BSEE Notification to Black Elk Regarding Safety Measures

During November the Bureau of Safety and Environmental Enforcement issued a latter notifying Black Elk Energy Offshore Operations, LLC (Black Elk) that the company must take immediate steps to improve its safety performance on the U.S. Outer Continental Shelf (OCS). According to BSEE the notification to Black Elk was the result of unacceptable safety performance following numerous incidents involving Black Elk facilities. BSEE gave specific instructions to Black Elk regarding corrective actions that the company should take in order to safety measures up to BSEE standards.

The BSEE letter was mainly the result of the following incidents:

1. The November 16. 2012, incident at Black Elk’s West Delta 32 NE facility, which resulted in loss of life, numerous serious injuries. and harm to the environment.
2. The October 2012 issuance of 45 INC’s by the Lafayette District to Black Elk regarding nine facilities in the South Marsh Island Area in the Gulf of Mexico.
3. Incidents that occurred before November 2012. which include a number of significant safety violations that demonstrate a disregard for the safety of personnel. For example, in October 2011, Black Elk operations involving the use of an acid-based chemical for treating a well at High Island 571A resulted in the hospitalization of six workers.

Specifically, BSEE instructs Black Elk to do the following:

1. Keep all facilities that currently are in a shut-in status in such status until it provides BSEE with documentation of the corrective actions taken to safely return each facility into operational status to BSEE’s satisfaction.
2. Notify the appropriate District Office atleast48 hours prior to returning these facilities to production to allow for the proper BSEE inspection.
3. Immediately cease hot work on its facilities until it demonstrates to BSEE’s satisfaction that steps have been taken, and a safety manager is in place whose responsibility it will be to improve hazard identification, training, and oversight for such operations.
4. Develop a performance improvement plan that at a minimum: a. Provides documentation to BSEE that Black Elk has complied with the requirements of 30 CFR Subpart S; b. Initiates an independent third-party audit of Black Elk’s Safety and Environmental Management Systems (SEMS) program in accordance with 30 CFR 250.1925(a).  Such audits must begin no later than January 31. 2013; and c. Integrates BSEE auditors into the third-pany audit team.
5. Submit the plan and scope of the audit(s) referenced in paragraph 4 above for approval by BSEE no later than December 15,2012.
6. Within 30 days of the BSEE Letter,  Black Elk should provide an analysis of all Incidents of Non-Compliance issued since 2010 identifying patterns and documenting actions taken by Black Elk to change processes or procedures to prevent similar incidents on other facilities.

Source: BSEE