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The January 2009 standard provides that each BP facility maintain a risk
register that contains a description of identified risks and the development of an
action plan to manage those risks. It also makes clear that BP entities should seek
to identify where the workforce may have become accustomed to the presence of
429
the risk, or to weaknesses in safety controls.

Former BP executive vice president, James “Kent” Wells summarized the
company’s OMS system as follows:

We have a number of systems. DWOP, for one, gives us guidance. We
have a system that weʹve been working on for the last several years called
OMS, which is our operational management system.

And the purpose of that system is to sort of bring together so weʹre very
systematic and consistent across the whole company the way we expect
things to be done. And it sets out ‐ ‐ we have some standards in there.

And what we do is we use that to set the guidelines for activity we might
do, and then also to work with our contractors that probably already have
their own safety management systems to make sure that we believe their
430
systems are adequate.

As noted by Wells, the requirements in the January 2009 standard were
supplemented by requirements in the DWOP. BP’s DWOP required that BP
employees be present at every well site and that there be adequate procedures in
place to ensure safe drilling operations.

BP’s DWOP also covered the management of risk. Specifically, it
provided that “[a]ll [drilling and completion] operations shall follow a
documented and auditable risk management process to include identification,
431
assessment, prioritization and action.” The DWOP required specific
documentation and stated that the recommended tool for documenting and
managing drilling and completions risk was a web‐based tool called the BP risk
assessment tool (RAT).

429 BP Commitment to Safety Submission.
430 Testimony of James Wells, Joint Investigation Hearing, August 26, 2010, at 23‐24.
431 BP‐HZN‐MBI00130820.

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