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   OEMM Web Team

MMS enforcement of regulatory requirements of the Fixed Platform Self-Inspection Program is being accomplished through Potential Incidents of Non-Compliance (PINCs). The 27 program-specific PINCs, which were jointly developed by the Coast Guard and MMS, are denoted by the alpha-character “Z” and have enforcement actions ranging from “Warning” to “Component Shut-in” to “Shut-in Facility."

To prepare MMS staff for the assumption of new inspection responsibilities, the Coast Guard developed training modules and conducted classroom training for both district inspectors and engineers in the Gulf of Mexico Region and the Pacific OCS Region. To further ensure consistency in inspection procedures, Coast Guard also conducted on-site training of MMS inspectors. Following all requisite training, MMS began inspection functions on August 30, 2002, in which MMS is conducting either a full inspection of all items on the Fixed Platform Self-Inspection form or a limited inspection of key safety items.

Efforts have been made to ensure consistency in program implementation and to establish procedures for the prompt identification and resolution of problems. MMS compiles biannual reports, based upon inspection statistics reported by MMS District offices, to highlight program progress and areas for improvement. These reports are presented to the Coast Guard’s Assistant Commandant for Marine Safety, Security, and Stewardship by the MMS Associate Director of Offshore Energy and Minerals Management during regular meetings between MMS and the Coast Guard, ensuring program attention at the highest level.

In cases where formal clarification of inspection policy is required, the Coast Guard is publishing guidance documents or instructions that provide additional information on how regulations are being enforced. In all cases where questions about program implementation surface, the Coast Guard and MMS Headquarters and Regional staff work closely in the evaluation of the problem and the recommendation for its solution. The collaborative effort, and the resultant policy guidance, ensures that all inspectors from the MMS and the Coast Guard, as well as the operators, have access to the same regulations and guidelines and thus share a similar understanding of program requirements.