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problems that had been encountered during drilling operations at Macondo; nor
was he given any MOC materials. Sepulvado sent Kaluza a short email on April
16 about rig operations – that was the only information Kaluza received from
Sepulvado prior to starting as well site leader on the Deepwater Horizon.

Kaluza had four years of deepwater drilling experience, but no experience
on the Deepwater Horizon and limited experience with Transocean operations.
The Panel concluded that there was adequate time for Guide to find a more
suitable replacement for Sepulvado or to perform a MOC prior to the date
Kaluza took Sepulvado’s place.

4. Job Transition and Handover Assurance

BP required employees to complete a job transition and handover
assurance form prior to permanent transfer from one job to another. The stated
purpose of this form was “to assure a safe and seamless job transition,” and BP
was supposed to use it “to certify that all accountabilities and expectations are
clear and communicated to all involved and that all performance obligations are
fulfilled.”
447

As part of the job handover process, BP required that the “incumbent”
and the “recipient” review and sign a completed form to certify the transfer of
authority. BP’s procedures stated that the team leader “should sign the form
indicating that handover is complete” (emphasis added). The job transition
448
and handover assurance process steps contradicted BP’s own golden rules of
safety by leaving the review and signature optional. The Panel found evidence
that three of the five job transition and handover assurance forms concerning the
personnel changes in the months preceding April 20 were not fully completed in
accordance with the instructions provided in the document.
449

447 BP‐HZN‐MBI00190164. The form included the following sections: accountabilities and
expectations; transition process; business risks and critical areas of focus; health, safety, security
and environment and crisis management; information transfer; people and organization;
performance monitoring and reporting; external relationships; and communication.
448 Id.
449 During a 2010 reorganization, BP failed to follow its MOC process in the following ways:
Kevin Lacy was replaced by Pat O’Bryan and four items were not checked completed and not
signed (BP‐HZN‐MBI00190161); Brett Cocales’ transition to engineering was not completed (BP‐
HZN‐MBI00190128); and Harry Thierens’ handover of wells director roles and accountabilities to
Dave Rich was not completed (BP‐HZN‐MBI00190128).

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