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incentives were 50% “discretionary” factors, 37.5% cost related items and 12.5%
safety performance.

The Panel found no evidence that decisions by Transocean personnel to
defer rig maintenance and/or down time were directly rewarded with any type
of bonus payment. However, Transocean’s policy of rewarding personnel based
upon a number of different variables (e.g., down time, lost revenue, cash flow
value added) when trying to maintain safe operations introduced conflicting
priorities and created risks that operational decisions might compromise safety.

C. BP and Transocean Bridging Document

BP and Transocean developed a bridging document for operations
associated with deepwater drilling in North America. It outlines the
responsibility of both parties to ensure that health and safety management
systems are in place, and that all operations are to be conducted in a safe manner.
But the bridging document did not include procedures on well control, a crucial
468
topic for safe drilling operations. This was inconsistent with BP’s prescribed
469
policies for safe drilling operations.

D. Stop Work Authority

The Deepwater Horizon had multiple stop work policies in play on the day
of the blowout. BP, Transocean and Halliburton personnel all had company‐
specific policies to stop work they deemed to be unsafe.

BP’s golden rules of safety state, “[e]veryone who works for or on behalf
470
of BP is responsible for their safety and the safety of those around them.”
Transocean’s stop work authority states, “[e]ach employee has the obligation to
interrupt an operation to prevent an incident from occurring.” Halliburton’s
471
hazard observation and communication policy states “[t]he HOC Card has been
designed for use by all employees regardless of their position or their type or

468 The Panel located stand‐alone well control manuals within BP and Transocean; however, but
no document bridging the two manuals together.
469 Section 15.2.17 of BP’s DWOP requires that “a well control interface / bridging document shall
be prepared with the appropriate contractor to ensure there is clear understanding of
responsibilities and which reference documents and procedures will be used in a well control
situation.”
470 BP’s Golden Rules of Safety.
471 BP‐HZN‐MBI00001604.

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