National Hydrocarbons
Commission CNH
NHC Data Initiative LCM
Netherlands NL
State Supervision of Mines SODM
Asset Integrity Management (AIM) LCM
Reporting Accident and Incidents, Mining Activities FRS
New Zealand NZ
Controller and Auditor-General Delet
Office e
Department of Labour NZ DOL
Facility Safety Case - Safety Management System (SMS) FRS
Delet
Military e
Norway NO
Petroleum Safety Authority PSA
Individual Facility-Customized LCM Systems LCM
Registration, Review and Investigation of Hazard and Accident Situations FRS
United Kingdom UK
Health and Safety Executive HSE
Ageing and Life Extension Inspection Program (KP4) LCM
Reporting of Injuries, Diseases and Dangerous Occurrences (RIDDOR) FRS
Well Life Cycle Practices Forum (WLCPF) FRS
Oil and Gas
Well Life Cycle Practices Forum (WLCPF)
BSEE LCM and Failure Reporting Task 1 Draft Report 22 | Page
LCM
or
Agency/Organization Acronym Program FRS
International Atomic Energy Agency IAEA
Incident Reporting System (IRS) FRS
Incident Reporting System for Research Reactors (IRSRR) FRS
Industry
American Institute of Aeronautics and
Astronautics AIAA
Failure Reporting, Analysis and Corrective Action System (FRACAS) FRS
American Petroleum Institute API
API RP 2D LCM
API RP 2FB LCM
API RP 75 LCM
API Q1 Both
API Q2 LCM
API Q3 Both
API 2C LCM
Life Cycle Management Plan (LMP) LCM
Strategic Approach to International Chemicals Management (SAICM) LCM
Reporting Process Safety Events FRS
American Waterway Operators AWO
Responsible Carrier Program (RCP) Both
AMTRAK
Maximo Asset Management LCM
CCD Health Systems
Adverse Event Management (AEMS®) FRS
ConocoPhillips
ISO
Crowley AWO

BSEE LCM and Failure Reporting Task 1 Draft Report 23 | Page


LCM
or
Agency/Organization Acronym Program FRS
ExxonMobil ISO
Foss RCP Both
International Association of Drilling
Contractors IADC
Asset Integrity and Reliability LCM
International Organizations for
Standardization ISO
Life Cycle Assessment (LCA) LCM
Joy Mining
Life Cycle Management at Joy Mining Machinery LCM
Potential Failure Reporting System FRS
ReliaSoft
XFRACAS Software Tool FRS
SEMATEC
Failure Reporting Analysis and Corrective Action System FRS

BSEE LCM and Failure Reporting Task 1 Draft Report 24 | Page


Each of these programs is now reviewed in this section. Agencies are divided by: Domestic: Federal
Agencies, Domestic: State Agencies, International Regulators, and Industry. Each identified agency
reviewed provides a background of the agency, whether an LCM or FRS is identified, and a brief
description of that program. If we were unable to identify a program, we stated as such. If an agency did
not have either an identifiable LCM or an FRS, this agency was eliminated from the review below.

4.1 Domestic Federal Agencies

4.1.1 Department of Defense (DOD)

Background
The mission of the Department of Defense (DOD) is to provide the U.S. military forces (Army, Navy, and
Air Force) needed to deter war and protect the security of the United States of America. (U.S.
Department of Defense, 2014)

LCM
No LCM identified at this time.

FRS

Failure Reporting, Analysis, and Corrective Action System (FRACAS)


The military standard, MIL-STD-215 (AS), establishes uniform requirements and criteria for a Failure
Reporting, Analysis, and Corrective Action System (FRACAS) to implement the requirement of MIL-STD­
785. FRACAS is intended to provide management visibility and control for reliability and maintainability
improvement of hardware and associated software by timely and disciplined utilization of failure and
maintenance data to generate and implement effective corrective actions to prevent failure recurrence
and to simplify or reduce the maintenance tasks.

4.1.2 Department of Energy (DOE)

Background
The United States Department of Energy (DOE) is a Cabinet-level department of the United States
government concerned with the United States' policies regarding energy and safety in handling nuclear
material. Its responsibilities include the nation's nuclear weapons program, nuclear reactor production
for the United States Navy, energy conservation, energy-related research, radioactive waste disposal,
and domestic energy production (U.S. Department of Energy, 2014).

LCM
No LCM identified at this time.

BSEE LCM and Failure Reporting Task 1 Draft Report 25 | Page


FRS

Occurrence Reporting and Performance Analysis


The DOE Manual 231.1-1, Occurrence Reporting and Performance Analysis Guide, details requirements
including categorization of occurrences related to safety, the environment, health, or operations
(“Reportable Occurrences”), notification of these occurrences, and development and submission of
documented follow-up reports.

Occurrence Reporting and Processing of Operations Information


The DOE Manual 231.1-2 provides detailed requirements to supplement DOE 231.1A, Environment,
Safety, and Health Reporting, dated 08-19-03. This Manual is approved for use by all DOE Elements and
their contractors.

4.1.3 Department of Health and Human Services (HHS)

4.1.3.1 Centers for Disease Control and Prevention (CDC)

Background
The Centers for Disease Control and Prevention (CDC) is the national public health agency and works
24/7 to protect America from health, safety and security threats, both foreign and in the U.S. The CDC
protects public health and safety through the control and prevention of disease, injury, and disability.
Whether diseases start at home or abroad, are chronic or acute, curable or preventable, human error or
deliberate attack, CDC fights disease and supports communities and citizens to do the same. The CDC
increases the health security of the nation. To accomplish their mission, the CDC conducts critical
science and provides health information that protects against expensive and dangerous health threats,
and responds when these arise (Centers for Disease Control and Prevention, 2014). The CDC focuses
particularly on infectious disease, food borne pathogens, environmental health, occupational safety and
health, health promotion, injury prevention and educational activities designed to improve the health of
U.S. citizens. The CDC also dedicates research to and disseminates information about non-infectious
diseases such as obesity and diabetes.

LCM

Enterprise Performance Life Cycle (EPLC) Framework


The Enterprise Performance Life Cycle (EPLC) framework consists of ten life cycle phases. Within each
phase, activities, responsibilities, reviews, and deliverables are defined. Exit criteria are established for
each phase and Stage Gate reviews are conducted through the IT Governance process to ensure that the
project’s management quality, soundness, and technical feasibility remain adequate and the project is
ready to move forward to the next phase. The EPLC framework provides a guide to Project Managers,
Business Owners, IT Governance Executives, other Stakeholders, and Critical Partners throughout the
life of the project.

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The EPLC framework is designed to provide flexibility needed to adequately manage risk while allowing
for differences in project size, complexity, scope, duration, etc.

EPLC framework elements are: initiation, concept, planning, requirements analysis, design,
development, test, implementation, operations & maintenance, and disposition (Department of Health
and Human Services, 2012).

Incident Management System (IMS)


The Incident Management System (IMS) is a common response system, which the CDC uses to manage
response efforts. IMS is based on the Incident Command System (ICS) and the National Incident
Management System (NIMS), both of which are standardized emergency response operating systems
used around the country. The CDC and all 50 States have trained public health officials on their specific
roles and responsibilities during an emergency, as outlined by ICS. This training helps ensure that the
CDC field response teams operate effectively as part of the state or local response structure.

FRS
No FRS identified at this time.

4.1.3.2 Food and Drug Administration (FDA)

Background
The Food and Drug Administration (FDA) is responsible for protecting the public health by assuring the
safety, efficacy and security of human and veterinary drugs, biological products, medical devices, our
nation’s food supply, cosmetics, and products that emit radiation.

The FDA is also responsible for advancing the public health by helping to speed innovations that make
medicines more effective, safer, and more affordable and by helping the public get the accurate,
science-based information they need to use medicines and foods to maintain and improve their health.
The FDA also has responsibility for regulating the manufacturing, marketing and distribution of tobacco
products to protect the public health and to reduce tobacco use by minors.

Finally, the FDA plays a significant role in the Nation’s counterterrorism capability. The FDA fulfills this
responsibility by ensuring the security of the food supply and by fostering development of medical
products to respond to deliberate and naturally emerging public health threats (U.S. Food and Drug
Administration, 2014).

LCM
No LCM identified at this time.

FRS

MedWatch: The FDA Safety Information and Adverse Event Reporting Program
MedWatch is the FDA gateway for clinically important safety information and reporting serious
problems with human medical products ( (U.S. Food and Drug Administration, 2014)). In an effort to

BSEE LCM and Failure Reporting Task 1 Draft Report 27 | Page


track and monitor the adverse events caused by medical products including serious drug side effects,
product use errors, product quality and therapeutic failures, the FDA developed and organized an online
reporting system where individuals (users or manufactures) can report any failures related to: Drugs,
Medical Devices (including in vitro diagnostic products), Biologics, Special Nutritional Products,
Cosmetics and Food/Beverage. The data and information is organized and available through an FDA
searchable website. Individuals and companies can search the website for problems and issues reported
about any product. MedWatch alerts provide timely new safety information on human drugs, medical
devices, vaccines and other biologics, dietary supplements, and cosmetics. The alerts contain actionable
information that may impact both treatment and diagnostic choices for healthcare professional and
patients.

Product Recalls, Including Removals and Corrections


Recall is an effective method of removing or correcting consumer products that are in violation of laws
administered by the Food and Drug Administration. Recall is a voluntary action that takes place because
manufacturers and distributors carry out their responsibility to protect the public health and well-being
from products that present a risk of injury or gross deception or are otherwise defective.

An evaluation of the health hazard presented by a product being recalled or considered for recall will be
conducted by an ad hoc committee of Food and Drug Administration scientists and will take into
account, but need not be limited to, the following factors:

1) Whether any disease or injuries have already occurred from the use of the product.
2) Whether any existing conditions could contribute to a clinical situation that could expose
humans or animals to a health hazard. Any conclusion shall be supported as completely as
possible by scientific documentation and/or statements that the conclusion is the opinion of the
individual(s) making the health hazard determination.
3) Assessment of hazard to various segments of the population, e.g., children, surgical patients,
pets, livestock, etc., who are expected to be exposed to the product being considered, with
particular attention paid to the hazard to those individuals who may be at greatest risk.
4) Assessment of the degree of seriousness of the health hazard to which the populations at risk
would be exposed.
5) Assessment of the likelihood of occurrence of the hazard.
6) Assessment of the consequences (immediate or long-range) of occurrence of the hazard (21 CFR
Part 7).

BSEE LCM and Failure Reporting Task 1 Draft Report 28 | Page


4.1.4 Department of Homeland Security (DHS)

4.1.4.1 United States Coast Guard (USCG)

Background
The United States Coast Guard serves to protect U.S. maritime interests. Serving a number of different
missions, it protects American economic and security interests in the maritime domain. Today’s U.S.
Coast Guard, with nearly 42,000 men and women on active duty, is a unique force that carries out an
array of civil and military responsibilities touching almost every facet of the U.S. maritime environment.

LCM
No LCM identified at this time.

FRS

Casualty Reporting (CASREP) System


The primary purpose of a casualty report (CASREP) message is to inform operational and tactical
commanders of specific mission degradation and operating limitations. The secondary purpose is to
inform mission support product line and logistics managers of technical assistance, parts, and repairs
required. Timely, accurate, and updated reporting enables operational and tactical commanders to
optimize resource allocation and mission effectiveness. Primary and secondary missions vary across
operational areas. Search and Rescue response and Maritime Security Response are primary missions
regardless of operational area. Damage control and crew endurance are missions and degradations, and
are also assessed, categorized, and reported similarly. Installed and portable fire/dewatering pumps,
self-contained breathing apparatus compressors, smoke/heat sensors, and aqueous film forming foam
systems are examples of vital damage control systems. Ventilation, heat/air conditioner, sewage,
potable water, scullery, and laundry capabilities are examples of fundamental crew endurance systems.
These systems have varying redundancies and mitigations, often based on cutter class and sometime
based on the operating environment. Regardless, cutters should specify and quantify limitations and
mitigations for clear understanding by operational commanders and support staffs. (United States Coast
Guard, 2013)

Notice of Marine Casualty


USCG regulations require the report of any and all incidents of Marine Casualties, as defined in 46 CFR
4.05-1. This regulation requires the master, owner, operator, agent or person in charge to report to the
nearest Coast Guard unit, as soon as it is safe, any marine casualty involving a vessel to include:

o Intended or un-intended grounding or allision with a bridge


o Loss of propulsion
o Fire, flooding, loss of firefighting system, bilge pump failure, damaged lifesaving equipment, and
loss of auxiliary power
o Injuries that require professional medical assistance
o Any damage that is in excess of $25,000.00

BSEE LCM and Failure Reporting Task 1 Draft Report 29 | Page


o Any incident that is harmful to the environment (46 CFR 4.03-65)

Pollution Incident Reporting


The USCG’s pollution incident reporting requirements are detailed in 33 CFR 153.203, Procedures for the
Notice of Discharge, which is enforced by the U.S. Coast Guard and the EPA, depending on jurisdiction at
the point of discharge/release. For pollution incidents on U.S. navigable waters and their tributaries, the
Coast Guard has jurisdiction; for inland or non-maritime pollution incidents, the EPA has jurisdiction (33
CFR 153.203). Responsible vessels or marine facilities must notify the National Response Center
immediately of a discharge of oil or release of a hazardous material occurs. If unable to contact the
National Response Center directly and immediately, then reports may be filed with the regional USCG
unit, followed by contact with the National Response Center as soon as possible. A report filed
according to this regulation covers requirements for Notice of Marine Casualties (46 CFR 4.05-1).

4.1.5 Department of the Interior (DOI)

4.1.5.1 Bureau of Land Management (BLM)

Background
The Bureau of Land Management is responsible for the management of over 245 million acres in the 12
Western states including Alaska. The Federal Land Policy and Management Act of 1976 mandates that
the BLM manage public land resources for multiple uses to include: energy development, livestock
grazing, recreation, and timber harvesting. The BLM is also responsible for protecting the natural,
cultural and historical resources found in the 27 million acre National Landscape Conservation System.

LCM

Inventory and Monitoring (AIM) Strategy


The Inventory and Monitoring (AIM) Strategy is intended to reach across programs, jurisdictions,
stakeholders, and agencies to provide data and information valuable to decision makers. This approach
will provide: (1) an opportunity to collect monitoring data that can be used many times for many
purposes and (2) the quantitative data essential for informed, defendable land management decision
making (Toevs, MacKinnon, & Bobo, 2011).

FRS

Report of Undesirable Events, NTL-MSO-1-92


Operators of onshore Federal and Indian oil and gas leases shall report all spills, discharges, or other
undesirable events in accordance with the requirements of Notice, Notice to Lessees (NTL)-MSO-1-92.
All such events which occur on State or private land leases within a Federally-supervised unit or
communitized areas must, likewise, be reported in accordance with the requirements of this Notice
(Lawton, Report of Undesirable Events, 1992).

BSEE LCM and Failure Reporting Task 1 Draft Report 30 | Page


4.1.5.2 Bureau of Safety and Environmental Enforcement (BSEE)

Background
“BSEE works to promote safety, protect the environment, and conserve resources offshore through
vigorous regulatory oversight and enforcement … The Offshore Regulatory Program develops standards
and regulations to enhance operational safety and environmental protection for the exploration and
development of offshore oil and natural gas on the U.S. Outer Continental Shelf (OCS).” (Bureau of
Safety and Environmental Enforcement, 2014)

LCM
No LCM identified at this time.

FRS

Safety Device Failure and Inventory Reporting System (FIRS)


The BSEE Failure Reporting System (FIRS) was a required reporting system that required industry to
provide reliability and safety data to BSEE. The system was created to enhance reliability and safety
through the development of reliability data on key safety devices.

“FIRS required periodic inventory and failure reports to be submitted on safety and pollution prevention
devices on offshore structures, including satellites and jackets, which produce or process hydrocarbons,
and the hydrocarbon pipelines thereon. Devices included blowdown valves, burner flame detectors,
check valves, combustible gas detectors, emergency shutdown valves, level sensors, pressure sensors,
relief valves, shutdown valves, subsurface safety valves, surface safety valves, temperature sensors,
valve actuators, and shutdown valves” (The Marine Board of the National Research Council, 1984).

FIRS relied on drilling companies and the Original Equipment Manufacturer (OEM) to provide their own
definitions of critical equipment, and submit data on what they determined to be critical. This led to a
massive amount of non-congruous data from multiple parties, which MMS/BSEE was unable to process
and utilize in an effective manner. Therefore, this data is no longer collected, FIRS was shut down and is
now defunct (Levine, 2014) (The Marine Board of the National Research Council, 1984).

Critical System:

Blowout preventer system

Critical Equipment:

o Blowdown valves
o Burner flame detectors
o Check valves
o Combustible gas detectors
o Emergency shutdown valves
o Level sensors

BSEE LCM and Failure Reporting Task 1 Draft Report 31 | Page


o Pressure sensors
o Relief valves
o Shutdown valves
o Subsurface safety valves
o Surface safety valves
o Temperature sensors
o Valve actuators
o Shutdown valves

4.1.6 Department of Labor (DOL)

4.1.6.1 Mine Safety and Health Administration (MSHA)

Background
The Mine Safety and Health Administration (MSHA) has been protecting Miners’ Safety and Health since
1978.

LCM
No LCM identified at this time.

FRS

Equipment Related Accidents – Fatalgrams and Accident Reports


Equipment related accident data from 1995-2014 is publicly available. Searches can be conducted for a
particular year or by listed equipment type, which then are linked to fatalgrams and accident reports.
The goal is to educate equipment operators and the mining community about the hazards associated
with operating a specific type of equipment. (Mine Safety and Health Administration, 2014)

Hazard Communication (HazCom)


MSHA's Hazard Communication Standard, called HazCom, expresses two safety and health principles:
miners have a right to know about the chemical hazards where they work and operators have a
responsibility to know about the chemical hazards at their mines. HazCom requires operators to inform
miners about chemical hazards (Mine Safety and Health Administration, 2014).

4.1.6.2 Occupational Safety and Health Administration (OSHA)

Background
The Occupational Safety and Health Administration (OSHA) is an agency of the United States
Department of Labor (DOL) responsible for assuring safe and healthful working conditions for working
men and women by setting and enforcing standards and providing training, outreach, education and
assistance (Occupational Safety and Health Administration, 2014).

BSEE LCM and Failure Reporting Task 1 Draft Report 32 | Page


LCM
No LCM identified at this time.

FRS

Oil and Gas Well Drilling and Servicing eTool


The OSHA Oil and Gas Well Drilling and Servicing eTool identifies common hazards and possible
solutions to reduce incidents that could lead to injuries or fatalities. Each drilling and servicing company
has its own safety program. This eTool is not a replacement for those programs, nor does it establish any
industry consensus standards. Rather, it can be used as a resource in identifying workplace hazards and
providing possible solutions that may be relevant to their safety programs (Occupational Health and
Safety Administration, 2009).

Unnamed Data Initiative


In an effort to monitor the work-related injuries and illness data from employers within specific industry
and employment size specifications, OSHA has developed a data collection system and uses the data to
calculate establishment-specific injury and illness incidence rates.

This searchable database contains a table with the name, address, industry, and associated Total Case
Rate (TCR); Days Away, Restricted, and Transfer (DART) case rate; and the Days Away From Work
(DAFWII) case rate for the establishments that provided OSHA with valid data for calendar years 1996
through 2009 (Occupational Safety and Health Administration). During Fiscal Year 1998 data were
collected from approximately 80,000 employers. As the program continued, the accumulated injury and
illness database has provided valuable information on the safety and health performance of individual
employers. These data may establish baselines and primary outcomes (Occupation Health and Safety
Administration, 2014).

4.1.7 Department of Transportation (DOT)

4.1.7.1 Federal Aviation Administration (FAA)

Background
The Federal Aviation Administration (FAA) is the national aviation authority of the United States. An
agency of the United States Department of Transportation, it has authority to regulate all aspects of
American civil aviation. The FAA is responsible for overseeing the safety and efficiency of the aerospace
system. FAA responsibilities include: aircraft certification and safety, and airport safety and compliance
(Federal Aviation Administration, 2014).

LCM
No LCM identified at this time.

BSEE LCM and Failure Reporting Task 1 Draft Report 33 | Page


FRS

Aviation Safety Information Analysis and Sharing (ASIAS) System


In an effort to track, monitor and improve aviation safety, the FAA developed and organized an online
reporting system where individuals (users or manufacturers) can report any safety related issues. The
data and information is organized and available through a searchable website. Individuals and
companies may search the website for problems or issues reported about any product. They system
provides users with advanced analytic and search capabilities. It enables the user to perform integrated
queries across multiple databases, search extensive safety data and display pertinent elements in an
array of useful formats. Construction of the system is continued in a phased approach. Additional data
sources and capabilities will be available as the system evolves in response to both expanded access to
shared data and technological innovation. (Federal Aviation Administration, 2014).

Aviation Safety Reporting System (ASRS)


The Aviation Safety Reporting System (ASRS) is an important facet of the continuing effort by
government, industry, and individuals to maintain and improve aviation safety. The ASRS compiles
voluntarily submitted aviation safety incident/situation reports from pilots, controllers, and others
(ASRS, PRACTICE NO. PD-ED-1255).

Federal Aviation Regulation (FAR) Part 21 Section 3


Manufacturers Reporting Failures, Malfunctions, or Defects (FAA, FAR Part 21 Section 3)

Pre-Flight Problem/Failure Reporting Procedures


This is a formal procedure when reporting and documenting problems or failures that occur during pre­
launch, testing and actual launch operations. (NASA, PRACTICE NO. PD-ED-1250)

4.1.7.2 Federal Highway Administration (FHWA)

Background
The Federal Highway Administration (FHWA) is responsible for the construction, maintenance and
preservation of the Nation’s highways, bridges and tunnels. The FHWA also works with state and local
governments to provide technical assistance to assist in the improvement of safety, mobility and
innovation of local highways and roads.

LCM

Pavement Management System (PMS)


An effective Pavement Management System (PMS) for Federal-aid highways is a systematic process that
provides information for use in implementing cost-effective pavement reconstruction, rehabilitation,
and preventative maintenance programs and that results in pavements designed to accommodate
current and forecasted traffic in a safe, durable, and cost-effective manner (49 CFR 500.106). The PMS
should be based on the “AASHTO Guidelines for Pavement Management Systems.”

BSEE LCM and Failure Reporting Task 1 Draft Report 34 | Page


Bridge Management System (BMS)
An effective Bridge Management System (BMS) for bridges on and off Federal-aid highways should be
based on the “AASHTO Guidelines for Bridge Management Systems”. It should use mathematical
models to make forecasts and recommendations, and should predict deterioration (49 CFR 500.107).

Safety Management System (SMS)


A Safety Management System (SMS) is a systematic process with the goal of reducing the number and
severity of traffic crashes by ensuring that all opportunities to improve highway safety are identified,
considered, implemented as appropriate, and evaluated in all phases of highway planning, design,
construction, maintenance, and operation. Development of the SMS may be based on the guidance in
“Safety Management Systems: Good Practices for Development and Implementation.” An effective
SMS includes: establishment of short- and long-term safety goals; collection, analysis and linkage of
highway safety data; identification of safety responsibilities of units and positions; and identification of
skills, resources, and training needs (49 CRF 500.108).

FRS

Highway Performance Monitoring System (HPMS)


The HPMS is a continuous data collection system jointly implemented by the FHWA and the States
beginning in 1978. It currently contains over 110,000 highway sample segments, the most
comprehensive nationwide data system in use regarding physical condition and usage of the Nation’s
infrastructure. The HPMS database is the primary source of information for the Federal government
about the Nation’s highway system.

To make use of the HPMS database, FHWA developed an Analytical Process (AP). These models were
originally developed and were subsequently enhanced over the years so that the U.S. Department of
Transportation and the U.S. Congress can have available improved understanding of those factors which
are of greatest importance in the development of highway programs and policy.

The HPMS AP is being used by FHWA, States, Metropolitan Planning Organizations (MPOs), and local
government agencies to assess the physical condition, safety, service, and efficiency of operation of
their respective highway systems. In addition to assessing the characteristics of the existing highway
systems, the HPMS AP also is being used to predict the effect that proposed highway programs and
policies are likely to have in the future. The capabilities of the HPMS AP may be summarized as:

o Assess Base Year Conditions and Performance


o Forecast Highway System Needs
o Simulate Highway System Conditions
o Analyze Investment Strategies
o Estimate User Costs

(Federal Highway Administration, 2014)

BSEE LCM and Failure Reporting Task 1 Draft Report 35 | Page


4.1.7.3 Federal Railroad Administration (FRA)

Background
The Federal Railroad Administration (FRA) develops programs that identify, monitor, and address issues
on passenger and freight railroads.

LCM

Collision Hazard Analysis / System Safety Program Plan (SSPP)


The Collision Hazard Analysis Guide to be used by passenger rail operators to conduct a collision hazard
analysis that identifies potential hazards and hazard mitigation strategies. Where applicable, this
analysis should be conducted in conjunction with the hazard analysis element under the passenger
railroad’s System Safety Program Plan (SSPP). Guidelines for hazard identification/resolution are
described in the APTA publication “Manual for the Development of System Safety Program Plans for
Commuter Railroads.” The disciplined, structured approach allows hazards to be systematically
identified, analyzed, and addressed. The process provides a permanent record of hazard analysis and
serves as a reference document to review and analyze future incidents, accidents, or changes in system
operations. The techniques for hazard analysis are valid for evaluating any hazards or safety issues
related to any type of operating system. A hazard analysis for a complete system may include several
analysis techniques applied throughout the life cycle of the product – from initial concept and design
through to the final disposal of the system. A full hazard analysis can consist of various analysis
documents including a Preliminary Hazard Analysis (PHA), Failure Modes and Effects Analysis (FMEA),
and Operating Hazard Analysis (OHA) (Federal Railroad Administration, 2007).

FRS
No FRS identified at this time.

4.1.7.4 Federal Transit Administration (FTA)

Background
The Federal Transit Administration (FTA), an agency within DOT, provides technical and financial
assistance to local public transportation systems. Public transportation includes: Buses, trains, subways,
passenger ferries, trolleys monorails, and other people movers. The FTA assists all 50 states and the
District of Columbia overseeing federal grants issued to state and local public transportation systems.

LCM

National Transit Asset Management (TAM) System


2013 advance notice of proposed rulemaking for new National Transit Asset Management (TAM) System
authorized by the Moving Ahead for Progress in the 21st Century Act (MAP-21) to ensure public
transportation systems are in a state of good repair (49 CFR Chapter VI).

BSEE LCM and Failure Reporting Task 1 Draft Report 36 | Page


The Moving Ahead for Progress in the 21st Century Act (MAP-21) was signed into law by President
Obama on July 6, 2012. MAP-21 creates a streamlined and performance-based surface transportation
program and builds on many of the highway, transit, bike, and pedestrian programs and policies
established in 1991. Goals included improving safety, maintaining infrastructure condition, and
protecting the environment. Among the national performance goals established by MAP-21 for Federal
highway programs is Infrastructure Condition – to maintain the highway infrastructure asset system in a
“state of good repair”. The Secretary, in consultation with States, Metropolitan Planning Organizations
(MPOs), and other stakeholders, will establish performance measures. States (and MPOs, where
applicable) will set performance targets in support of those measures, and State and metropolitan plans
will describe how targets will be achieved. States and MPOs will subsequently report to DOT on
progress in achieving targets. If reports show inadequate progress, particularly in “key safety
measures”, the State must undertake corrective actions. MAP-21 requires State maintenance of
minimum standards for Interstate pavement and National Highway System (NHS) bridge conditions
(Federal Highway Administration, 2012).

FRS
No FRS identified at this time.

4.1.7.5 Maritime Administration (MARAD)

Background
The Maritime Administration (MARAD) is the agency within the U.S. Department of Transportation
dealing with waterborne transportation. Its programs promote the use of waterborne transportation
and its seamless integration with other segments of the transportation system, and the viability of the
U.S. merchant marine. The Maritime Administration works in many areas involving ships and shipping,
shipbuilding, port operations, vessel operations, national security, environment, and safety. The
Maritime Administration is also charged with maintaining the health of the merchant marine, since
commercial mariners, vessels, and intermodal facilities are vital for supporting national security, and so
the agency provides support and information for current mariners, extensive support for educating
future mariners, and programs to educate America's young people about the vital role the maritime
industry plays in the lives of all Americans.

The Maritime Administration also maintains a fleet of cargo ships in reserve to provide surge sealift
during war and national emergencies, and is responsible for disposing of ships in that fleet, as well as
other non-combatant Government ships, as they become obsolete.

The Maritime Administration recently realigned many of its functions, to revitalize its role as an industry
facilitator, and to bring greater focus to the areas of environment and safety. (U.S. Department of
Transportation Maritime Administration, 2014).

BSEE LCM and Failure Reporting Task 1 Draft Report 37 | Page


LCM

Comprehensive Management Plan for the Disposal of Non-retention Ships


This plan was developed by MARAD’s Ship Disposal Program and is a cost-effective and feasible short
and long-term strategy for the disposal of MARAD’s obsolete ships. Strategy and performance elements
of this plan are updated and presented to the Administrator as a quarterly executive summary of the
Program’s progress and status relative to this plan. The quarterly plan is necessary in order to stay
current with the many variables that affect the selection and award of ships for disposal.

Each Fiscal Year, MARAD will develop an annual installment to the Comprehensive Management Plan
which will reassess MARAD’s progress and all factors affecting the program and revise, if necessary, the
short and long-term strategy and implementation plan for disposal of its obsolete ships.

The MARAD’s disposal strategy is integrated to include critical elements that are considered for both the
long-term disposal strategy and the short-term disposal decisions (National Defense Authorization Act
for fiscal year 2006). These elements include the following:

o Disposal alternatives available to the Program


o Non-retention vessel condition and location
o Environmental threat posed by specific vessels
o Specific proposals received by industry

(U.S. Department of Trasportation Maritime Administration, 2006).

FRS
No FRS identified at this time.

4.1.7.6 National Highway Traffic Safety Administration (NHTSA)

Background
The National Highway Traffic Safety Administration (NHTSA) was established by the Highway Safety Act
of 1970 and is dedicated to achieving the highest standards of excellence in motor vehicle and highway
safety. It works daily to help prevent crashes and their attendant costs, both human and financial.

LCM
No LCM identified at this time.

FRS

Fatality Analysis Reporting System (FARS)


The Fatality Analysis Reporting System (FARS) is a nationwide census providing National Highway Traffic
Safety Administration (NHTSA), Congress and the American public annual data on fatalities suffered in
motor vehicle traffic crashes (National Highway Traffic Safety Administration, 2014).

BSEE LCM and Failure Reporting Task 1 Draft Report 38 | Page


Buses in Fatal Accidents (BIFA)
The Buses in Fatal Accidents (BIFA) database contains records for buses involved in fatal traffic accidents
in the 50 states and the District of Columbia. Data was collected from 1999-2010. The University of
Michigan’s Transportation Research Institute (UMTRI) built on BIFA files starting with FARS cases that
involved trucks and buses (National Highway Traffic Safety Administration, 2014).

Trucks in Fatal Accidents (TIFA)


The Trucks in Fatal Accidents (TIFA) database contains records for all medium and heavy trucks involved
in fatal traffic accidents in the 50 states and the District of Columbia. Data was collected from 1980­
2010. The University of Michigan’s Transportation Research Institute (UMTRI) built on TIFA files starting
with FARS cases that involved trucks and buses (National Highway Traffic Safety Administration, 2014).

4.1.7.7 Pipeline and Hazardous Materials Safety Administration (PHMSA)

Background
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is responsible for establishing
policy, developing safety standards, safety education for the public and first responders and conducting
research in an effort to reduce consequences in the event of a hazardous materials spill or pipeline
incident. PHMSA works to reduce risk of injury, deaths, environmental and property damage and
disruptions to the transportation system. PHMSA’s primary focus is on pipeline and hazardous material
safety.

LCM

Integrity Management
Operators of covered pipeline segments must develop and follow a written integrity management
program that contains all the elements described in 49 CFR 192.911 and that addresses the risks on each
covered transmission pipeline segment. An operator must make continued improvements to the
program. Operators must also follow the requirements of American Society of Mechanical Engineers
(ASME)/ANSI B31.8S and its appendices. An operator must identify and evaluate all potential threats to
each covered pipeline segment, which include, but are not limited to: 1) time dependent threats such as
internal corrosion, external corrosion, and stress corrosion cracking; 2) static or resident threats, such as
fabrication or construction defects; 3) time independent threats, such as third party damage and outside
force damage; and 4) human error. An operator must continue to assess the line pipe at intervals
specified in 49 CFR 192.939 and periodically evaluate the integrity of each covered pipeline segment. An
operator must file any report electronically to PHMSA and must maintain, for the useful life of the
pipeline, records that demonstrate compliance with these requirements.

49 CFR Subpart P contains similar requirements for gas distribution pipeline integrity management (IM).

BSEE LCM and Failure Reporting Task 1 Draft Report 39 | Page


FRS

Incident Reports and Safety Related Condition Reports


Incident Reports and Safety Related Condition Reports are mandated in the industry of transportation of
natural and other gas by pipeline (49 CFR 191).

Mechanical Fitting Failure Report Form, PHMSA F 7100.1—2


Beginning calendar year 2012, section 192.1009 of the pipeline safety regulations (49 CFR parts 190-199)
requires each owner or operator of a gas distribution pipeline facility to file (online) a written report for
any mechanical fitting failure that results in a hazardous leak. Each report must be filed by March 15 of
the following year. Data including the apparent cause of the leak shall be captured (49 CFR 192.1009).

4.1.8 Environmental Protection Agency (EPA)

Background
The mission of the Environmental Protection Agency (EPA) is to protect human health and the
environment (Environmental Protection Agency, 2014).

LCM

Plan to Assess Fracking


The EPA proposed examining every aspect of hydraulic fracturing, from water withdrawals to waste
disposal, according to a draft plan the agency released in February 2011. The study planned to be the
most comprehensive investigation of whether the drilling technique risks polluting drinking water near
oil and gas wells across the nation (Kusnetz, 2011). No public statement regarding LCM in direct relation
to fracking have been identified from the EPA since the above referenced announcement.

FRS

Pollution Incident Reporting


The EPA’s pollution incident reporting requirements are detailed in 33 CFR 153.203, Procedures for the
Notice of Discharge, which is enforced by the U.S. Coast Guard and the EPA, depending on jurisdiction at
the point of discharge/release. For pollution incidents on U.S. navigable waters and their tributaries, the
Coast Guard has jurisdiction; for inland or non-maritime pollution incidents, the EPA has jurisdiction (33
CFR 153.203). Table 1 of this regulation provides contact telephone numbers in the various regions
throughout the U.S. to which pollution accidents and releases shall be reported. Any emergency that
threatens the public health with regards to the release of oil or chemicals, radiological releases or
biological discharges should immediately be reported to the National Response Center (NRC) via
telephone (United States Environmental Protection Agency, 2014). If a person witnesses an apparent
environmental violation, this may be reported via online report (United States Environemental
Protection Agency, 2014). If the reporting source does not have internet access, a report may be filed
by calling the local EPA office.

BSEE LCM and Failure Reporting Task 1 Draft Report 40 | Page


4.1.9 National Aeronautics and Space Administration (NASA)

Background
The National Aeronautics and Space Administration (NASA) is the United States government agency that
is responsible for the civilian space program as well as for aeronautics and aerospace research.

LCM
No LCM identified at this time.

FRS

Aviation Safety Reporting System (ASRS)


In an effort to continue improvement of aviation where government, industry, pilots, air traffic
controllers, flight attendants, mechanics, ground personnel, and others involved in aviation operations
can voluntarily share information about unsafe situations that they have encountered or observed,
NASA has developed an online reporting system where individuals can report any safety related issues.
All reports sent through the system are held in strict confidence; all identifying information about the
submitter is removed before the report is posted. The Aviation Safety Reporting System (ASRS) acts on
the information contained in each report. It identifies system deficiencies, and issues alerting messages
to persons in a position to correct them. It educates through its newsletter CALLBACK, its journal ASRS
Directline and through its research studies. The searchable database is a public repository, which serves
the FAA and NASA's needs and those of other organizations world-wide who are engaged in research
and the promotion of safe flight (Aviation Safety Reporting System, 2014).

Spacecraft Orbital Anomaly Report (SOAR)


The Spacecraft Orbital Anomaly Report system is used for reporting, evaluating and correcting of
problems occurring on-orbit (Practice No. PD-ED-1232).

A positive feedback system for reporting, documenting, collecting, analyzing, and closing orbital
anomaly information on spacecraft is currently managed by Goddard Space Flight Center (Practice No.
PD-ED-1233).

Pre-Flight Problem/Failure Reporting Procedures


A formal procedure is followed in the reporting and documentation of problems/failures occurring
during test, pre-launch operations, and launch operations for both hardware and software (Practice No.
PD-ED-1250).

Problem Reporting and Corrective Action System (PRACAS)


A closed-loop Problem (or Failure) Reporting and Corrective Action System (PRACAS or FRACAS) is
implemented to obtain feedback about the operation of ground support equipment used for the
manned spaceflight program (Practice No. PD-ED-1255).

BSEE LCM and Failure Reporting Task 1 Draft Report 41 | Page


4.1.10 Nuclear Regulatory Commission (NRC)

Background
The Nuclear Regulatory Commission (NRC) is an independent agency of the United States government,
established by the Energy Reorganization Act of 1974, and began operations on January 19, 1975. As
one of two successor agencies to the United States Atomic Energy Commission, the NRC's role is to
protect public health and safety related to nuclear energy. It oversees reactor safety and security,
reactor licensing and renewal, licensing of radioactive materials, radionuclide safety, and spent fuel
management including storage, security, recycling, and disposal.

LCM
No LCM identified at this time.

FRS

Licensee Event Report Search (LERSearch)


In an effort to monitor safety events, all commercial nuclear reactor licensees are required to report
event information per 10 CFR 50.73. The NRC has developed an online reporting system where
licensees can report any Loss of Emergency Preparedness Capabilities, or major loss of emergency
assessment capability, offsite response capability, or communications capability. The Licensee Event
Report Search (LERSearch) allows individuals to search for licensee event reports (LERs) based on a
variety of factors including name, dates, plant characteristics, event characteristics, and abstract or
document keywords (United States Nuclear Regulatory Committee, 2014).

Web-Based Incident Reporting System (WBIRS)


The NRC submits relevant reactor-related generic communications to the international community
through the internet via the Web-Based Incident Reporting System (WBIRS). The reports are coded using
the Incident Reporting System Reporting Guidelines manual, and the full documents are submitted.

4.1.11 National Transportation Safety Board (NTSB)

Background
The National Transportation Safety Board (NTSB) is an independent Federal agency charged by Congress
with investigating every civil aviation accident in the United States and significant accidents in other
modes of transportation – railroad, highway, marine and pipeline.

LCM
No LCM identified at this time.

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FRS

Accident Investigation and Reports


In an effort to determine the probable cause of accidents and issue safety recommendations aimed at
preventing future accidents, the NTSB carries out special studies concerning transportation safety and
coordinates the resources of the Federal Government and other organizations to provide assistance to
victims and their family members impacted by major transportation disasters. The NTSB issues an
accident report following the investigation. These reports are available online for reports issued since
1996, with older reports coming online soon.

Accident Reports are one of the main products of an NTSB investigation. Reports provide details about
the accident, analysis of the factual data, conclusions and the probable cause of the accident, and the
related safety recommendations. Most reports focus on a single accident, though the NTSB also
produces reports addressing issues common to a set of similar accidents (National Transportation Safety
Board, 2014).

4.1.12 1United States Department of Agriculture (USDA)

Background
The mission of the United States Department of Agriculture (USDA) is to provide leadership on food,
agriculture, natural resources, rural development, nutrition, and related issues based on sound public
policy, the best available science, and efficient management (USDA.gov, 2014). The USDA aims to:

o Expand economic opportunity through innovation, helping rural America to thrive;


o Promote agriculture production sustainability that better nourishes Americans while also
helping feed others throughout the world; and
o Preserve and conserve our Nation’s natural resources through restored forests, improved
watersheds, and healthy private working lands (USDA.gov, 2014).

Key activities identified to achieve these goals are to:

o Expand markets for agricultural products and support international economic development;
o Further develop alternative markets for agricultural products and activities;
o Provide financing needed to help expand job opportunities and improve housing, utilities and
infrastructure in rural America;
o Enhance food safety by taking steps to reduce the prevalence of foodborne hazards from farm
to table;
o Improve nutrition and health by providing food assistance and nutrition education; and
o Promote, manage and protect America’s public and private lands working cooperatively with
other levels of government and the private sector (USDA.gov, 2014).

BSEE LCM and Failure Reporting Task 1 Draft Report 43 | Page


LCM

A Treatise on the Application of Life Cycle Management Principles in Agriculture & Biological
Engineering
At the 2009 American Society of Agriculture and Biological Engineers (ASABE) Annual International
Meeting, a particular Meeting Proceeding defined Life Cycle Management as applied in the context of
the USDA:

“Life Cycle Management (LCM) is a systematic approach, mindset and culture that
considers economic, social, and environmental factors among other factors in the
decision making process throughout various business or organizational decisions that
affect both inputs and outputs of a product or service life cycle. It is a product, process,
or activity management system aimed at minimizing environmental and socio-economic
burdens associated with an organization’s product or process during its entire life cycle
and value chain. LCM’s application is gaining wider acceptance both in the corporate
and governmental organizations as an approach to reduce ecological footprints and to
improve the sustainability of human activities. But where and how can it be used in
agricultural engineering applications? This study highlights the potential areas of life
cycle management application in agricultural and biological engineering and how it can
be utilized. The study revealed that life cycle management tools such as design for
environment and life cycle analysis can be used to evaluate the environmental impacts
of – and to improve the products, equipment, and structures produced by agricultural
and biological engineers as well as the processes used to generate them” (Dunmade &
Rosentrater, 2009).

FRS
No FRS identified at this time.

4.2 Domestic State Agencies

4.2.1 Commonwealth of Massachusetts Department of Public Health (MA DHP)

Background
The Massachusetts Department of Public Health (MA DPH) is mandated by State law to "maintain,
protect, and improve the health and wellbeing of the people." To do this, MA DHP is divided into a
central office in Boston, five district health offices and four public health hospitals located throughout
the State, and the State Laboratory Institute. Major health related offices within MA DPH are: Family
and Community Health, Substance Abuse Services, HIV/AIDS, Environmental Health, Communicable

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Diseases, Health Statistics, Hospitals, and Health Quality Systems (Massachusetts Department of Public
Health, 2014).

LCM
No LCM identified at this time.

FRS

Health Care Facility Reporting System (HCFRS)


The Massachusetts Department of Public Health (MA DPH), Bureau of Health Care Safety and Quality
(BHCSQ) tracks and monitors Serious Reportable Events (SRE) and incidents that occur at licensed and
certified health care facilities. The Health Care Facility Reporting System (HCFRS) is a secure and
confidential web-based system developed by experts at MA DPH. The HCFRS provides a single process
for handling the intake and processing of reportable facility incidents and SRE’s for MA DPH (Executive
Office of Health and Human Services Department of Public Health Bureau of Healthcare Safety and
Quality, 2011).

4.2.2 State of California: California State Lands Commission, Other Offices

Background
The California State Lands Commission manages all public state owned land. The Commission has
jurisdiction and management control of certain State lands that were received from the United States
Government in 1850 when California became a state. This Commission manages the economic
development, resource protection, land preservation and land restoration by establishing and enforcing
state regulations.

LCM

Minimum Maintenance Standards and Life Cycle Management Plan


Applicable to all oil and gas production facilities in the state of California are minimum maintenance
standards according to California state law, Article 4.4 (Regulations of Production facilities), subsection
3270(a). Also outlined are the requirements for a well/facility Life Cycle Management Plan (State of
California, 2014).

Mitigation Monitoring, Compliance, and Reporting Program (MMCRP)


The California State Lands Commission, as well as other California state regulatory bodies, requires
organizations seeking permission to develop state infrastructure such as pipeline development, utilities
upgrades and expansions, etc. to apply the Mitigation Monitoring, Compliance, and Reporting Program
(MMCRP). Use of this safety and environmental risk identification, monitoring and reporting process is
required from the initial onset of a project and throughout the life of the project.

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Project Life Cycle Framework
The state of California office of Systems Integration employs an LCM process called the Project Life Cycle
Framework. This framework is used to assist in project management, coordinate project funding and
approval, as well as acquisition and system development. This best practice framework distinguishes
four Life Cycle Process:

o Project Management Life Cycle


o Project Funding Approval Life Cycle
o Acquisition Life Cycle
o System Development Life Cycle

Depending on the project, these Life Cycles may overlap throughout the project from the beginning to
either product or project acceptance or throughout the life of the project to include decommissioning
(State of California, 2010).

FRS

Minimum Maintenance and Failure Reporting


California state law outlines a minimum maintenance and failure reporting requirement. Further
research into the state of California regulatory divisions may yield more specific information about
Failure Reporting programs.

Mitigation Monitoring, Compliance, and Reporting Program (MMCRP)


The California State Lands Commission, as well as other California state regulatory bodies, require
organizations seeking permission to develop state infrastructure such as pipeline development, utilities
upgrades and expansions, etc. to apply the Mitigation Monitoring, Compliance, and Reporting Program
(MMCRP). Use of this safety and environmental risk identification, monitoring and reporting process is
required from the initial onset of a project and throughout the life of the project.

4.3 International Regulators

4.3.1 Australia

4.3.1.1 Australia Asset Management Council

Background
The Australian Asset Management Council is a non-profit organization made up of engineers from
multiple asset management disciplines. The mission of the council is to create an awareness of the
value of asset management, a common understanding of and provide a portal for asset management
resources to asset management practitioners and engineers.

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LCM

Asset Life Cycle Management


Australia has a very comprehensive Asset Life Cycle Management program, developed by the Asset
Management Council and Engineers Australia. Within this program, there are four different models
used: 1) an Optimum Replacement age model, 2) a Repair/Replacement model, 3) an Alternative
Decision Making model, and 4) the Maintenance Strategy Selection model. These models are used to
identify an asset life determination, repair or replace decisions, depreciation values, lost productivity
costs, disposal costs and alternative decision making processes (Thomas, 2005).

FRS
No FRS identified at this time.

4.3.1.2 National Offshore Petroleum Safety and Environmental Management Authority


(NOPSEMA)

Background
Australia’s National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA)
is charged with regulating all offshore areas in Commonwealth waters, as well as designated coastal
waters where functions have been conferred. Jurisdictions where functions to regulate are not
conferred on NOPSEMA remain the responsibility of the relevant state or territory department
(NOPSEMA, 2014).

LCM

Safety Case Life Cycle Management


NOPSEMA’s LCM system is named Safety Case Life Cycle Management. This system is designed to cover
all stages facility life from start-up to decommissioning. The facility operator should be aware of all
stages of the facility’s Life Cycle safety case and should plan for each stage in the process. A Safety Case
may be developed for one or more stages of the process and may cover more than one facility.

FRS

Asset Registry
NOPSEMA’s FRS requires facilities to have an asset registry/safety management system in place. This
system shall have a plan which includes a risk based decision matrix or process that covers maintenance
options such as preventive, predictive and run to failure decision. This program should apply the
Reliability Centered Maintenance (RCM) concept and it should be focused on systems and equipment
with safety concerns and frequent failure possibilities. This is a comprehensive system that is intended
to be developed and structured by individual facilities to meet their specific needs.

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4.3.1.3 Australian Transport Safety Bureau (ATSB)

Background
The Australian Transport Safety Bureau (ATSB) is the national transport safety investigation
organization. The ATSB is Australia’s primary independent investigation organization. ATSB is
responsible for investigating civil aviation, rail and marine accidents, incidents and safety deficiencies.

LCM
No LCM identified at this time.

FRS

Failure Investigations
The Australian Transportation Safety Bureau investigates failures in any mode of transportation such as
airlines, maritime, trains, etc. (Bureau, 2013). The Marine industry uses the Modernized Australian Ship
Tracking and Reporting (MASTREP) system to track all shipping activity but also to report any equipment
failures, accidents resulting in human injuries, groundings, pollution incidents and collisions.

4.3.1.4 Australian Treasury

Background
The Australian Treasury is responsible for managing the Australian National budget. This includes policy
analysis and reform, taxation, micro and macroeconomic policy and reforms as well as regulatory
oversight. The Treasury delivers Commonwealth payments to the State and Territory governments and
supports markets and businesses.

LCM

Total Asset Management / Life Cycle Costing (LCC)


In September of 2004, the Australian Treasury published the Life Cycle Costing (LCC) Guideline. This
guide explains why LCC should be used; what LCC is; distribution of assets over the assets life cycle; and
linkages with Total Asset Management. This guide also describes Modeling Life Cycle Costs and the Life
Cycle Costing process (Thomas, 2005).

FRS
No FRS identified at this time.

4.3.2 Brazil, National Agency of Oil, Gas and Biofuels (ANP)

Background
The National Agency of Oil Gas and Biofuels is Brazil’s regulatory body with regards to the oil sector. It is
linked with the Ministry of Mines and Energy to form the federal impetus of implementing and enforcing
energy regulation.

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LCM
Life Cycle Management programs within the ANP could not be identified from the English-language
sources available at this time. It is recommended that the Organization’s actual official website should
be examined by Subject Matter Expert (SME) who is also proficient in Portuguese.

FRS
Failure reporting systems within the ANP could not be identified from the English-language sources
available at this time. It is recommended that the Organization’s actual official website should be
examined by an SME who is also proficient in Portuguese.

4.3.3 Canada

4.3.3.1 National Energy Board (NEB)

Background
The National Energy Board (NEB or Board) is an independent federal agency that was established in
1959 by the Parliament of Canada to regulate international and interprovincial aspects of the oil, gas
and electric utility industries. The purpose of the NEB is to regulate pipelines, energy development and
trade in the Canadian public interest. These principles guide NEB staff to carry out and interpret the
organization's regulatory responsibilities. The NEB is accountable to Parliament through the Minister of
Natural Resources Canada (National Energy Board, 2014).

LCM

Lifecycle Approach
The NEB uses a lifecycle approach to the management of environmental resources and issues. This
adapts throughout the different stages of a regulated facility, such as the planning and application
phase, the application assessment and public hearing phase the construction and post-construction
phase, the operations and maintenance phase, and the abandonment phase. NEB specialists conduct
audits in order to ensure that these regulations are being upheld (National Energy Board, 2014).

FRS

Pipeline Incident Reporting System


The Pipeline Incident Reporting system for the NEB is described as following:

Incident reporting facilitates the NEB’s oversight assurance that industry is compliant by providing
timely and factual reporting of all incidents. Under the National Energy Board Onshore Pipeline
Regulations (OPR), companies must immediately notify the NEB of any incident that relates to the
construction, operation or abandonment of its pipeline. These reports also serve to highlight, for the
NEB, industry and the Canadian public, the number of environmental and safety incidents related to

BSEE LCM and Failure Reporting Task 1 Draft Report 49 | Page


federally-regulated pipelines. The OPR contains graphs showing the number of incidents occurring
between 2000 and 2013 (National Energy Board, 2014).

Incident includes:

o the death of or serious injury to a person


o a significant adverse effect on the environment
o an unintended fire or explosion
o an unintended or uncontained release of low vapor pressure hydrocarbons (Liquid) in excess of
1.5m3
o an unintended or uncontrolled release of gas or high vapor pressure hydrocarbons
o the operation of a pipeline beyond its design limits

4.3.3.2 Canada-Newfoundland & Labrador Offshore Petroleum Board (C-NLOPB)

Background
The Canada-Newfoundland and Labrador Offshore Petroleum Board (C-NLOPB) exists in order to
interpret and apply the provisions of the Atlantic Accord and the Atlantic Accord Implementation Acts to
all activities of operators in the Newfoundland and Labrador Offshore Area; and, to oversee operator
compliance with those statutory provisions.

In the implementation of its mandate, the role of the C-NLOPB is to facilitate the exploration for and
development of the hydrocarbon resources in the Newfoundland and Labrador Offshore Area in a
manner that conforms to the statutory provisions for: worker safety, environmental protection and
safety, effective management of land tenure, maximum hydrocarbon recovery and value, and
Canada/Newfoundland & Labrador benefits (Canada, Newfoundland & Labrador Offshore Petroleum
Board, 2014).

LCM
No LCM identified at this time.

FRS
No FRS identified at this time.

4.3.3.3 Canada-Nova Scotia Offshore Petroleum Board (CNSOPB)

Background
The Canada-Nova Scotia Offshore Petroleum Board (CNSOPB) is an independent joint agency of the
Governments of Canada and Nova Scotia. It regulates petroleum-related activities in offshore areas near
Nova Scotia. It focuses on efficient and safe exploration and production with regards to Nova-Scotia’s
offshore petroleum resources (Canada-Nova Scotia Offshore Petroleum Board, 2014).

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LCM

Life Cycle Approach


The board assumes a Life Cycle Approach that constitutes multiple activities which are performed within
the resource assessment, exploration, development, production and abandonment phases of a project.
This approach encompasses the totality of the areas of a project life span over which the board exercises
authority over the management of offshore projects near Nova-Scotia (Canada-Nova Scotial Offshore
Petroleum Board, 2014).

FRS

Incident Reporting and Investigation Guidelines


Operators are required to report health and safety, and environmental incidents to the CNSOPB in
accordance with criteria set out in regulations and detailed in the Incident Reporting and Investigation
Guidelines (Canada-Nova Scotia Offshore Petroleum Board, 2014). Reporting requirements include:

o Incident Notification (immediate verbal, immediate written and written notification depending
on the nature of the incident);
o Incident Investigation Reports (due within 21 days of occurrence, all reported incidents are to be
investigated by the operator to determine information such as root cause and actions to
prevent reoccurrence); and
o Quarterly Incident Statistics Reporting (due within 15 days of the end of each quarter, a
statistical accounting of exposure hours, injury/occupational illness incidents, and lost/restricted
workdays in the period).

4.3.4 Denmark, Danish Energy Agency (DEA)

Background
The Danish Energy Agency (DEA) supervises the health and safety aspects of the offshore installations on
the Danish Continental Shelf in the North Sea. DEA has the jurisdiction regarding health and safety on
offshore installations and for certain vessels related to the exploration and production of oil and gas.
Offshore installations are facilities for exploration and production of oil and gas from beneath the
seabed including subsea production wells. Health and safety on fixed and mobile offshore units in the
Danish continental shelf area are regulated by the Danish Offshore Safety Act and regulations issued
under the Act (Ib Larsen, 2013).

LCM

Documentation of Management Plans


For documenting management plans DEA appears to follow European Economic Community (EEC)
Offshore Safety Directives, European Directive 92/91/EEC, and guidelines from Britain’s Health and
Safety Executive (HSE).

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FRS
No FRS identified at this time.

4.3.5 Mexican National Hydrocarbons Commission (CNH)

Background
The Mexican National Hydrocarbons Commission (CNH) was established in 2008. The role of this
organization is to develop policy to assist in managing the hydrocarbon reserves of Mexico. The
Commission approves and governs all exploration and extraction of oil reserves, develops regulations
and supervises compliance of required regulations.

LCM

CNH Data Initiative


Mexico's national hydrocarbons information agency is charged with responsibility for the collection,
management and updating of geological, geophysical and petrochemical data. This information will be
obtained from Mexico's upstream and downstream activities, from exploration and production to
processing and manufacturing (Business News Americas staff reporter, 2014).

FRS
No FRS identified at this time, although the CNH Data Initiative may incorporate failure reporting.

4.3.6 Netherlands, State Supervision of Mines (SSM)

Background
State Supervision of Mines (SSM) is a governmental organization and is situated in The Hague. The
department falls under the ministerial responsibility of the Minister of Economic Affairs. SSM oversees
the compliance with statutory regulations applicable to mineral exploration, extraction, storage and
transport of minerals, focusing on the aspects of health, safety, the environment, and effective
extraction and soil movements.

The NL Oil and Gas Portal provides information about oil, gas and geothermal energy exploration and
production in the Netherlands and the Dutch sector of the North Sea continental shelf. It aims to help
user’s access information furnished by the Dutch government in an easy, comprehensible fashion.

The central government maintains close links with the Netherlands Oil and Gas Exploration Production
Association (NOGEPA). NOGEPA’s Industry Guidelines closely reference Netherland’s legislation and are
available in English (NOGEPA, 2014). NOGEPA Guidelines are copyrighted and require permission to be
reproduced.

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LCM

Asset Integrity Management (AIM)


Asset Integrity (AI) is the ability of an asset to perform its required function effectively and efficiently
whilst protecting Health, Safety and the Environment (HSE) (Netherlands Oil and Gas Exploration
Production Association, 2014). Asset Integrity Management (AIM) is the means to ensure people,
systems, processes and resources that deliver integrity are in place, is use and will perform when
required over the whole lifecycle of the asset.

FRS

Reporting Accident and Incidents, Mining Activities


The Netherlands Oil and Gas Exploration Production Association (NOGEPA) Industry Guideline No. 5
outlines requirements for Reporting Accident and Incidents, Mining Activities (Revised 3/13/2013)
(NOGEPA, 2014) (NL Olie- en Gasportaal, 2014). Reporting of accidents and incidents during the
execution of mining activities has various requirements outlined below.

On what term:

o Immediately
o As soon as possible
o Every month

Who may be required to provide information:

o Employer
o Operator (in the old mining act called “mining company”)
o Manager, e.g. in case of pipelines
o Operator/ contractor1 in case of radiation activities
o Licensee
o The one who manages a collective water facility
o The owner of a collective water facility

Authority / organization to which to submit:

o State Supervision of Mines: the Inspector-General or the civil servants’ inspectors


o The Dutch Coastguard
o Dutch Safety Board
o Inspector for Health Care
o Branch Director
o Chief Inspector for Environmental Hygiene
o Deputy of States
o Minister of Transport, Public Works and Water Management

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4.3.7 New Zealand, Department of Labor

Background
The New Zealand Department of Labor, now known as the Ministry of Business, Innovation and
Employment (MBIE), is responsible for developing policy and regulations and delivering services and
advice in support of the growth of New Zealand. The MBIE has absorbed the functions of four former
New Zealand Government agencies, the Department of Building and Housing, Ministry of Economic
Development, Department of Labor and the Ministry of Science and innovation. As of 01 July 2012, any
inquiries regarding the New Zealand Department of Labor should be addressed to the MBIE.

LCM

Facility Safety Case – Safety Management System (SMS)


According to the New Zealand Department of Labor, the oil and gas industry must comply with
regulations outlined in the Health and Safety Employment (Petroleum Exploration and Extraction)
Regulations 2013. Under these regulations, the Duty Holder of each on and off shore facility must
develop, submit, and receive an accepted Safety Case for a facility. A Safety Case must include, in some
form, an LCM program or process (Part 4) (New Zealand Legislation, 2013). Specifically, within each
Safety Case, there must be a Safety Management System (SMS), which includes a process plan for an
independent competent person to verify that all safety-critical elements of the facility remain effective
(New Zealand Legislation, 2013). The operator must ensure the Design Notice complies with and
contains specific information (Schedule 2, sub-clause 2) (New Zealand Legislation, 2013). However,
specifics about each LCM will vary from facility to facility because the regulations are designed to allow
the Duty Holder and Operator to develop programs based on the specifics of the individual facility.

FRS

Facility Safety Case – Safety Incident Reporting


According to the New Zealand Department of Labor, the oil and gas industry must comply with
regulations outlined in the Health and Safety Employment (Petroleum Exploration and Extraction)
Regulations 2013. Under these regulations, the Duty Holder of each on and off shore facility must
develop, submit, and receive an accepted Safety Case for a facility. Within the required Safety
Management System (SMS) detailed in the Safety Case must be a process for safety incident reporting
(New Zealand Legislation, 2013). Specifics about each FRS will vary from facility to facility because the
regulations are designed to allow the Duty Holder and Operator to develop programs based on the
specifics of the individual facility.

4.3.8 Norway, Petroleum Safety Authority (PSA)

Background
Norway’s Petroleum Safety Authority (PSA) is responsible for developing and enforcing regulations
which govern safety and working environment in the petroleum activities on the Norwegian continental

BSEE LCM and Failure Reporting Task 1 Draft Report 54 | Page


shelf and associated land facilities. The regulations assume that the activities maintain prudent health,
environmental and safety standards. They are developed to be a good tool for the industry and for the
authorities’ supervision. Therefore, the regulations contain a large degree of functional requirements
where standards and norms specify the regulations’ level of prudence.

The PSA is an independent government regulator with responsibility for safety, emergency
preparedness, and the working environment in the Norwegian Petroleum Industry. The regulations and
supervisory system designed by the PSA are implemented with the goal of enhancing the awareness of
companies that they assume total responsibility for operating acceptably (Petroleum Safety Authority,
2014). The regulations put in place by the PSA are key regulations relating to health, safety and the
environment (HSE) in the offshore petroleum industry and at land-based facilities subject to their
supervisory authority. They are divided into regulations designed for the HSE and the working
environment respectively (Petroleum Safety Authority, 2014).

LCM

Individual Facility-Customized LCM Systems


It appears that the law allows for customized LCM systems for individual facilities. For guidance, one
could look at Chapter 9 of the Activities Regulations which addresses maintenance, or Chapters 8 of the
Technical and Operational Regulations which addresses planning, operations and controls during
activities. Other regulatory chapters address design and planning (Petroleum Safety Authority, 2014).
Follow up with our colleagues at Safetech may yield a simple yet descriptive account of LCM systems
used in Norway.

FRS

Registration, Review and Investigation of Hazard and Accident Situations


Section 20 of the Management Regulations in the HSE is labeled “Registration, Review and Investigation
of Hazard and Accident Situations” (Petroleum Safety Authority, 2014). The section guidelines read as
such:

Registration should include a description of the situation, causal relations and the actual or potential
consequence.

The investigation should clarify:

o The actual course of events and the consequences


o Other potential courses of events and consequences
o Nonconformities in relation to requirements, methods and procedures
o Human, technical and organizational causes of the hazard and accident situation, as well as in
which processes and at what level the causes exist
o Which barriers have failed, the cause of barrier failure and which barriers should have been
established, if applicable

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o Which barriers functioned, i.e. which barriers contributed to prevent a hazard situation from
developing into an accident, or which barriers reduced the consequences of an accident
o Which measures should be implemented to prevent similar hazard and accident situations

The investigation shall include actions to combat acute pollution, where relevant.

For hydrocarbon leaks, potential courses of events and consequences should be mapped, regardless of
the ignition probability (Petroleum Safety Authority, 2014).

4.3.9 United Kingdom (UK)

4.3.9.1 Health and Safety Executive (HSE)

Background
The Health and Safety Executive (HSE) is the health and safety regulatory body for Great Britain. The
HSE is responsible for developing, managing and enforcing health and safety regulations. The Health
and Safety at Work etc Act of 1974 is the legislative framework the HSE follows to provide guidance,
training and education and enforcement as it applies to occupational health and safety in Great Britain.

LCM

Ageing and Life Extension Inspection Program (KP4)


The Ageing and Life Extension Inspection Program (KP4 Program) will determine the extent to which
asset integrity risks associated with ageing and life extension are being managed effectively by duty
holders, and will place emphasis on the development and promotion of good practice in the industry to
ensure continued safety (Health and Safety Executive, 2014).

Technical Specialties include:

o Corrosion
o Fire & Explosion
o Structural and Marine integrity
o Process Safety
o Pipelines
o Mechanical
o Electrical, Control & Instrumentation
o Human Factors

BSEE LCM and Failure Reporting Task 1 Draft Report 56 | Page


FRS

Reporting of Injuries, Diseases and Dangerous Occurrences (RIDDOR)


The purpose of 2013 Reporting of Injuries, Diseases and Dangerous Occurrences (RIDDOR) regulations is
to assign duties to employers, the self-employed and people in control of work premises (the
“Responsible Person”) to report certain serious workplace accidents, occupational diseases and
specified dangerous occurrences (near misses) (Health and Safety Executive, 2014).

Complete legislation here: http://www.legislation.gov.uk/uksi/2013/1471/contents/made

Reportable incidents include, but are not limited to:

o Death and injury


o Occupational diseases
o Asthma caused by working conditions
o Cancer
o Carpal Tunnel
o Dangerous occurrences
o Collapse of lifts or lifting equipment
o Complete list here: http://www.legislation.gov.uk/uksi/2013/1471/schedule/2/made
o Gas incidents
o Gas leaking
o Combustion
o Incomplete removal of gases (Health and Safety Executive, 2014)

Within 10 days of the appearance of a significant threat to the integrity of an installation, a written
report shall be made by the duty holder to the HSE (Design and Construction (DCR) Regulation 9, (The
National Archives, 2014)). The report must identify the threat and specify any action taken, or to be
taken, to avert it (Health and Safety Executive, 2014).

The duty holder shall ensure that suitable arrangements are in place for maintaining the integrity of the
installation, including suitable arrangements for:

o Periodic assessment of integrity


o Carrying out of remedial work in the event of damage or deterioration which may prejudice its
integrity (The National Archives, 2014).

4.3.9.2 Oil & Gas UK

Background
Oil & Gas UK is a not-for-profit organization established in 2007. They are the leading representative for
the offshore oil and gas industry in the UK working closely with Government, industry and offshore oil

BSEE LCM and Failure Reporting Task 1 Draft Report 57 | Page


and gas stakeholders. They promote an open dialog for industry to collaborate on technical issues,
safety, environmental, fiscal and training and other industry initiatives.

LCM
No LCM identified at this time.

FRS

Well Life Cycle Practices Forum (WLCPF)


Oil & Gas UK set up the Well Life Cycle Practices Forum (WLCPF) to allow industry members to
communicate information about incidents and best practices (Oil Spill Prevention and Response
Advisory Group, 2011).

The Technical Review Group under the Oil Spill Prevention and Response Advisory Group has
recommended “An ongoing series of workshops should be developed and hosted by Oil & Gas UK, HSE,
and the Department of Energy and Climate Change (DECC) to ensure the continuing education of the
United Kingdom Continental Shelf (UKCS) regulatory requirements. These workshops should inform new
personnel to our area as well as act as a refresher for those personnel requiring it” as part of the WLCPF
(Oil Spill Prevention and Response Advisory Group, 2011).

4.3.10 International Atomic Energy Agency (IAEA)

Background
The International Atomic Energy Agency (IAEA) is an international organization that seeks to promote
the peaceful use of nuclear energy, and to inhibit its use for any military purpose, including nuclear
weapons. The IAEA was established as an autonomous organization on 29 July 1957. The IAEA, though
established independently of the United Nations through its own international treaty and IAEA Statute,
reports to both the United Nations General Assembly and Security Council.

LCM
No LCM identified at this time.

FRS

Incident Reporting System (IRS)


The IAEA/Nuclear Energy Agency (NEA) Incident Reporting System (IRS) was designed as a tool for
exchanging lessons learned from unusual events which occurred in nuclear power plants. The premise is
to use operating experience to improve safety.

Incident Reporting System for Research Reactors (IRSRR)


The Incident Reporting System for Research Reactors (IRSRR) is a system established to collect, analyze,
maintain and disseminate information received from the IAEA participating Member States on unusual
events in research reactors. The objective is to enhance the safety of research reactors through

BSEE LCM and Failure Reporting Task 1 Draft Report 58 | Page


exchange of operating experience, and sharing of information and lessons learned from events as well
as on the actions established to avoid re-occurrence of these events and improve the safety of the
research reactors.

4.4 Industry

4.4.1 Australia

4.4.1.1 Australia Asset Management Council

Background
The Australian Asset Management Council is a non-profit organization made up of engineers from
multiple asset management disciplines. The mission of the council is to create an awareness of the
value of asset management, a common understanding of and provide a portal for asset management
resources to asset management practitioners and engineers.

LCM

Asset Life Cycle Management


Australia has a very comprehensive Asset Life Cycle Management program, developed by the Asset
Management Council and Engineers Australia. Within this program, there are four different models
used: 1) an Optimum Replacement age model, 2) a Repair/Replacement model, 3) an Alternative
Decision Making model, and 4) the Maintenance Strategy Selection model. These models are used to
identify an asset life determination, repair or replace decisions, depreciation values, lost productivity
costs, disposal costs and alternative decision making processes (Thomas, 2005).

FRS
No FRS identified at this time.

4.4.1.2 National Offshore Petroleum Safety and Environmental Management Authority


(NOPSEMA)

Background
Australia’s National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA)
is charged with regulating all offshore areas in Commonwealth waters, as well as designated coastal
waters where functions have been conferred. Jurisdictions where functions to regulate are not
conferred on NOPSEMA remain the responsibility of the relevant state or territory department
(NOPSEMA, 2014).

BSEE LCM and Failure Reporting Task 1 Draft Report 59 | Page


LCM

Safety Case Life Cycle Management


NOPSEMA’s LCM system is named Safety Case Life Cycle Management. This system is designed to cover
all stages facility life from start-up to decommissioning. The facility operator should be aware of all
stages of the facility’s Life Cycle safety case and should plan for each stage in the process. A Safety Case
may be developed for one or more stages of the process and may cover more than one facility.

FRS

Asset Registry
NOPSEMA’s FRS requires facilities to have an asset registry/safety management system in place. This
system shall have a plan which includes a risk based decision matrix or process that covers maintenance
options such as preventive, predictive and run to failure decision. This program should apply the
Reliability Centered Maintenance (RCM) concept and it should be focused on systems and equipment
with safety concerns and frequent failure possibilities. This is a comprehensive system that is intended
to be developed and structured by individual facilities to meet their specific needs.

4.4.1.3 Australian Transport Safety Bureau (ATSB)

Background
The Australian Transport Safety Bureau (ATSB) is the national transport safety investigation
organization. The ATSB is Australia’s primary independent investigation organization. ATSB is
responsible for investigating civil aviation, rail and marine accidents, incidents and safety deficiencies.

LCM
No LCM identified at this time.

FRS

Failure Investigations
The Australian Transportation Safety Bureau investigates failures in any mode of transportation such as
airlines, maritime, trains, etc. (Bureau, 2013). The Marine industry uses the Modernized Australian Ship
Tracking and Reporting (MASTREP) system to track all shipping activity but also to report any equipment
failures, accidents resulting in human injuries, groundings, pollution incidents and collisions.

4.4.1.4 Australian Treasury

Background
The Australian Treasury is responsible for managing the Australian National budget. This includes policy
analysis and reform, taxation, micro and macroeconomic policy and reforms as well as regulatory
oversight. The Treasury delivers Commonwealth payments to the State and Territory governments and
supports markets and businesses.

BSEE LCM and Failure Reporting Task 1 Draft Report 60 | Page


LCM

Total Asset Management / Life Cycle Costing (LCC)


In September of 2004, the Australian Treasury published the Life Cycle Costing (LCC) Guideline. This
guide explains why LCC should be used; what LCC is; distribution of assets over the assets life cycle; and
linkages with Total Asset Management. This guide also describes Modeling Life Cycle Costs and the Life
Cycle Costing process (Thomas, 2005).

FRS
No FRS identified at this time.

4.4.2 Brazil, National Agency of Oil, Gas and Biofuels (ANP)

Background
The National Agency of Oil Gas and Biofuels is Brazil’s regulatory body with regards to the oil sector. It is
linked with the Ministry of Mines and Energy to form the federal impetus of implementing and enforcing
energy regulation.

LCM
Life Cycle Management programs within the ANP could not be identified from the English-language
sources available at this time. It is recommended that the Organization’s actual official website should
be examined by Subject Matter Expert (SME) who is also proficient in Portuguese.

FRS
Failure reporting systems within the ANP could not be identified from the English-language sources
available at this time. It is recommended that the Organization’s actual official website should be
examined by an SME who is also proficient in Portuguese.

4.4.3 Canada

4.4.3.1 National Energy Board (NEB)

Background
The National Energy Board (NEB or Board) is an independent federal agency that was established in
1959 by the Parliament of Canada to regulate international and interprovincial aspects of the oil, gas
and electric utility industries. The purpose of the NEB is to regulate pipelines, energy development and
trade in the Canadian public interest. These principles guide NEB staff to carry out and interpret the
organization's regulatory responsibilities. The NEB is accountable to Parliament through the Minister of
Natural Resources Canada (National Energy Board, 2014).

BSEE LCM and Failure Reporting Task 1 Draft Report 61 | Page


LCM

Lifecycle Approach
The NEB uses a lifecycle approach to the management of environmental resources and issues. This
adapts throughout the different stages of a regulated facility, such as the planning and application
phase, the application assessment and public hearing phase the construction and post-construction
phase, the operations and maintenance phase, and the abandonment phase. NEB specialists conduct
audits in order to ensure that these regulations are being upheld (National Energy Board, 2014).

FRS

Pipeline Incident Reporting System


The Pipeline Incident Reporting system for the NEB is described as following:

Incident reporting facilitates the NEB’s oversight assurance that industry is compliant by providing
timely and factual reporting of all incidents. Under the National Energy Board Onshore Pipeline
Regulations (OPR), companies must immediately notify the NEB of any incident that relates to the
construction, operation or abandonment of its pipeline. These reports also serve to highlight, for the
NEB, industry and the Canadian public, the number of environmental and safety incidents related to
federally-regulated pipelines. The OPR contains graphs showing the number of incidents occurring
between 2000 and 2013 (National Energy Board, 2014).

Incident includes:

o the death of or serious injury to a person


o a significant adverse effect on the environment
o an unintended fire or explosion
o an unintended or uncontained release of low vapor pressure hydrocarbons (Liquid) in excess of
1.5m3
o an unintended or uncontrolled release of gas or high vapor pressure hydrocarbons
o the operation of a pipeline beyond its design limits

4.4.3.2 Canada-Newfoundland & Labrador Offshore Petroleum Board (C-NLOPB)

Background
The Canada-Newfoundland and Labrador Offshore Petroleum Board (C-NLOPB) exists in order to
interpret and apply the provisions of the Atlantic Accord and the Atlantic Accord Implementation Acts to
all activities of operators in the Newfoundland and Labrador Offshore Area; and, to oversee operator
compliance with those statutory provisions.

In the implementation of its mandate, the role of the C-NLOPB is to facilitate the exploration for and
development of the hydrocarbon resources in the Newfoundland and Labrador Offshore Area in a
manner that conforms to the statutory provisions for: worker safety, environmental protection and

BSEE LCM and Failure Reporting Task 1 Draft Report 62 | Page


safety, effective management of land tenure, maximum hydrocarbon recovery and value, and
Canada/Newfoundland & Labrador benefits (Canada, Newfoundland & Labrador Offshore Petroleum
Board, 2014).

LCM
No LCM identified at this time.

FRS
No FRS identified at this time.

4.4.3.3 Canada-Nova Scotia Offshore Petroleum Board (CNSOPB)

Background
The Canada-Nova Scotia Offshore Petroleum Board (CNSOPB) is an independent joint agency of the
Governments of Canada and Nova Scotia. It regulates petroleum-related activities in offshore areas near
Nova Scotia. It focuses on efficient and safe exploration and production with regards to Nova-Scotia’s
offshore petroleum resources (Canada-Nova Scotia Offshore Petroleum Board, 2014).

LCM

Life Cycle Approach


The board assumes a Life Cycle Approach that constitutes multiple activities which are performed within
the resource assessment, exploration, development, production and abandonment phases of a project.
This approach encompasses the totality of the areas of a project life span over which the board exercises
authority over the management of offshore projects near Nova-Scotia (Canada-Nova Scotial Offshore
Petroleum Board, 2014).

FRS

Incident Reporting and Investigation Guidelines


Operators are required to report health and safety, and environmental incidents to the CNSOPB in
accordance with criteria set out in regulations and detailed in the Incident Reporting and Investigation
Guidelines (Canada-Nova Scotia Offshore Petroleum Board, 2014). Reporting requirements include:

o Incident Notification (immediate verbal, immediate written and written notification depending
on the nature of the incident);
o Incident Investigation Reports (due within 21 days of occurrence, all reported incidents are to be
investigated by the operator to determine information such as root cause and actions to
prevent reoccurrence); and
o Quarterly Incident Statistics Reporting (due within 15 days of the end of each quarter, a
statistical accounting of exposure hours, injury/occupational illness incidents, and lost/restricted
workdays in the period).

BSEE LCM and Failure Reporting Task 1 Draft Report 63 | Page


4.4.4 Denmark, Danish Energy Agency (DEA)

Background
The Danish Energy Agency (DEA) supervises the health and safety aspects of the offshore installations on
the Danish Continental Shelf in the North Sea. DEA has the jurisdiction regarding health and safety on
offshore installations and for certain vessels related to the exploration and production of oil and gas.
Offshore installations are facilities for exploration and production of oil and gas from beneath the
seabed including subsea production wells. Health and safety on fixed and mobile offshore units in the
Danish continental shelf area are regulated by the Danish Offshore Safety Act and regulations issued
under the Act (Ib Larsen, 2013).

LCM

Documentation of Management Plans


For documenting management plans DEA appears to follow European Economic Community (EEC)
Offshore Safety Directives, European Directive 92/91/EEC, and guidelines from Britain’s Health and
Safety Executive (HSE).

FRS
No FRS identified at this time.

4.4.5 Mexican National Hydrocarbons Commission (CNH)

Background
The Mexican National Hydrocarbons Commission (CNH) was established in 2008. The role of this
organization is to develop policy to assist in managing the hydrocarbon reserves of Mexico. The
Commission approves and governs all exploration and extraction of oil reserves, develops regulations
and supervises compliance of required regulations.

LCM

CNH Data Initiative


Mexico's national hydrocarbons information agency is charged with responsibility for the collection,
management and updating of geological, geophysical and petrochemical data. This information will be
obtained from Mexico's upstream and downstream activities, from exploration and production to
processing and manufacturing (Business News Americas staff reporter, 2014).

FRS
No FRS identified at this time, although the CNH Data Initiative may incorporate failure reporting.

BSEE LCM and Failure Reporting Task 1 Draft Report 64 | Page


4.4.6 Netherlands, State Supervision of Mines (SSM)

Background
State Supervision of Mines (SSM) is a governmental organization and is situated in The Hague. The
department falls under the ministerial responsibility of the Minister of Economic Affairs. SSM oversees
the compliance with statutory regulations applicable to mineral exploration, extraction, storage and
transport of minerals, focusing on the aspects of health, safety, the environment, and effective
extraction and soil movements.

The NL Oil and Gas Portal provides information about oil, gas and geothermal energy exploration and
production in the Netherlands and the Dutch sector of the North Sea continental shelf. It aims to help
user’s access information furnished by the Dutch government in an easy, comprehensible fashion.

The central government maintains close links with the Netherlands Oil and Gas Exploration Production
Association (NOGEPA). NOGEPA’s Industry Guidelines closely reference Netherland’s legislation and are
available in English (NOGEPA, 2014). NOGEPA Guidelines are copyrighted and require permission to be
reproduced.

LCM

Asset Integrity Management (AIM)


Asset Integrity (AI) is the ability of an asset to perform its required function effectively and efficiently
whilst protecting Health, Safety and the Environment (HSE) (Netherlands Oil and Gas Exploration
Production Association, 2014). Asset Integrity Management (AIM) is the means to ensure people,
systems, processes and resources that deliver integrity are in place, is use and will perform when
required over the whole lifecycle of the asset.

FRS

Reporting Accident and Incidents, Mining Activities


The Netherlands Oil and Gas Exploration Production Association (NOGEPA) Industry Guideline No. 5
outlines requirements for Reporting Accident and Incidents, Mining Activities (Revised 3/13/2013)
(NOGEPA, 2014) (NL Olie- en Gasportaal, 2014). Reporting of accidents and incidents during the
execution of mining activities has various requirements outlined below.

On what term:

o Immediately
o As soon as possible
o Every month

Who may be required to provide information:

o Employer

BSEE LCM and Failure Reporting Task 1 Draft Report 65 | Page


o Operator (in the old mining act called “mining company”)
o Manager, e.g. in case of pipelines
o Operator/ contractor1 in case of radiation activities
o Licensee
o The one who manages a collective water facility
o The owner of a collective water facility

Authority / organization to which to submit:

o State Supervision of Mines: the Inspector-General or the civil servants’ inspectors


o The Dutch Coastguard
o Dutch Safety Board
o Inspector for Health Care
o Branch Director
o Chief Inspector for Environmental Hygiene
o Deputy of States
o Minister of Transport, Public Works and Water Management

4.4.7 New Zealand, Department of Labor

Background
The New Zealand Department of Labor, now known as the Ministry of Business, Innovation and
Employment (MBIE), is responsible for developing policy and regulations and delivering services and
advice in support of the growth of New Zealand. The MBIE has absorbed the functions of four former
New Zealand Government agencies, the Department of Building and Housing, Ministry of Economic
Development, Department of Labor and the Ministry of Science and innovation. As of 01 July 2012, any
inquiries regarding the New Zealand Department of Labor should be addressed to the MBIE.

LCM

Facility Safety Case – Safety Management System (SMS)


According to the New Zealand Department of Labor, the oil and gas industry must comply with
regulations outlined in the Health and Safety Employment (Petroleum Exploration and Extraction)
Regulations 2013. Under these regulations, the Duty Holder of each on and off shore facility must
develop, submit, and receive an accepted Safety Case for a facility. A Safety Case must include, in some
form, an LCM program or process (Part 4) (New Zealand Legislation, 2013). Specifically, within each
Safety Case, there must be a Safety Management System (SMS), which includes a process plan for an
independent competent person to verify that all safety-critical elements of the facility remain effective
(New Zealand Legislation, 2013). The operator must ensure the Design Notice complies with and
contains specific information (Schedule 2, sub-clause 2) (New Zealand Legislation, 2013). However,

BSEE LCM and Failure Reporting Task 1 Draft Report 66 | Page


specifics about each LCM will vary from facility to facility because the regulations are designed to allow
the Duty Holder and Operator to develop programs based on the specifics of the individual facility.

FRS

Facility Safety Case – Safety Incident Reporting


According to the New Zealand Department of Labor, the oil and gas industry must comply with
regulations outlined in the Health and Safety Employment (Petroleum Exploration and Extraction)
Regulations 2013. Under these regulations, the Duty Holder of each on and off shore facility must
develop, submit, and receive an accepted Safety Case for a facility. Within the required Safety
Management System (SMS) detailed in the Safety Case must be a process for safety incident reporting
(New Zealand Legislation, 2013). Specifics about each FRS will vary from facility to facility because the
regulations are designed to allow the Duty Holder and Operator to develop programs based on the
specifics of the individual facility.

4.4.8 Norway, Petroleum Safety Authority (PSA)

Background
Norway’s Petroleum Safety Authority (PSA) is responsible for developing and enforcing regulations
which govern safety and working environment in the petroleum activities on the Norwegian continental
shelf and associated land facilities. The regulations assume that the activities maintain prudent health,
environmental and safety standards. They are developed to be a good tool for the industry and for the
authorities’ supervision. Therefore, the regulations contain a large degree of functional requirements
where standards and norms specify the regulations’ level of prudence.

The PSA is an independent government regulator with responsibility for safety, emergency
preparedness, and the working environment in the Norwegian Petroleum Industry. The regulations and
supervisory system designed by the PSA are implemented with the goal of enhancing the awareness of
companies that they assume total responsibility for operating acceptably (Petroleum Safety Authority,
2014). The regulations put in place by the PSA are key regulations relating to health, safety and the
environment (HSE) in the offshore petroleum industry and at land-based facilities subject to their
supervisory authority. They are divided into regulations designed for the HSE and the working
environment respectively (Petroleum Safety Authority, 2014).

LCM

Individual Facility-Customized LCM Systems


It appears that the law allows for customized LCM systems for individual facilities. For guidance, one
could look at Chapter 9 of the Activities Regulations which addresses maintenance, or Chapters 8 of the
Technical and Operational Regulations which addresses planning, operations and controls during
activities. Other regulatory chapters address design and planning (Petroleum Safety Authority, 2014).

BSEE LCM and Failure Reporting Task 1 Draft Report 67 | Page


Follow up with our colleagues at Safetech may yield a simple yet descriptive account of LCM systems
used in Norway.

FRS

Registration, Review and Investigation of Hazard and Accident Situations


Section 20 of the Management Regulations in the HSE is labeled “Registration, Review and Investigation
of Hazard and Accident Situations” (Petroleum Safety Authority, 2014). The section guidelines read as
such:

Registration should include a description of the situation, causal relations and the actual or potential
consequence.

The investigation should clarify:

o The actual course of events and the consequences


o Other potential courses of events and consequences
o Nonconformities in relation to requirements, methods and procedures
o Human, technical and organizational causes of the hazard and accident situation, as well as in
which processes and at what level the causes exist
o Which barriers have failed, the cause of barrier failure and which barriers should have been
established, if applicable
o Which barriers functioned, i.e. which barriers contributed to prevent a hazard situation from
developing into an accident, or which barriers reduced the consequences of an accident
o Which measures should be implemented to prevent similar hazard and accident situations

The investigation shall include actions to combat acute pollution, where relevant.

For hydrocarbon leaks, potential courses of events and consequences should be mapped, regardless of
the ignition probability (Petroleum Safety Authority, 2014).

4.4.9 United Kingdom (UK)

4.4.9.1 Health and Safety Executive (HSE)

Background
The Health and Safety Executive (HSE) is the health and safety regulatory body for Great Britain. The
HSE is responsible for developing, managing and enforcing health and safety regulations. The Health
and Safety at Work etc Act of 1974 is the legislative framework the HSE follows to provide guidance,
training and education and enforcement as it applies to occupational health and safety in Great Britain.

BSEE LCM and Failure Reporting Task 1 Draft Report 68 | Page


LCM

Ageing and Life Extension Inspection Program (KP4)


The Ageing and Life Extension Inspection Program (KP4 Program) will determine the extent to which
asset integrity risks associated with ageing and life extension are being managed effectively by duty
holders, and will place emphasis on the development and promotion of good practice in the industry to
ensure continued safety (Health and Safety Executive, 2014).

Technical Specialties include:

o Corrosion
o Fire & Explosion
o Structural and Marine integrity
o Process Safety
o Pipelines
o Mechanical
o Electrical, Control & Instrumentation
o Human Factors

FRS

Reporting of Injuries, Diseases and Dangerous Occurrences (RIDDOR)


The purpose of 2013 Reporting of Injuries, Diseases and Dangerous Occurrences (RIDDOR) regulations is
to assign duties to employers, the self-employed and people in control of work premises (the
“Responsible Person”) to report certain serious workplace accidents, occupational diseases and
specified dangerous occurrences (near misses) (Health and Safety Executive, 2014).

Complete legislation here: http://www.legislation.gov.uk/uksi/2013/1471/contents/made

Reportable incidents include, but are not limited to:

o Death and injury


o Occupational diseases
o Asthma caused by working conditions
o Cancer
o Carpal Tunnel
o Dangerous occurrences
o Collapse of lifts or lifting equipment
o Complete list here: http://www.legislation.gov.uk/uksi/2013/1471/schedule/2/made
o Gas incidents
o Gas leaking
o Combustion

BSEE LCM and Failure Reporting Task 1 Draft Report 69 | Page


o Incomplete removal of gases (Health and Safety Executive, 2014)

Within 10 days of the appearance of a significant threat to the integrity of an installation, a written
report shall be made by the duty holder to the HSE (Design and Construction (DCR) Regulation 9, (The
National Archives, 2014)). The report must identify the threat and specify any action taken, or to be
taken, to avert it (Health and Safety Executive, 2014).

The duty holder shall ensure that suitable arrangements are in place for maintaining the integrity of the
installation, including suitable arrangements for:

o Periodic assessment of integrity


o Carrying out of remedial work in the event of damage or deterioration which may prejudice its
integrity (The National Archives, 2014).

4.4.9.2 Oil & Gas UK

Background
Oil & Gas UK is a not-for-profit organization established in 2007. They are the leading representative for
the offshore oil and gas industry in the UK working closely with Government, industry and offshore oil
and gas stakeholders. They promote an open dialog for industry to collaborate on technical issues,
safety, environmental, fiscal and training and other industry initiatives.

LCM
No LCM identified at this time.

FRS

Well Life Cycle Practices Forum (WLCPF)


Oil & Gas UK set up the Well Life Cycle Practices Forum (WLCPF) to allow industry members to
communicate information about incidents and best practices (Oil Spill Prevention and Response
Advisory Group, 2011).

The Technical Review Group under the Oil Spill Prevention and Response Advisory Group has
recommended “An ongoing series of workshops should be developed and hosted by Oil & Gas UK, HSE,
and the Department of Energy and Climate Change (DECC) to ensure the continuing education of the
United Kingdom Continental Shelf (UKCS) regulatory requirements. These workshops should inform new
personnel to our area as well as act as a refresher for those personnel requiring it” as part of the WLCPF
(Oil Spill Prevention and Response Advisory Group, 2011).

BSEE LCM and Failure Reporting Task 1 Draft Report 70 | Page


4.4.10 International Atomic Energy Agency (IAEA)

Background
The International Atomic Energy Agency (IAEA) is an international organization that seeks to promote
the peaceful use of nuclear energy, and to inhibit its use for any military purpose, including nuclear
weapons. The IAEA was established as an autonomous organization on 29 July 1957. The IAEA, though
established independently of the United Nations through its own international treaty and IAEA Statute,
reports to both the United Nations General Assembly and Security Council.

LCM
No LCM identified at this time.

FRS

Incident Reporting System (IRS)


The IAEA/Nuclear Energy Agency (NEA) Incident Reporting System (IRS) was designed as a tool for
exchanging lessons learned from unusual events which occurred in nuclear power plants. The premise is
to use operating experience to improve safety.

Incident Reporting System for Research Reactors (IRSRR)


The Incident Reporting System for Research Reactors (IRSRR) is a system established to collect, analyze,
maintain and disseminate information received from the IAEA participating Member States on unusual
events in research reactors. The objective is to enhance the safety of research reactors through
exchange of operating experience, and sharing of information and lessons learned from events as well
as on the actions established to avoid re-occurrence of these events and improve the safety of the
research reactors.

5. Recommendations and Conclusions


Each program was rated on a Likert-type scale, which measures positive or negative responses to a
certain statement. A Likert scale does indicate people’s positions on various topics, but it can be very
difficult to analyze. The first problem is that the value assigned to a Likert item has no unique
mathematical property. The number associated with each “feeling” is therefore arbitrary and leaves
room for determination by the researcher. There is no relative distance between “strongly agree” and
“agree” that can be defined. The scale is designed to quantify the subjective judgment of each program.

Members of the compilation review team rated each program on a five-part scale on four different
program qualities: Established, Relevance – Safety, Relevance – Environment, and Applicability.

- Established: If the program is in regulations and is currently in use by the agency. Defunct or
hypothetical programs are given a low score.

BSEE LCM and Failure Reporting Task 1 Draft Report 71 | Page


- Applicability: If the program relates to or is easily relatable to the Oil & Gas industry, then the
program would be given a high applicability score.
- Relevance: How much of the program has to do with regulating and mitigating the risks posed to
safety or environmental impacts. Those programs with a direct relationship to safety and the
environment were given a high relevance score.

Instead of ranking each of the eighty-six programs, ABS Consulting scored each of the fifty-three
agencies for use in Tasks 2 and 3. For each agency, a maximum of 20 is the highest score an agency
could obtain. Each agency was reviewed and scored by the review team along these four scores, with
API receiving the highest score of 14.7. Given API’s numerous standards and Recommended Practice,
strong association with the Oil & Gas industry, and the focus on safety and the environment, it makes
sense that this agency would be the highest ranked. Each review team member indicated a preference
for certain agencies, regardless of the rankings that were created. These recommendations matched
fairly well with the top ranked agencies. Causality between the review team members’ preference and
the subjective ranking of the agencies is most likely dependent.

Using the organization provided in Table 1, Table 3 below provides the average ranked score of each
agency, rounded to the first decimal.

Table 3: Agency Review Scores


Ranking
Agency/Organization Acronym Score
Domestic: Federal
Department of Agriculture USDA 5.3
Department of Defense DOD 9.0
Department of Energy DOE 11.7
Department of Health and Human Services DHHS
Centers for Disease Control CDC 8.7
Food and Drug Administration FDA 8.0
Department of Homeland Security DHS
U.S. Coast Guard USCG 14.0
Department of the Interior DOI
Bureau of Land Management BLM 12.0
Bureau of Safety and Environmental Enforcement BSEE 8.7
Department of Labor DOL
Mine Safety and Health Administration MSHA 8.3
Occupational Safety and Health Administration OHSA 11.7
Department of Transportation DOT
Federal Aviation Administration FAA 9.3
Federal Highway Administration FHWA 8.3
Federal Motor Carrier Safety Administration FMCSA 3.3

BSEE LCM and Failure Reporting Task 1 Draft Report 72 | Page


Ranking
Agency/Organization Acronym Score
Federal Rail Administration FRA 7.7
Federal Transit Administration FTA 8.0
Maritime Administration MARAD 8.0
National Highway Traffic Safety Administration NHTSA 7.7
Pipeline and Hazardous Materials Administration PHMSA 12.0
Environmental Protection Agency EPA 13.3
National Aeronautics and Space Administration NASA 7.0
Nuclear Regulatory Commission NRC 11.3
National Transportation Safety Board NTSB 9.3
Domestic: State
Massachusetts Department of Health MA DPH 8.0
California State Lands Commission CSLC 14.3
International
Australia AU
Asset Management Council AMC 6.7
National Offshore Petroleum Safety and Environmental Management Authority NOPSEMA 14.0
Transportation Safety Bureau TSB 9.0
Treasury 5.0
Brazil BR
National Agency of Oil, Gas and Biofuels ANP 7.7
Canada CA
National Energy Board NEB 14.0
Newfoundland & Labrador Offshore Petroleum Board C-NLOPB 7.7
Nova Scotia Offshore Petroleum Board C-NSOPB 12.3
Denmark DK
Danish Energy Agency DEA 9.7
Mexico MX
National Hydrocarbons Commission CNH 8.7
Netherlands NL
State Supervision of Mines SODM 12.7
New Zealand NZ
Controller and Auditor-General Office 4.0
Department of Labour NZ DOL 13.3
Military 2.3
Norway NO
Petroleum Safety Authority PSA 14.0
United Kingdom UK
Health and Safety Executive HSE 12.7

BSEE LCM and Failure Reporting Task 1 Draft Report 73 | Page


Ranking
Agency/Organization Acronym Score
Oil and Gas 13.0
International Atomic Energy Agency IAEA 9.3
International
American Institute of Aeronautics and Astronautics AIAA 5.3
American Petroleum Institute API 14.7
American Waterway Operators AWO 11.0
AMTRAK 7.0
CCD Health Systems 6.7
ConocoPhillips 13.3
Crowley 6.3
ExxonMobil 12.7
Foss 8.3
International Association of Drilling Contractors IADC 10.7
International Organizations for Standardization ISO 13.7
Joy Mining 8.0
ReliaSoft 4.7
SEMATEC 4.3

BSEE LCM and Failure Reporting Task 1 Draft Report 74 | Page


Table 4 below represents the same information as Table 3, but with each agency organized by ranking.

Table 4: Agencies Sorted by Ranked Score


Agency/Organization Acronym
Domestic: Federal
14.0 Department of Homeland Security: USCG DHS
13.3 Environmental Protection Agency EPA
12.0 Department of the Interior: BLM DOI
12.0 Department of Transportation: PHMSA NHTSA
11.7 Department of Energy DOE
11.7 Department of Labor: OSHA MSHA
11.3 Nuclear Regulatory Commission NRC
9.3 Department of Transportation: FAA DOT
9.3 National Transportation Safety Board NTSB
9.0 Department of Defense DOD
8.7 Department of Health and Human Services: CDC DHHS
8.7 Department of the Interior: BSEE BLM
8.3 Department of Labor: MSHA DOL
8.3 Department of Transportation: FHWA FAA
8.0 Department of Health and Human Services: FDA CDC
8.0 Department of Transportation: FTA FRA
8.0 Department of Transportation: MARAD FTA
7.7 Department of Transportation: FRA FMCSA
7.7 Department of Transportation: NHTSA MARAD
7.0 National Aeronautics and Space Administration NASA
5.3 Department of Agriculture USDA
3.3 Department of Transportation: FMCSA FHWA
Domestic: State
14.3 California State Lands Commission CSLC
8.0 Massachusetts Department of Health MA DPH
International
14.0 Australia: NOPSEMA AMC
14.0 Canada: NEB CA
14.0 Norway: PSA NO
13.3 New Zealand: Department of Labour
13.0 United Kingdom: Oil and Gas HSE
12.7 Netherlands: State Supervision of Mines NL
12.7 United Kingdom: HSE UK
12.3 Canada: C-NSOPB C-NLOPB
9.7 Denmark: Danish Energy Agency DK

BSEE LCM and Failure Reporting Task 1 Draft Report 75 | Page


Agency/Organization Acronym
9.3 International Atomic Energy Agency IAEA
9.0 Australia: Transportation Safety Bureau NOPSEMA
8.7 Mexico: CNH MX
7.7 Brazil: ANP BR
7.7 Canada: C-NLOPB NEB
6.7 Australia: Asset Management Council AU
5.0 Australia: Treasury TSB
4.0 New Zealand: Controller and Auditor-General Office NZ
2.3 New Zealand: Military NZ DOL
Industry
14.7 American Petroleum Institute API
13.7 International Organizations for Standardization ISO
13.3 ConocoPhillips
12.7 ExxonMobil
11.0 American Waterway Operators AWO
10.7 International Association of Drilling Contractors IADC
8.3 Foss
8.0 Joy Mining
7.0 AMTRAK
6.7 CCD Health Systems
6.3 Crowley
5.3 American Institute of Aeronautics and Astronautics AIAA
4.7 ReliaSoft
4.3 SEMATEC

BSEE LCM and Failure Reporting Task 1 Draft Report 76 | Page


ABS Consulting recommends that for Tasks 2 and 3, we continue with further analysis of those agencies with a ranked score of 13 or
higher. This would include two domestic federal agencies, one domestic state agency, five international agencies, and two industry
associations. These nine agencies/ organizations represent twenty-two different programs: two programs contain both LCM and FRS
elements, thirteen LCM, and seven FRS programs.

Table 5 below has ABS Consulting’s recommended agencies and programs.

Table 5: ABS Consulting Recommended Agencies for Further Review


LCM or
Agency/Organization Acronym Program FRS
Domestic: Federal
14.0 Department of Homeland Security DHS
U.S. Coast Guard USCG
Casualty Reporting (CASREP) System FRS
Notice of Marine Casualty FRS
Pollution Incident Reporting FRS
13.3 Environmental Protection Agency EPA
Plan to Assess Fracking LCM
Pollution Incident Reporting FRS
Domestic: State
14.3 California State Lands Commission CSLC
Accident Investigation and Reports FRS
International
14.0 Australia AU

National Offshore Petroleum Safety


and Environmental Management Authority NOPSEMA
Safety Case Life Cycle Management LCM
Asset Registry LCM
BSEE LCM and Failure Reporting Task 1 Draft Report 77 | Page
LCM or
Agency/Organization Acronym Program FRS
14.0 Canada CA
National Energy Board NEB
14.0 Norway NO
Petroleum Safety Authority PSA
Individual Facility-Customized LCM Systems LCM
Registration, Review and Investigation of Hazard and Accident Situations FRS
13.3 New Zealand NZ
Department of Labour NZ DOL
Facility Safety Case - Safety Management System (SMS) FRS
Industry
14.7 American Petroleum Institute API
API RP 2D LCM
API RP 2FB LCM
API RP 75 LCM
API Q1 Both
API Q2 LCM
API Q3 Both
API 2C LCM
Life Cycle Management Plan (LMP) LCM
Strategic Approach to International Chemicals Management (SAICM) LCM
Reporting Process Safety Events FRS

13.7 International Organizations for


Standardization ISO
Life Cycle Assessment (LCA) LCM

BSEE LCM and Failure Reporting Task 1 Draft Report 78 | Page


This report approached identification of LCM and FRS programs with a ‘mile wide, inch deep’ mentality
in collecting applicable programs and data. After an initial cursory review of each agency and their
programs, the ABS Consulting review team analyzed and ranked each agency for fit with the guidelines
set forth for Tasks 2 and 3: examination of LCM and the examination of FRS. After identifying the various
agencies across different industries, the recommended agencies for review provide a top level review of
applicability and relevance to BSEE for both LCM and FRS.

The results of our analyses examined diverse options and highlighted several potential programs for
further analysis, as well as other agencies for BSEE review, if desired. In Tasks 2 and 3, we will be able to
identify the specific areas of strengths, benefits, lessons, and development opportunities should BSEE
choose to implement an LCM or FRS for the Oil & Gas industry, or to revive the FIRS with improvements
from the lessons learned from this project.

An LCM and FRS program, if implemented with the lessons learned and best practices, can improve risk
reporting, which should lead to risk mitigation and risk reduction across the industry. Effective LCM and
FRS programs can work to fulfill BSEE’s mission to generate compliance among offshore operators with
BSEE’s regulations to promote safety and protection of the environment.

This report acts as the initial review and selection for further development and specific research into
robust programs that will be further reviewed in Tasks 2 and 3. The information collected in this report
should be utilized at the discretion of BSEE to guide the next steps of this project.

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BSEE LCM and Failure Reporting Task 1 Draft Report 80 | Page


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