This paper examines the health and safety (H&S) landscape of offshore oil and gas exploration, with a focus on the Bureau of Safety and Environmental Enforcement (BSEE) and its Safety and Environmental Management System (SEMS) regulatory framework. It identifies major occupational health risks faced by offshore workers — including dermatitis, chemical inhalation, noise exposure, and psychosocial hazards — and traces the origins of SEMS to the industry's own Safety and Environmental Management Program (SEMP). The paper outlines SEMS's general and specific regulatory requirements, defines key roles and responsibilities, and reviews the enforcement tools available to BSEE, including non-compliance notices, probationary proceedings, disqualification, and civil penalties. Implementation costs and training obligations are also briefly discussed.
The United States meets a significant portion of its energy demand from oil and gas reserves situated in the Gulf of Mexico, Alaska, and the Pacific. There are high stakes involved in the oil and gas industry, both financially and strategically. Major risks are faced by those who work directly at offshore exploration sites. The health and safety of workers at rigs, wellheads, and key operational sites remain a challenging task for exploration companies and regulatory bodies alike. The remoteness of these sites is a significant barrier to providing assisted backup medical and safety services. Locational barriers arise because exploration wells are often located in deep-water areas ranging from Arctic to tropical weather conditions.
Many hazards — including physical, chemical, ergonomic, and psychological hazards — pose serious threats to the health of employees working at offshore oil and gas exploration sites. The International Labour Organization (ILO) identified these hazards more than 20 years ago, and since then employers along with state and federal governments have been expected to minimize and mitigate health and safety risks in the sector. Various chemical hazards include exposure to hydrogen sulphide, welding fumes, acids, and chemical coatings. Mechanical hazards involve exposure to heavy machinery at offshore sites. Physical hazards are those related to thermal extremes. Psychological health hazards stem from working in isolation and for long hours (Gardner, 2003).
The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) was formed in 2011 following the tragic incident on April 20, 2010, in which 11 workers died aboard the Mobile Offshore Drilling Unit (MODU) at Deepwater Horizon. This disaster resulted in an oil spill at the Macondo well managed by British Petroleum (BP) in the Gulf of Mexico. The Bureau of Safety and Environmental Enforcement (BSEE) and the Bureau of Ocean Energy Management (BOEM) were subsequently formed after BOEMRE was dissolved. Regulations and enforcement policies are devised and implemented by BSEE. Lately, there has been criticism over BSEE's role in limiting the involvement of the Coast Guard (CG) and the Occupational Safety and Health Administration (OSHA) in monitoring and regulating offshore oil and gas industry compliance with employee health and safety requirements.
The major area in which BSEE is expected to ensure compliance and initiate enforcement proceedings is the Safety and Environmental Management System (SEMS). In order to mitigate health and safety risks associated with offshore oil and gas exploration activities, the SEMS program serves as an industry-wide process safety standard. It was initially developed by the oil and gas exploration industry as the Safety and Environmental Management Program (SEMP) in 1993 and was also published by the American Petroleum Institute (API) in 2004 under the same title. The following sections provide an overview and explanation of the program's requirements.
Several health risks have long been identified and associated with working conditions at offshore oil and gas sites. Inhalation risks arising from hazardous substances are the most commonly reported health incidents. Dermatitis is another major health risk for personnel working at wells and rigs. Due to the nature of structures at oil fields and rigs, noise- and vibration-related harm to workers' hearing has also been widely reported (Gardner, 2003). Physical health along with the psychosocial well-being of offshore workers is said to be negatively impacted when health and safety (H&S) is neglected at these sites (Ross, 2009).
Atkinson et al. (2008) conducted empirical research on shift workers and concluded that shift work generally decreases opportunities for physical exercise. This is especially true for offshore oil and gas industry workers and negatively impacts their physical and mental well-being. As Mearns and Yule (2009) have noted, the risk to the health and safety of offshore oil and gas industry workers is a universal challenge, not limited to the United Kingdom or the United States alone.
The Safety and Environmental Management Program (SEMP) — later formalized as SEMS — is a broad framework that can be used by offshore oil and gas exploration companies to ensure compliance with optimal standards of worker safety and field operations. The program pertains to safety in oil, gas, and sulfur operations on the Outer Continental Shelf (OCS). The SEMS regulation adopted in 30 CFR 250 by BSEE covers well workover, drilling, construction, Department of Interior (DOI) pipeline services, well servicing, and well completion (AcuTech, 2012). The program outlines operating and design requirements followed by a hazard analysis guideline. The BSEE SEMS regulation adopted in 2010 makes it mandatory for oil, gas, and sulfur exploration firms to fully adopt the 2004 API publication "Recommended Practice for Development of a Safety and Environmental Management Program," reaffirmed in 2008 (API, 2012).
The general requirements of SEMS apply to well and rig lessees, operating owners, contractors, and subcontractors. By virtue of the SEMS program, all contractors and subcontractors are tasked with maintaining safety policies and procedures in written format at all times during operations. Foremost among the general requirements is the provision of the best available and safest machinery for drilling purposes. During drilling, monitoring and evaluation must be carried out to ensure that oil or gas wells do not kick or flow. It is also a general requirement that operating owners must "assess, address, and manage safety, environmental hazards, and potential health impacts during (i) design, (ii) construction, (iii) start-up of operations, monitoring, and maintenance of all facilities." A representative of the lessee, operating owner, contractor, or subcontractor must be present at all times to fulfill the responsibilities established by the SEMS program.
In the context of rig and well operations, the general requirements specify that unless a drilling site is secured with bridge plugs, blowout preventers (BOPs), and cement plugs, adequate human surveillance should be maintained by deploying a tool pusher or operator's representative at the rig floor. Subpart O of the SEMS regulation was made mandatory for training of deployment staff at the rig floor. Maintenance of materials and equipment for personnel security and safety is also required ("Code of Federal Regulations," 2012). During maintenance or securing procedures, the application of downhole safety devices is required of operators. Drilling must be interrupted if any of the following events occur: (i) evacuation of crew, (ii) displacement of rig location, or (iii) repair or maintenance of the rig. Operating entities are also required to report to the district manager regarding the arrival of a MODU on site, movement of a platform rig, and departure of a MODU, among other sub-requirements. Form BSEE-0144 is to be used for MODU movement notifications in the Gulf of Mexico OCS region ("Code of Federal Regulations," 2012).
Director: The Director of the Bureau of Safety and Environmental Enforcement (BSEE) of the U.S. Department of the Interior — or a person authorized to act on behalf of the Director — is responsible for the overall execution of BSEE operations in the Outer Continental Shelf (OCS). The Director is also responsible for preventing injury or loss of life from exploration operations. Cooperation and consultation with affected states is also part of the Director's responsibilities.
Regional Director: A Regional Director is an officer of BSEE holding authority and responsibility for a region within BSEE's jurisdiction. The Regional Director is responsible for executing policy and strategies under the supervision of the Director and reports directly to the Director.
District Manager: A District Manager (DM) is an officer of BSEE who holds authority and responsibility over a district within BSEE's jurisdiction. The DM is responsible for ensuring compliance with BSEE regulations, including site operational requirements and specifically the SEMS regulation.
Operator: The operator may be an individual, firm, corporation, or partnership that controls all or part of the management of a leased portion of oil and gas exploration in the OCS. The operator may also be a BSEE- or BOEM-approved agent of the lessee or holder of operating rights in the leased area. The operator's major responsibilities include the management of operations at wells, rigs, and offshore jurisdictions under lease.
Lessee: A lessee is a person, corporation, or executive entity that holds the right of ownership under a lease agreement duly executed with the United States Government (USG) and pays royalty against the lease agreement to the USG. The lessee's responsibilities include meeting performance metrics related to the SEMS regulation as outlined by BSEE.
"BSEE director, operator, lessee, and personnel duties"
"SEMS regulatory titles, enforcement tools, and penalties"
"Training mandates, implementation costs, and management benefits"
Offshore oil and gas exploration involves working conditions that are isolated, making it difficult to obtain and maintain the highest quality of data related to health and safety risks posed by the environment in which employees work. However, many researchers have investigated the adverse impacts that such isolated conditions create on the health and safety of workers. Dermatitis, noise and vibrations, contamination from chemicals, inhalation of hazardous substances, injury from handling heavy materials, and loss of life are not uncommon in the industry.
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