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would allow BOEMRE inspectors to review the major BOP inspection
records to ensure they were performed as required.

7. The Agency should consider researching the best BOP stack configuration
to minimize unsupported pipe in order to reduce the likelihood of elastic
buckling of drill pipe.

8. The Agency should consider researching the need to requirethird‐party

surveys of the drilling packages on rigs operating on the OCS.

9. The Agency should consider researching the need for a complete
independent, acoustically controlled system for subsea BOPs. This would
eliminate the situation which occurred in this event where the MUX lines
seemed to be damaged in the explosion and rendered the surface
operation of the BOP inoperative. Having a complete independent control
system would add an additional safeguard for operating the BOP stack.

10. The Agency should consider researching the need for a completely
independent BOP system (short stack) in lieu of, or in addition to, the
independent control system discussed in Recommendation 9. This gives
the rig a truly independent, redundant, and robust system – unlike an
acoustic system or any other secondary system. The Deepwater Horizon
BOP stack had redundant elements, but these elements relied upon a
number of the same components to function. A completely independent
BOP control system provides true redundancy and robustness.

11. The Agency should consider promulgating regulations that would require
real‐time, remote capture of BOP function data. This would be beneficial
in post‐accident source control and subsequent investigations. Having the
data that show which rams have been activated would help analyze
intervention options. During the Macondo source control response and
ROV intervention attempts, BP and Transocean did not know which rams
may have been activated and critical time was spent trying to function a
ram that had already been activated.

F. OCS Companies’ Practices Recommendations

The Agency should consider working with industry organizations to
revisit the core well control training curriculum used by most companies and

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