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installation; dynamic flow testing of BOP stacks; guidance on ram configuration
on BOP stacks; and improvements in a number of BOEMRE inspection practices.

L. Incidents of Non‐Compliance

During its investigation, the Panel found evidence that BP, and in some
instances its contractors, violated the following regulations in effect at the time of
the blowout:
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 30 CFR § 250.107 – BP failed to protect health, safety, property, and the
environment. BP did not: (1) perform all operations in a safe and
workmanlike manner; or (2) maintain all equipment and work areas in a
safe condition.

 30 CFR § 250.300 – BP, Transocean, and Halliburton (Sperry Sun) did not
prevent conditions that posed unreasonable risk to public health, life,
property, aquatic life, wildlife, recreation, navigation, commercial fishing,
or other uses of the ocean.

 30 CFR § 250.401 – BP, Transocean, and Halliburton (Sperry Sun) failed to
take necessary precautions to keep the well under control at all times.

 30 CFR § 250.420(a)(1) and (2) – BP and Halliburton did not cement the
well in a manner that would properly control formation pressures and
fluids; and prevent the direct or indirect release of fluids from any stratum
through the wellbore into offshore waters.

 30 CFR § 250.427(a) – BP failed to use pressure integrity test and related
hole‐behavior observations, such as pore pressure test results, gas‐cut
drilling fluid, and well kicks to adjust the drilling fluid program and the
setting depth of the next casing string.

 30 CFR § 250.446(a) – BP and Transocean failed to maintain the BOP
system in accordance to API RP 53 section 18.10 and 18.11.

423 This list of violations is based upon the evidence gathered by the JIT during its investigation
and upon the Panel’s findings and conclusions. Additional evidence may reveal further
violations. After this Report is released, BOEMRE will issue Incidents of Non‐Compliance based
upon evidence contained in this Report and/or other relevant evidence.

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