Maritime Security:

Coast Guard Should Conduct Required Inspections of Offshore Energy Infrastructure

GAO-12-37: Published: Oct 28, 2011. Publicly Released: Oct 28, 2011.

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Congressional interest in the security of offshore energy infrastructure has increased because of the lives lost and the substantial damages that resulted from the Deepwater Horizon incident in April 2010. The U.S. Coast Guard--a component of the Department of Homeland Security (DHS)--is the lead federal agency for maritime security, including the security of offshore energy infrastructure. The Coast Guard oversees two main types of offshore energy infrastructure--facilities on the Outer Continental Shelf (OCS) and deepwater ports. GAO was asked to examine (1) Coast Guard actions to ensure the security of OCS facilities and what additional actions, if any, are needed; (2) Coast Guard actions to ensure the security of deepwater ports and what additional actions, if any, are needed; and (3) what limitations in oversight authority, if any, the Coast Guard faces in ensuring the security of offshore energy infrastructure. GAO reviewed Coast Guard documents, such as inspection records, and relevant laws and regulations and interviewed Coast Guard inspectors and officials, including those at Coast Guard headquarters and the two Coast Guard districts that oversee all OCS facilities and deepwater ports that are subject to security requirements.

The Coast Guard has taken actions to address the security of OCS facilities (that is, facilities regulated for security pursuant to 33 C.F.R. part 106), but could improve its process for managing security inspections. For example, the Coast Guard developed a security plan for the Gulf of Mexico, in which all 57 OCS facilities are located, and it reviews security plans developed by the owners and operators of OCS facilities. It has also issued guidance, which states that Coast Guard personnel should conduct security inspections of OCS facilities annually, but has conducted about one-third of these inspections from 2008 through 2010. Further, the Coast Guard does not have procedures in place to ensure that its field units conduct these inspections. Consequently, the Coast Guard may not be meeting one of its stated goals of reducing the risk and mitigating the potential results of an act that could threaten the security of personnel, the OCS facility, the environment, and the public. The Coast Guard also faces challenges in summarizing inspection results. Specifically, its database for storing inspection data has limitations that make it difficult to determine if security inspections were conducted. For example, there is no data field to identify OCS facilities, which makes it difficult to readily analyze whether required inspections were conducted. By addressing some of these challenges, Coast Guard managers could more easily use the data as a management tool to inform decision making. The Coast Guard has also taken actions to ensure the security of the four deepwater ports, but opportunities exist for improvement. The Coast Guard's actions to ensure the security of deepwater ports are similar to actions it has taken to ensure the security of OCS facilities. For example, Coast Guard security plans address security at deepwater ports, and the Coast Guard also reviews security plans developed by the owners and operators of the deepwater ports. However, Coast Guard guidance for deepwater ports does not call for annual security inspections, and it has conducted only one security inspection at a deepwater port from 2008 through 2010. Coast Guard officials said that the Coast Guard plans to begin annual security inspections of deepwater ports in recognition of the risk of a transportation security incident. However, limitations in the Coast Guard's inspection database and lack of guidance available to database users may complicate the Coast Guard's management and oversight of inspections at deepwater ports. For example, the data field for deepwater ports has been incorrectly applied to other types of infrastructure and some deepwater ports are recorded under multiple names. Unless the Coast Guard addresses these database limitations and issues updated guidance to database users, it will be difficult for the Coast Guard to verify that the deepwater ports are complying with applicable maritime security requirements. The Coast Guard has limited authority regarding the security of mobile offshore drilling units (MODU) registered to foreign countries, such as the Deepwater Horizon. The Coast Guard is taking action, though, to gain a fuller understanding of the security risks associated with MODUs by conducting a study to help determine whether additional actions could better ensure the security of offshore energy infrastructure in the Gulf of Mexico, including MODUs. GAO recommends that the Coast Guard develop policies or guidance to ensure that (1) annual security inspections are conducted at OCS facilities and (2) information entered into its database for both OCS facilities and deepwater ports is more useful for management. DHS and the Coast Guard concurred with these recommendations.

Status Legend:

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  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To strengthen the Coast Guard's efforts to ensure the security of OCS facilities and deepwater ports, the Commandant of the Coast Guard should develop policies and procedures to monitor and track annual security inspections for OCS facilities to better ensure that such inspections are consistently conducted.

    Agency Affected: Department of Homeland Security: United States Coast Guard

    Status: Open

    Comments: According to a statement the Coast Guard provided in June 2012, the Coast Guard plans to add a feature to the Marine Information for Safety and Law Enforcement (MISLE) database--which is used to track inspection activities--to identify if a vessel or facility is an OCS facility regulated under the Maritime Transportation Security Act (MTSA), 33 CFR 106. Then, on February 20, 2014, the Coast Guard's Chief of External Coordination informed GAO that the MISLE update is on schedule to be deployed in March 2015. In addition, the Coast Guard recently developed a process guide entitled "33 CFR 106 MTSA Data Integrity and Inspection Performance Monitoring," which outlines standardized procedures for Coast Guard units prior to the MISLE update to (1) confirm existing populations of fixed OCS facilities and deepwater ports and (2) track inspection performance by inspection type. GAO will follow up with the Coast Guard in 2015 to confirm if the feature was incorporated into the MISLE update. At that time, GAO will also determine the extent to which the Coast Guard is tracking security inspections for OCS facilities using the newly added feature or other means of tracking annual security inspections.

    Recommendation: To strengthen the Coast Guard's efforts to ensure the security of OCS facilities and deepwater ports, the Commandant of the Coast Guard should make improvements to the Marine Information for Safety and Law Enforcement (MISLE) database or MISLE guidance to better ensure that all OCS facilities, both fixed and floating, are accurately and consistently identified and that the results of security inspections are consistently recorded to allow for better data analyses and management of the security inspections process.

    Agency Affected: Department of Homeland Security: United States Coast Guard

    Status: Open

    Comments: On February 24, 2012, DHS responded to GAO's report stating that the Coast Guard had released a MISLE database process guide in 2011 that greatly improved database quality. The updated "33 CFR 106 MTSA Population Identification and Compliance Examinations" guide addresses the MISLE limitation for easily identifying fixed OCS facilities subject to 33 C.F.R. part 106. According a statement the Coast Guard provided in June 2012, by following the standardized description titling convention and other steps, Coast Guard units and program managers will be able to query the MISLE database and quickly derive the actively regulated fixed facility population. Furthermore, according to the Coast Guard, it is monitoring data quality such as properly describing actively regulated fixed OCS facilities and inspection performance through periodic reviews of MISLE data using the recently developed process guide "33 CFR 106 MTSA Data Integrity and Inspection Performance Monitoring." According to the Coast Guard, once the ability to label both fixed and floating OCS facilities as regulated under 33 C.F.R. part 106 comes on line through an update to MISLE in March 2015, past difficulties in identifying fixed or floating OCS facilities subject to 33 C.F.R. part 106 as well as duplicative facilities will be mitigated. GAO will follow up with the Coast Guard in 2015 to confirm the feature to label both types of OCS facilities was incorporated into the MISLE update and that the challenges identified in GAO's report have been mitigated.

    Recommendation: To strengthen the Coast Guard's efforts to ensure the security of OCS facilities and deepwater ports, the Commandant of the Coast Guard should ensure that information on deepwater ports in MISLE can be used as a management tool for decision making. These actions should include (1) issuing guidance on how information on deepwater ports and their security inspections should be entered into MISLE; (2) defining deepwater ports in MISLE guidance; and (3) making any changes necessary in the database to ensure that deepwater ports regulated under 33 C.F.R. parts 148-150 can be identified within MISLE.

    Agency Affected: Department of Homeland Security: United States Coast Guard

    Status: Open

    Comments: On February 24, 2012, DHS responded to GAO's report stating that the Coast Guard will be modifying the MISLE database to include non-MTSA facilities, and according to a statement the Coast Guard provided in June 2012, the Coast Guard plans to modify the facility type choice in MISLE from simply "Deepwater Port" to "Deepwater Port - 33 CFR Sub NN" in order to clearly indicate to the user that this facility type is to be used for only specific types of facilities that fall under the deepwater port regulations in 33 C.F.R. Subchapter NN. This enhancement is expected to be built into the MISLE update anticipated to occur in March 2015. In addition to modifications to MISLE, the Coast Guard distributed updated MISLE user guides in December 2011 to clarify when the deepwater port facility type is to be used in MISLE. In December 2011, the Coast Guard asked its field units to examine facilities in MISLE that were perceived to be erroneously labeled with the deepwater port facility type. As a result the Coast Guard was able to delete some unnecessary entries and add notes for others that were not deepwater ports as defined by 33 CFR Subchapter NN (parts 148 - 150). According to the Coast Guard, as a result of these efforts, those facilities that are deepwater ports or associated with deepwater ports can now be easily identified. However, MISLE does not allow Coast Guard users to change the existing facility type for the facilities that are incorrectly labeled with the deepwater port facility type. The Coast Guard expects to enable changing the facility type as part of the update to MISLE that is planned for March 2015. GAO will follow up with the Coast Guard in 2015 to confirm the feature was incorporated into the MISLE update and that, following the MISLE update, the list of deepwater port facilities in MISLE is accurate.

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