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6. BOP Recordkeeping

30 CFR § 250.450. required lessees to record the time, date and results of
all pressure tests, actuation and inspections of the BOP system in the driller’s
report. The lessee was also required to:

 Record BOP test pressures on pressure charts;
 Require onsite representation to sign and date BOP test charts and reports
as correct;
 Document the sequential order of BOP and auxiliary equipment testing
and the pressure duration of each test (subsea BOPs record closing times
for annular and ram BOPs);
 Identify the control station and pod used during the test;
 Identify any problems or irregularities observed during BOP system
testing and record actions taken; and
 Retain all records at the facility for the duration of drilling the well.

Additionally, operators had to maintain complete and accurate records of all well
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activities including records of any significant malfunction or problem.

K. Regulatory Improvements

At the time of the Macondo blowout, MMS did not have a comprehensive
set of regulations specifically addressing deepwater technology, drilling, or well
design. Regulations applicable at that time to both shallow water and deepwater
drilling operations were captured in 30 CFR §§ 250.400‐490 (Subpart D).

As drilling operations have moved into deeper water, operational issues
have become far more complex. This increased complexity demands appropriate
regulatory improvements. The Panel concluded that the regulations in effect at
the time of the Macondo blowout could be strengthened in a number of ways
and that regulatory improvements may have decreased the likelihood of the
Macondo blowout.

The Recommendations section of this Report contains a number of
proposed regulatory improvements that the Panel believes would address the
following areas: cement barriers in high flow potential wells; negative test
procedures; specific cementing requirements; guidance on lock‐down sleeve

422 30 CFR § 250.466.

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