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training program complied with 30 CFR Part 250 Subpart O and that
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Transocean’s training program met the stipulations dictated by BP.

BP, however, did not require the mudloggers monitoring the rig data to be
trained in well control, and such training is not required by Subpart O. The
mudloggers on in the Deepwater Horizon were employees of Sperry‐Sun, a
subsidiary of Halliburton. Halliburton has a well control training program for its
own personnel, but its training program did not require mudloggers to be
trained in well control operations, including kick detection.
415

As noted previously in this Report, the Panel found evidence that BP,
Transocean, and Halliburton violated 30 CFR § 250.401 by failing to take
necessary precautions to keep the Macondo well under control at all times. As
provided in 30 C.F.R. § 250.146, operators and contractors are jointly and
severally liable for the failure to comply with all applicable regulations.

J. Subsea BOP Regulatory Requirements

MMS regulations established certain requirements related to BOP stack
maintenance, testing, recordkeeping and inspections. Some of these regulations
incorporated by reference API Recommended Practices (“RP”), which meant that
compliance with an incorporated API RP was required as directed by the
416
regulation. This section discusses relevant MMS regulations in place at the
time of the blowout.

1. General BOP Requirements

30 CFR § 250.440 required operators to design, install, maintain, test and
use the BOP system and system components to ensure well control. The
working‐pressure rating of each BOP component had to exceed maximum
anticipated surface pressures. The BOP system includes the BOP stack and
associated BOP systems and equipment. BP calculated the Macondo well
maximum anticipated surface pressure (“MASP”) to be 6,153 psi using the well’s
estimated pore pressure at the well’s planned total depth of 20,200 feet. BP also

414 The Panel makes recommendations to improve the regulations at 30 CFR 250.1500 (Subpart O)
relating to well control training.
415 BP‐HZN‐MBI00328704.
416 1 CFR § 51.9(b)(3).

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