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from one well to another. The document also sets forth required documentation
including maintenance records, pre/post deployment sign off, and component
condition evaluation. The document also covered the actual maintenance,
overhaul and testing of the subsea equipment. Section 8 of the document
required full function testing of the equipment prior to deployment.

Transocean required two forms to be completed and stored electronically:
a pre‐deployment sign‐off sheet and a component condition evaluation form.
Transocean provided the Panel with three pre‐deployment sign off sheets.
However, Transocean was unable to produce copies of the component condition
evaluation forms or similar documents. 363 Michael Fry, a Transocean equipment
manager, testified about why the component condition evaluation form was not
utilized:

When the subsea maintenance philosophy was originally created, the
thought process behind this form was to establish mean time between
failures and documenting problems that we were having with equipment
that we had failures with. This document wasnʹt really utilized, because
what we ended up doing was the major [original equipment
manufacturers] have forms, like discrepancy forms, that when you send in
a piece of equipment ‐‐ Cameron, for example, uses whatʹs called an FPR
form, I believe itʹs field performance report, …

We felt later on it was best to just have the equipment sent back to the
OEM and let them do a formal investigation of any failures and to have
364
them submit the inspection reports back to us.

Although Fry testified that Transocean relies upon these reports to make
changes to their maintenance and should have ready access to them,the Panel

found that the component condition documentation for the Deepwater Horizon
was kept on the rig, and Transocean did not appear to electronically store the
reports elsewhere. 365

Section 10 of the maintenance philosophy document further explained
that all subsea equipment was subject to an approved 1,825‐day test and
inspection/survey and, for the Gulf of Mexico, the 1,825‐day overhaul was

363 TRN‐USCG_MMS‐00097219.
364 Testimony of Michael Fry, Joint Investigation Hearing, April 6, 2011, at 49‐50
365 Id. at 50.

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