MMS issued NTL 2008-G13, regarding Electronically Stored Records to clarify MMS policy concerning the availability and inspection of electronically stored records and documents, including test records for surface and subsurface safety devices as well as other records related to operations, testing, training, and inspections, including, but not limited to, the following:

• 30 CFR 250.108(e) - Crane records
• 30 CFR 250.301 - Pollution inspection records
• 30 CFR 250.803(b)(1) and (b)(2) - Operating pressure-recorder charts
• 30 CFR 250.1105(d) and (e) - Records of flaring and venting gas and burning liquids
• 30 CFR 250.1203(f)(4) - Measurements or estimates of volumes of gas lost or used
• 30 CFR 250.1205(b)(3) and (4) - Meter site security seal records

If you use a compliance management system and store your test records and other documentation in an Internet-accessible central database or electronic filing system, MMS may recognize this as your official records storage location, if your system meets the following minimum criteria:

• Provides your offshore personnel a means to present the required records to authorized MMS personnel, as needed, in a reasonable amount of time before the conclusion of an onsite inspection
• Includes provisions for backing up data and records at a secure offsite location.
• Includes controls to ensure data integrity and security, including tracking and storing information about those persons who enter and modify data and when any changes are made.
• Provides a summary report containing the applicable information outlined in 30 CFR 250.804.

If you would like MMS personnel to use your electronic compliance management system for records inspection, submit a letter to the MMS regional office requesting approval of an alternate procedure under 30 CFR 250.141. With the request, provide a list of your facilities (in a spreadsheet format) that use a web-based records compliance management system. In the list, include:

• the MMS complex identification number
• OCS area and block number
• facility name
• compliance management system name
• contact name, telephone number, and email address for the MMS GOMR to use to request access

Email your request for alternative compliance and accompanying spreadsheet to eInspections@mms.gov After receiving your request, MMS personnel will contact you at least two weeks prior to your scheduled facility inspection to request URL's, user account names, and passwords to access your records for a specific period of time prior to the onsite inspection. After reviewing the records, MMS may contact you and provide a list of any forms or records that were unavailable, unclear, or problematic. In this case, MMS will expect you to provide the records, corrections, or clarifications during the on-site inspection.

You may limit MMS access to only the pertinent data subject to inspection as required by the regulations.

The NTL is effective July 9, 2008. If you have any questions contact Mr. Tom Machado, Field Operations at (504) 736-2833 or by e-mail at tom.machado@mms.gov or eInspections@mms.gov.

If you need JCC assistance, please contact Cathy Thornton @ 281.578.3388 or cathy.thornton@jccteam.com.