COVID-19 Information

In discussions between industry groups and agency representatives it is clear that although both sides are working to reduce the impacts of implementing COVID-19 precautions, there will be adjustments to some activities performed. Below is a summary of some recent actions being taken by agencies and industry groups to deal with these impacts. This list is being updated weekly. This page was last updated on 10/26/2020.

Department of Interior

Bureau of Ocean Energy Management (BOEM)

Operating Status

BOEM Headquarters in Sterling, Virginia and the Main Interior Building in Washington D.C. are considered open with maximum telework flexibilities to all current telework-eligible employees.

BOEM Regional Offices at 1201 Elmwood Park Blvd. New Orleans, LA will not accept hand-carried filings/documents until further notice. This action was taken to continue mission-critical functions while keeping staff safe.

Plans and Permit Approvals

The Regional Office is continuing operational activities with maximum telework flexibilities to all current telework-eligible employees. Email, contact information, and more detailed procedures on submissions can be found at https://www.boem.gov/office-leasing-and-plans. Email filings submitted to the sections in the Office of Leasing and Plans after 4:00 p.m. Central Time will be dated the next business day.

Department of Interior

Bureau of Safety and Environmental Enforcement (BSEE)

Operating Status

Bureau staff will be performing the maximum amount of remote / telework possible, although some activities cannot be performed this way. BSEE has identified initial activities that can continue via teleworking and alternate work schedules and which operations require in-person interfacing.

Office Closures

  • Houston Office / Engineering Technology Center Houston, Texas) - 100% telework order in effect
  • New Orleans District Office (New Orleans, Louisiana) - 100% telework order in effect
  • GOM Regional Office (New Orleans, Louisiana) - 100% telework order in effect
The Department of Interior and BSEE are working on return-to-work plans in line with CDC and White House guidance. This would be done in phases and include mitigations such as social distancing and facial coverings. Return to work processes will include some degree of rotation (i.e. “A” and “B” crews alternating time at the office).

Pandemic Management Plans

BSEE has wrapped up the last Performance Based Risk Inspections on Pandemic Management Plans and recently presented its findings (find the presentation in the "Related Links" listed at the bottom of the page). A BSEE Safety Alert will be issued once internal review is completed. The Safety Alert will contain a disclaimer that the SA is subject to change based on CDC recommendations. As there are no requirements in API RP 75 to include these plans in SEMS programs, BSEE did not issue INCs after the reviews. The evaluations are an aspect of BSEE’s pro-active response to the pandemic and are based on BSEE’s performance-based risk inspection process.

The OOC has posted updated and consolidated guidance for operators on "COVID-19 Management Strategies for Offshore Energy Operations (Rev. 5)," that may be useful in preparing Pandemic Management Plans. The document draws on lessons learned from multiple operators and contractors but should be reviewed, considered, and customized as necessary for each organizations' needs. See the OOC COVID-19 website for obtaining these guidelines.

Inspections

BSEE continues to evaluate risks posed by inspections but maintains authority to gain unimpeded access to operator facilities and is performing voluntary mitigations. Drilling inspections have been prioritized over production inspections due to the virus and eRecords inspection protocols have been implemented (see below). BSEE is conducting physical inspections following all screening guidelines for inspectors and is developing methods to facilitate remote / virtual inspections for drilling and production operations. Additionally, the following mitigations have been put in place:

Communications

  • Communicating with facilities prior to flying out for inspections and asking operators to provide details on potential issues (i.e. using OOC "screening and status codes" provided on OOC website). 
  • Requesting that operators provide any specific company screening requirements that exceed BSEE’s requirements when scheduling inspections.
  • Monitoring reports provided by operators via web pages set up by the OOC in their Ryver application to track facility status.
  • Tracking changes in operator screening levels (has observed some moving to lower-level screenings and some higher-level screenings).
Screening Levels
  • Holding ongoing meetings with operators of Level 3 facilities that had cases. The intent is to understand how barriers may be improved, how cases developed, and try to find gaps and best practices. (Posted July 22, 2020)
  • BSEE has implemented protocols and testing for Level 3 screening, which allow BSEE inspectors to inspect Level 3 facilities.
  • Protocols include 7-day quarantining, PCR and serology testing.
  • BSEE reminds operators to contact Bryan Domangue or Lars Herbst when requesting Level 3 inspectors.
  • Issues with differences between BSEE's and operators' Level 3 protocols have been brought to light and additional communications may be planned to discuss an appropriate way forward.
  • BSEE has used Level 3 protocols to facilitate inspections of multiple Level 3 operators.
  • Operator questions or concerns with Level 3 protocols should be brought up with Regional leadership (i.e. Bryan Domangue or Lars Herbst) rather than individual inspectors / districts.
  • BSEE Level 3 inspectors will carry a doctor's letter verifying that they have passed screening protocols.
  • Medically screening inspectors with questionnaires / body temperature verification prior to boarding helicopters. 
Inspection Processes
  • Beginning October 1 the new fiscal year inspections have begun. (Posted October 5, 2020)
  • Some facilities that only received virtual or sample inspections may undergo full annual inspection. This will be based on facility risk. (Posted August 5, 2020)
  • Inspectors performing "records inspections" when they cannot travel offshore. BSEE has provided a list of eRecords to be submitted every Monday on a 7-day cycle to District well operations lead inspectors/supervisory well operations inspectors for digital inspection in lieu of 30-45-day on-site inspections (including IADC reports, BOP test records, and other information). For more information, see the Well Operations eRecords document.
  • DOI solicitors have affirmed Inspection protocols for eRecords and flyby inspections for low-risk assets. Inspectors may return to assets already shut-in to verify they are correctly / safely shut-in. BSEE continuing work toward meeting OCSLA inspection obligations with inspection protocol adjustments.
  • Potential risks / options for adjustments to inspection protocols are based on long-standing policy for inspecting drilling operations every 45 days while production inspections are conducted annually. BSEE wants to hear from operators of any risk reduction measures being taken for well operations.
  • Working with operators and OOC to address issues where access to proprietary records is an issue in order to perform more electronic inspections.
Specific Mitigations / PPE
  • Redaucing exposure vectors for inspectors (i.e. 2 inspectors per helicopter, sanitization logs, skeleton office crews, etc.) and practicing "social distancing".
  • Received and trained with personal protective equipment (PPE) to give inspectors for voluntary use. Inspectors are required to wear gloves and face shields are encouraged when social distancing cannot be maintained (both provided by BSEE).
  • If possible, BSEE inspectors will follow operator protocols for PPE.
  • Although some operators are utilizing N95 masks, BSEE inspectors will not be using N95 masks due to medical screening and fit test requirements, but will utilize facial coverings on a voluntary basis since they are not classified as PPE. Operators utilizing N95 masks should review Subpart O plans to ensure they have required fit testing for individuals that wear the respirators.
  • BSEE noted positively that some operators are using secondary locations to transport personnel impacted by the coronavirus to shore rather than through primary heliports.

Plans and Permit Approvals

Permitting operations can chiefly be accomplished via teleworking although BSEE acknowledges there have been permitting delays due to difficulties visiting the office for mail and large files. Mail continues to be processed on a regular basis, but not as quickly as normal. Paper applications will need to be scanned in by BSEE personnel, which will also not be processed as quickly as during normal operations. Electronic permitting via TIMSWeb and/or eWell will ensure the quickest processing of BSEE applications. BSEE is encouraging and accepting OSRP submittals through e-permits instead of via CD's. Forms will still have to be signed by operator and agent and emailed (scanned versions are accepted).

COVID-19 Reporting

Current Statistics

BSEE has provided guidance to operators in reporting COVID-19 cases as of October 26, 2020. The Gulf of Mexico OCS has reported 424 confirmed cases with 15 cases confirmed in the last 14 days. 51 personnel are PUI in last 14 days from 14 facilities, of which seven are currently green. Total cases are from 75 unique facilities, 52 are production facilities and 23 are well operations. This represents approximately 11 percent of GOM OCS manned facilities. The total cases are from 25 unique operators. There have been no COVID-19 related fatalities offshore in the Gulf of Mexico. This is the 210th day of COVID-19 statistical reporting. 

BSEE is interested in lessons learned from the facilities with confirmed cases to see what failures or gaps exist that have resulted in cases. Companies willing to self-report should do so to Bryan Domangue. BSEE will reach out to facilities to gather this information.

Experience during the pandemic has shown that a large percentage of personnel tested after having close contact with confirmed cases have been asymptomatic. Most have remained asymptomatic as BSEE has followed up with operators. 

PCR Tests have been used to determine recent cases whose facilities were at screening Level 2+. PCR Tests detect the genetic information, (the RNA), of the virus, which is only possible if the virus is present and a patient is actively infected. PCR Tests are recommended by the OOC medical professional workgroup to confirm positive cases (rather than antibody tests).

Evacuation / Positive Case Reporting

In accordance with BSEE incident reporting requirements, those occupational injuries that require or result in evacuation of the injured person(s) by any means from the facility to shore or to another offshore facility for the purpose of receiving medical treatment must be reported. COVID-19 in itself is not deemed to be a occupational injury; however, if the disease is passed along from person to person at the facility, BSEE will define it as occupational. Additionally, if it elevates to a fatality, it will need to be reported immediately. Operators should also notify BSEE of any cases confirmed after personnel return onshore via normal crew change so the facility status can be updated.

Medical treatment means the management and care of a patient to combat disease, disorder, or injury. It does not include:

  • Visiting a physician or other licensed health care professional solely for observation or counseling;
  • Conducting diagnostic procedures, such as x-rays and blood tests and including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils); or
  • Providing first aid (see NTL 2019-N05-BSEE for a complete list of first aid treatments)

Operators should input the notice into the BSEE system and mark it as "Required Evacuation" and "Other event not listed above". Operators should insert "COVID-19" in the text box provided next to "Other event not listed above."

Reporting of COVID-19 case information to the USCG is also required but reporting to BSEE via eWell satisfies USCG requirements (see below). OSHA reporting for medevac of infected personnel is recommended.

BSEE also monitors reports provided via webpages set up by the OOC in their Ryver application. Operators request a page to be created and set up access permissions through the OOC. BSEE monitors these pages each day to see the status of facilities.

Production Reporting

BSEE has provided a Voluntary Production Curtailment Form for voluntarily reporting facility shut ins due to issues related to COVID-19. If this request is made, BSEE would like to know the amount of production that is shut-in to track the impact of the virus on GOM production (similar to hurricane reporting). This is only applicable to COVID-19 related shut-ins (i.e. not applicable to facilities shut-in due to oil prices).

BSEE regulations do allow for officially collecting production curtailment data based on economic impacts or shut-ins outside of hurricane curtailment. BSEE has not published any of the information it has received on production shut-ins and would only be aware of more complete data once OGOR reports are received.

Training

BSEE has established a 60-day grace period for in-house and hands-on training (not remote training) for third-party training providers. BSEE requests that operators contact BSEE with lists of those affected. This does not apply to initial training and BSEE stated that un-trained personnel should not go offshore.

Annual Performance Reviews (APR)

BSEE is aiming for completion of APRs by June 1st for those that are due by the end of May. BSEE has completed some APRs via virtual meetings. Contact BSEE to discuss specific company situations in completing APRs.

U.S. Coast Guard (USCG)

General Updates

USCG is working to continue operations while satisfying response obligations. All staff is teleworking and working "flex hours" to account for limited ability to work online at the same time. USCG is encouraging staff to “self-monitor" and using BSEE contract to screen personnel prior to going offshore. Currently, USCG is averaging 2 inspections per week. USCG inspection personnel are instructed to self-quarantine for 14 days prior to going offshore and are working with operators to get records electronically so time offshore is limited.

Questions on USCG activity for District 8 (D8) should be directed to OCS OCMI CMDR Denning or inspector CMDR Dougherty via email or phone.

  • USCG inspectors will not be moving to Level 3 screening due to resource limitations. Direct all questions regarding screening levels for inspections to OCS OCMI CMDR Denning or inspector CMDR Dougherty.
  • Working on issues with B-1 visas.
  • Still processing letters of determination (LODs).
  • Reviewing “mission essential” work (i.e. illegal fishing) to assist with prioritization.
  • Operators with Certificates of Inspection (COI) or Certificates of Compliance (COC) nearing expiration should call OCS D8 Operations Officer LT Betts to file an application for inspection, as these inspections are a priority for USCG.
  • Operators with Annual Inspections nearing the end of the 90-day window should work with USCG for potential on-deck inspections if possible and will discuss onshore options if necessary due to risks from confirmed COVID-19 cases. USCG will also consider past year's performance in reviewing potential onshore inspections.
  • USCG inspectors are being screened by paramedics prior to flying out for inspections.
  • Recommends being "creative" with muster drills and practicing social distancing.
Inspections and Level 2+ Protocols (Enhanced Social Distancing)
  • USCG’s definition of 14 day quarantine is to minimized contact, but allows for individuals to go get groceries / medicine, etc. w/ social distancing and masks. This does not include putting people in hotels for 14 days before going offshore.
  • Working on a rotating schedule: 1 week on, 1 week off for personnel going offshore and office visits.
  • Performing temperature screens and questionnaires when inspectors go to facility. USCG is willing to do additional temperature screenings and questionnaires offshore if that is the operator’s protocol. However, they have not submitted to blood testing offshore
  • In an effort to be flexible and minimize risk, if the facility is a Level 3 facility, since the USCG is at Level 2+, the USCG wants operator to reach out either directly to inspector, CMDR Dougherty, or OCS OCMI CMDR Denning.

Extensions

  • Evaluating which inspections can be deferred and what extensions can be given.
  • Employing a "common sense approach" to extension requests – operators are encouraged to call to make requests with urgent needs.
  • Reviewing requests for annual lifesaving equipment drills on a case-by-case basis and considering operator protocols in their evaluations.
  • Currently reviewing extensions when certificate of inspection (COI) training is coming due.
  • Allowing operators to self-extend expiration dates through September 30, 2020 for third party surveys normally conducted offshore. Applies to USCG-regulated systems, including inspections for firefighting, lifesaving equipment, crane testing reviewed by the USCG. (Operators expected to continue regular maintenance / inspections completed onboard the facility. See MSIB D8 20-03 Change 1 below.)
Mariner Credentials
  • National Maritime Center (NMC) will launch an email delivery process for renewal examinations allowing mariners to request, complete, and submit renewal examinations. (See NMC notice on “New Email Renewal Examinations” below).
  • Commercial Regulations and Standards and the Office of Merchant Mariner Credentialing provide information regarding the Processing of Mariner Appeals during the COVID-19 Pandemic.

Notifications

  • Requesting notification when personnel exhibit symptoms (see MSIB 02-20 and D8 MSIB 20-02) on facilities they intend to visit or have recently visited. Early guidance required reporting to COTP zones, but clarified that reports already made to BSEE via eWell, do not need to be filed with USCG (see D8 MSIB 20-02).
  • Requesting details on how operators are handling contractors and third-parties accessing their facilities.

Personal Protective Equipment (PPE)

  • USCG is not using N95 masks and do not have plans to use them. Inspectors do have face shields when social distancing cannot be maintained.
  • If additional PPE / mitigations are needed, USCG will discuss with the operator the necessity of the scheduled inspection.
  • USCG is not currently inspecting facilities with requirements for N95 masks. This should be addressed during the inspection request process.
  • USCG has provided FAQs for respiratory protection requirements.

Related Links

U.S. Customs and Border Protection (CBP)

General Updates / Notifications

The CBP would appreciate notification of confirmed COVID-19 cases being transferred onshore from units that would typically provide notification if they were non-coastwise (i.e. drillships attached to OCS are considered coastwise points and CBP would not be alerted). For similar situations on domestic units, CBP would appreciate notification although it is not required.

Department of Transportation


Pipeline and Hazardous Materials Administration (PHMSA)

Related Links

PHMSA Issues Memo on Enforcement Discretion & Guidance to State Partners

Environmental Protection Agency

Operating Status

EPA is taking actions to maintain workforce health and safety while implementing contingency plans to ensure the fulfillment of its responsibilities. The Agency is paying close attention to guidance issued by the Office of Personnel Management (OPM), Centers for Disease Control (CDC) and Prevention, and other federal agencies as well as state and local public health partners.

Following CDC and OPM guidance and specific state guidelines impacting regional offices, EPA’s workforce has been authorized to telework to help prevent transmission of the coronavirus.

Status of “Hard Copy” Submissions to EPA

While in this workforce telework status, there are practical limitations on the ability of staff to collect and respond to "hard copy" mailed queries sent directly to Agency office locations. Until the workforce is able to return to office locations, EPA recommends any mailed correspondence should also be sent via email (to the extent feasible). See the EPA Contact Us page for more information. Note that FOIA requests for EPA records are most effectively submitted through FOIAonline.

Additional Agencies

CDC

WHO

OSHA


STATE AGENCIES

Multi-state COVID-19 Updates 


Texas Railroad Commission


Louisiana Dept. of Environmental Quality

Louisiana Office of The Governor

Alabama Dept. of Environmental Quality

Florida Dept. of Environmental Protection

Industry Groups

Industry Groups and others have created specific COVID-19 websites to provide resources for industry related to their areas of expertise (listed below). Each group continues to work to address pandemic-related issues and expand upon these sites as necessary:

National / Regional

  • API – Provides pandemic information resources to ensure members and industry partners have easy access to critical health and safety information as the outbreak of COVID-19 develops. API is also asking industry to reach out with questions or issues that operators are experiencing, such as whether exemptions are needed for the recent Presidential Proclamation on entry of foreign travelers.
  • NOIA - Provides safety guidance and resources for offshore energy.
  • PESA - National trade association representing the oilfield services and equipment sector provides recommendations and guidance for the offshore industry
  • OOC – Meets daily with regulators and industry to provide continuous updates and documentation on operations from each vantage point. Current documents available for public view include COVID-19 Mitigations for Offshore Energy Operations, Common Screening & Status Codes Document, and COVID-19 Case Management Considerations, Rev. 5 (released September 18, 2020, containing guidance, which includes revised details from the Centers for Disease Control (CDC) on COVID-19 related symptoms, a link to the CDC Self-Checker for screening prior to travel, and details on contact tracing per CDC recommendations).
  • ONG SCC - Represents the private sector interests of the oil and natural gas industry in the public-private partnership. It provides a forum to coordinate oil and natural gas security strategies, activities, policy, and communication across the sector to support the nation’s homeland security mission.
International
  • IADC – Provides information on IADC-related activities and a variety of COVID-19 related resources. IADC drilling reports / records are also being included to facilitate BSEE eRecords reviews that assist with social distancing and continued well operations inspections.
  • IAGC - Provides resources and guidance for geophysical and exploration industry.
  • IMCA – Provides industry guidance and a selection of COVID-19 related safety and operational information resources for industry.
  • IMO – Provides guidance for international maritime issues including circulars on safe crew changes, travel arrangements, sanitization certificates, and other items.

  • IOGP – Provides COVID-19 updates, and industry response and operational impacts due to the Coronavirus. 
  • IWCF – Continues to monitor the developments of the COVID-19 pandemic over recent weeks, responding to local guidance as it has evolved. Additionally, IWCF Well Control Certificates expiring between February 17, 2020 and May 31, 2020, will be extended by 90 days. IWCF will review this decision on May 31, 2020.
  • UN - The UN Global Compact has released a document making recommendations for the global supply change.

State-Specific

  • LMOGA – Provides industry preparedness and response information with a focus on Louisiana.
Industry Sub-group
  • ISOA - Provides resources and guidance for offshore support vessel operators


OSRO Readiness
  • CGA – Clean Gulf Associates remains ready to respond with 100% of response force available and zero positive COVID-19 cases as of 5/11/20. No equipment training events are scheduled through May and anticipate no training through June.
  • MSRC – Marine Spill Response Corporation remains ready to respond with 94% of response force available as of 5/08/20. Additionally, MSRC will be extending their current mitigation approach until June 1, 2020. MSRC plans to take a staggered approach to re-opening some manned sites and offices on June 1, 2020 but will not be conducting any planned deployment training in the month of June.

  • NRCC – The National Response Corporation and its parent company, US Ecology are on standby to implement decontamination measures to combat the spread of COVID-19. The group has established methodologies for handling health crisis from managing previous responses to Ebola, H1N1 and other health crises.
  • Witt O'Brien's – Witt O'Brien's is maintaining continuity of operations, response readiness and capability to support clients.
Classification Societies
  • ABS - Provides guidance for the marine and offshore industry
  • IACS - International Association of Classification Society provides resources for safe shipping and clean oceans

Documents / Announcements (see the websites listed above for documents released by each organization):

Special Report Video


J. Connor Consulting, Inc. Teaming with Industry