Recent Recommendation Status Updates

Open: 0% | Closed: 100%

Final Report Released On: April 20, 2016

2010-10-I-OS-3

Publish an offshore exploration and production safety standard for the identification and effective management of safety critical elements (SCEs)— technical, operational, and organizational— with the goal of reducing major accident risk to As Low As Reasonably Practicable (ALARP), including but not limited to:
a. development and implementation of a SCE management system that includes the minimum necessary “shall” requirements in the standard to establish and maintain effective safety barriers to prevent major accidents;
b. methodologies for (1) the identification of SCEs and (2) the development of performance standards of each SCE, including its functionality, availability, reliability, survivability, and interactions with other systems;
c. establishment of assurance schemes for continuous active monitoring of all identified SCEs throughout each SCE’s lifecycle;
d. fulfillment of independent verification requirements and use of those verification activities to demonstrate robustness of the SCE management process;
e. development of process safety key performance indicators pertaining to the effective management of SCEs to drive continuous improvement.

Status: Closed - Acceptable Alternative Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: April 20, 2016

2010-10-I-OS-1

Augment 30 C.F.R §250 Subpart S to require the responsible parties, including the lessee, operator, and drilling contractor, to effectively manage all safety critical elements (SCEs)— technical, operational, and organizational—thereby ensuring their effective operation and reducing major accident risk to As Low As Reasonably Practicable (ALARP).  At a minimum, require the following improvements:

a. Written identification of all safety critical elements for offshore operations through hazard analysis. This list will be made available for audits and inspections performed by the responsible parties, external entities (e.g., independent competent parties, third-party auditors), and the regulator, and it will be shared among the lessee, operator, and drilling contractor. Identifying all safety critical elements shall ensure the establishment and maintenance of effective safety barriers to prevent major accidents;

b. Documented performance standards (as defined in Section 5.2 of the CSB Macondo Investigation Report Volume 2) describing the required performance of each SCE, including its functionality, availability, reliability, survivability, and interactions with other systems;

c. Augmentation of 30 C.F.R §250.1916 to include requirements for all responsible parties, including contractors, to conduct monitoring for continuous active assurance of all identified SCEs through each SCE’s lifecycle (as described in Section 5.0 of the CSB Macondo Investigation Report Volume 2);

d. Documented independent verification scheme for the identified SCEs reported to and subject to review by the regulator (as described in Section 5.5 of the CSB Macondo Investigation Report Volume 2), where:

1. the independent party meets BSEE criteria that guarantees its competence and independence from the company or facility for which it is providing verification;
2. the independent verification occurs prior to commencement of the offshore drilling or production activity and periodically, as defined by BSEE;
3. all resulting assessments of the independent verification activities will be tracked in a formal records management system; and
4. corrective action shall be taken to address negative verification findings and non-compliance. Verified noncompliance shall be tracked by the responsible party as a process safety key performance indicator and be used to drive continuous improvement.

Status: Closed - Acceptable Alternative Action
Recommendation Status Change Summary

2010-10-I-OS-2

Publish safety guidance to assist the responsible parties in fulfillment of regulatory obligations stipulated in R1 for the identification and effective management of safety critical elements (SCEs)—technical, operational, and organizational— with the goal of reducing major accident risk to As Low As Reasonably Practicable (ALARP), including but not limited to each of the identified minimum requirements (See R1, items a-d).

Status: Closed - Acceptable Alternative Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: April 20, 2016

2010-10-I-OS-11

Revise and augment the offshore safety regulations, including the SEMS Rule (C.F.R. 250 subpart S), and issue guidance as it relates to those revisions/augmentations, to:
a.    Establish clear and consistent safety and environmental management responsibilities to prevent major accidents for the companies having primary control over the hazardous activities being undertaken (e.g., the owner/drilling contractor for a non-production installation and the leaseholder/operator for the production installation);
b.    Require all responsible parties as defined in R11(a) to develop documentation for each hazardous operation/facility it maintains primary control over, where the documentation demonstrates the party’s systematic analysis that risks posed by all identifiable major accident hazards are reduced to As Low As Reasonably Practicable (ALARP) or similar risk-reduction target. The documentation shall include:
1.    Identification of major hazards and the barriers and safety management systems controls (including augmented SEMS elements) that will be used to reduce risk to ALARP or similar risk reduction target;
2.    Use of the hierarchy of controls to the greatest extent feasible in establishing safety barriers and controls;
3.    Identification of safety critical elements and tasks to establish and maintain safety barriers and controls, in fulfillment of R1 (See Volume 2);
4.    Demonstrate use of established qualitative, quantitative and semi-quantitative methods in determining (1) the barriers and safety management systems necessary to achieve ALARP risk reduction levels and (2) the performance requirements of those barriers and controls (e.g., reliability, functionality, and availability) to ensure their effectiveness;
5.    Identification of all US and international standards that have been applied, or will be applied, in relation to the facility, hazardous operation, or equipment used on/in connection with the operation for which required documentation is submitted. Should the responsible party wish to use standards other than well-recognized US or international consensus safety standards developed by a representative committee of diverse stakeholders, a detailed technical justification that those standards achieve risk-reduction to ALARP must accompany submitted documentation. The regulator may challenge or reject the technical justification. Remove from the US offshore safety regulatory scheme the provisions that allow companies to substitute requirements to use the best available and safest technology with a showing of compliance with BSEE regulations.
c.    Require responsible parties as defined by R11(a) to fully implement all aspects of the documentation stipulated in R11(b) and establish a documented process to verify that all methods to manage, reduce, and control those hazards are effectively maintained throughout the lifecycle of the operation/facility.

Status: Closed - Acceptable Alternative Action
Recommendation Status Change Summary

2010-10-I-OS-12

Augment the capabilities and functioning of BSEE to incorporate the following proactive oversight mechanisms:
a.    Review of the documentation required to be submitted under CSB 2010-I-OS-R11(b) by technically qualified regulatory personnel who have the capability and authority to require modifications and improvements to the major hazards report as necessary, either before an acceptance process and commencement of the major hazards operation(s) or during periodic proactive review by the regulator;
b.    Establish a program for preventive, comprehensive inspections and audits with technically qualified staff as described in R13(a) to ensure that the responsible party as defined in R11(a) can demonstrate the risk reduction commitments stipulated in its major hazards report.

Status: Closed - Acceptable Alternative Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: December 21, 2022

2018-03-I-TX-5

Review the Center for Chemical Process Safety guidance on recognizing catastrophic incident warning signs and then develop and implement a program for the EVAL Plant that incorporates warning signs into its safety management system.

Status: Closed - Acceptable Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: December 11, 2023

2021-03-I-GA-1

Include in the emergency action program provisions for proactively interacting with and informing local emergency response resources of all emergencies at the former FFG Plant 4 facility to which Gold Creek expects them to respond. At a minimum, Gold Creek should:

a) inform local emergency responders of the existence, nature, and location of hazardous substances at its facilities, including liquid nitrogen;

b) inform local emergency responders of the location of emergency-critical equipment such as bulk storage tanks, points of use, isolation valves, E-stop switches, and any other emergency equipment or systems with which emergency responders may need to interact; and,

c) provide local emergency responders with information, such as facility plot plans, engineering drawings, or other information needed to mount an effective emergency response.

Status: Closed - Acceptable Action
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: May 25, 2023

2021-05-I-TX-5

Revise API Standard 599 Metal Plug Valves—Flanged, Threaded, and Welding Ends as follows:

a. State that there have been multiple incidents in which workers have inadvertently removed pressure-retaining components from plug valves while workers were attempting to remove the valve’s actuator or gearbox.

b. Recommend that facilities using plug valves establish written procedures detailing the correct way to remove the plug valve actuator or gearbox for each specific plug valve design at the facility.

c. For existing plug valves, require facilities to clearly mark all pressure-retaining components (for example, with paint, accompanying warning signs, etc.). Work with ASME and VMA to ensure a consistent methodology is specified across both API and ASME standards.

d. Require that new plug valves be designed, consistent with Prevention through Design principles, to prevent the inadvertent removal of pressure-retaining components when removing the actuator or gearbox. Evaluate past plug valve incidents, and the associated plug valve designs involved in those incidents, when formulating a new plug valve design. Work with ASME and VMA to ensure a consistent methodology is specified across both API and ASME standards.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: July 06, 2023

2019-01-I-TX-6

Update API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities, or other appropriate products to include flammable gas detection systems within the leak detection section or where appropriate. The discussion of flammable gas and/or leak detection should address both engineering and administrative controls, including actions associated with responding to a catastrophic or emergency leak.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: December 29, 2022

2018-02-I-WI-15

Incorporate lessons learned from the FCC Unit Explosion and Asphalt Fire at Husky Superior Refinery incident into the appropriate API products (for example, API RP 2023, Guide for Safe Storage and Handling of Heated Petroleum-Derived Asphalt Products and Crude Oil Residua, or API RP 2021, Management of Atmospheric Storage Tank Fires). At a minimum, topics shall include the flammability of heated material such as asphalt and the ignition risk of pyrophoric material inside asphalt storage tanks. Include a reference to this CSB investigation in the document’s bibliography.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: June 03, 2025

2024-01-I-TN-4

Include physical, protective barriers as part of the standard design for liquid nitriding processes. These protective barriers shall be intended to isolate employees from molten salt releases.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-5

Develop a safety management system that incorporates industry guidance and includes, but is not limited to:

a. A hazard analysis program for assessing the nitriding process. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety, the National Fire Protection Association’s (NFPA) Standard for Ovens and Furnaces, and ASM International’s Handbook. The program shall apply to new and existing parts, assess parts for accumulation hazards and sealed cavities, and include non-routine tasks such as reprocessing unsatisfactory parts.

b. Written operating procedures for the nitriding process. The procedures shall be based on the information gathered from the hazard analysis program. The procedures shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Writing Effective Operating and Maintenance Procedures.

c. A training program, including written materials, for the employees involved in the nitriding process. This program shall be based on the nitriding facility’s operating procedures and other relevant information from the hazard analysis program. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety.

d. An incident investigation program. This program shall include requirements for performing causal analysis, producing written reports, and communicating findings and corrective actions throughout the entire HEF Groupe organization. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Investigating Process Safety Incidents.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-6

Develop and implement an effective and comprehensive Knowledge Management program for sharing knowledge throughout the HEF Groupe organization. Knowledge shall include all information from audits, hazard analyses, and incident investigations, including causal analyses and corrective actions recommended and taken. This program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Process Safety Knowledge Management.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-7

Develop and implement a comprehensive and effective Corporate Governance program. This program shall include regular audits of subordinate facilities throughout the organization, with tracking and accountability for implementation of all recommendations and corrective actions identified in the audits. Facility adherence to the safety management system recommended above shall be evaluated during the audits. The program shall require documentation of audit findings, prompt responses to deficiencies, development of corrective actions, and implementation of the corrective actions throughout the organization. This program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Implementing Process Safety Management.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: June 03, 2025

2024-01-I-TN-1

Implement physical, protective barriers around the molten salt baths that isolate employees from hazardous releases at all locations that perform liquid nitriding.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-2

Develop a safety management system that incorporates industry guidance and includes, but is not limited to:

a. A hazard analysis program for assessing the nitriding process. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety, the National Fire Protection Association’s (NFPA) Standard for Ovens and Furnaces, and ASM International’s Handbook. The program shall apply to new and existing parts, assess parts for accumulation hazards and sealed cavities, and include non-routine tasks such as reprocessing unsatisfactory parts.

b. Written operating procedures for the nitriding process. The procedures shall be based on the information gathered from the hazard analysis program. The procedures shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Writing Effective Operating and Maintenance Procedures.

c. A training program, including written materials, for the employees involved in the nitriding process. This program shall be based on the nitriding facility’s operating procedures and other relevant information from the hazard analysis program. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety.

d. An incident investigation program. This program shall include requirements for performing causal analysis, producing written reports, and communicating findings and corrective actions throughout the entire TS USA organization. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Investigating Process Safety Incidents.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary

2024-01-I-TN-3

For each TS USA facility, establish a position with specific professional expertise and experience in safety management systems, such as risk-based process safety. This position shall be responsible for TS USA’s safety management system, ensuring that HEF Groupe’s safety information is incorporated at the site level, and implementing regulatory and industry safety guidance.

Status: Open - Awaiting Response or Evaluation/Approval of Response
Recommendation Status Change Summary