Page 180 - test2

XV. Policies and Practices of Involved Companies

A. BP’s Policies and Practices

The Panel’s investigation found that, at the time of the blowout, BP had a
number of carefully documented policies and practices addressing drilling
operations, change management, safety and risk management.

According to BP, during 2010 it was in the process of implementing a
comprehensive, company‐wide approach to management called the Operating
Management System (“OMS”). OMS was and is intended to “provide a
standardized approach that promotes effective and consistent risk management
across the company.”
424

Under BP’s OMS, local business units are responsible for implementing
their own OMS. BP’s drilling and completions unit in the Gulf of Mexico issued
its local OMS in November 2009. Gulf of Mexico drilling operations are also
425
guided by BP’s DWOP manual and its “Beyond the Best” manual. BP drilling
operations must also follow the Company’s “golden rules” of safety.

1. BP’s Risk Assessment Policies

BP has recognized that “[t]he identification and mitigation of operating
risk is a key element of OMS” and has touted a number of its risk assessment and
management tools. In January 2009, BP issued a company standard on
426
assessment, prioritization and management of risk (January 2009 standard). This
document recognizes that “[i]nconsisent or ineffective identification and
assessment of risk to health and safety of people, the environment and operating
427
performance can create many issues for the organization.” The stated purpose
of issuing the January 2009 standard was to “provide a consistent approach to
risk management to target resources most effectively for continuous risk
reduction.”
428

424 BP Submittal to the National Commission on the BP Deepwater Horizon Oil Spill and Offshore
Drilling, entitled “BP’s Commitment to Safety” (“BP Commitment to Safety Submission”).
425 BP‐HZN‐MBI00208572.
426 BP Commitment to Safety Submission.
427 BP–HZN‐MBI00195284.
428 Id.

175