They  perform the inspections, in part, by using a checklist derived from  regulated safety and environmental requirements. In December 2015, BSEE issued its Fiscal Year 2016–2019 Strategic  Plan. BSEE Leadership Has Started Several Initiatives to Improve the Bureau’s Safety and Environmental Oversight Capabilities but Its Actions Have Hindered Progress

BSEE leadership has started several initiatives to improve its safety and  environmental oversight capabilities but its limited efforts to obtain and  incorporate input from within the bureau have hindered its progress. Limited Efforts to Obtain and Incorporate Input from Regional Personnel Hindered the Development and Implementation of Risk-Based Inspection Initiative

Since it was established as a separate bureau in 2011, BSEE leadership  has continued an initiative begun by its predecessor to transition the  bureau’s inspection program to a risk-based approach. In 2012, BSEE  leadership started a new initiative that included the development of a risk  model and an approach for inspecting production facilities based on the  risk they pose. By going against BSEE’s inspection planning methodology,  BSEE leadership appears to have excluded the input of regional  personnel, undercutting the pilot effort and raising questions about  whether the bureau’s leadership has the commitment necessary to  enable the successful implementation of its risk-based program. Inspection Protocol. However,  according to officials, BSEE did not provide the operator of the first  pilot facility with a report of its findings. Limited Efforts to Obtain and Incorporate Input Hindered BSEE’s Ability to Identify and Remediate Deficiencies in Its Risk-Based Inspection Program

In July 2003, we found that when implementing large-scale management  initiatives, a key practice is involving employees to obtain their ideas and  gain their ownership by incorporating employee feedback into new  policies and procedures. Without higher level  oversight within Interior establishing a mechanism for BSEE management  to obtain and incorporate input from personnel within the bureau and any  external parties, such as Argonne, that can affect the bureau’s ability to  achieve its objectives, BSEE’s Environmental Stewardship efforts are  likely to experience continued implementation and efficacy problems. BSEE Leadership Has Made Limited Progress in Implementing Strategic Initiatives to Improve Its Internal Management

Since 2013, BSEE began four strategic initiatives to improve its internal  management, but their successful implementation has been hindered by  limited leadership commitment and not addressing factors contributing to  trust concerns. 2. However, BSEE  terminated the contract in January 2015 because, according to BSEE  officials, leadership determined that the bureau needed to complete its  ongoing internal organizational restructuring prior to developing  programmatic performance measures. BSEE headquarters officials told us  that the bureau did not implement the consultant-developed measures,  but rather that those measures are informing BSEE’s third effort to  develop performance measures. BSEE initially planned to finalize its  internally-developed list of performance measures in February 2016, but  did not meet this deadline. As of  August 2016, BSEE had developed 17 draft performance measures, but  bureau leadership has repeatedly missed deadlines to review them. BSEE headquarters officials told us that, subsequent to leadership  approval, the bureau plans to pilot these measures and develop others in  upcoming years. Interior agreed that  additional reforms—such as documented policies and procedures—are  needed to address offshore oil and gas oversight deficiencies, but Interior  neither agreed nor disagreed with our recommendation. In our 2013 High-Risk update, because progress had been made in one  of the three segments we identified in Interior’s Management of Federal  Oil and Gas Resources on our 2011 High-Risk List—reorganization of its  oversight of offshore oil and gas activities—we narrowed the scope of the  high-risk area to focus on the remaining two segments (revenue collection  and human capital). However, BSEE leadership has not demonstrated continuing  oversight and accountability for implementing internal management  initiatives, as evidenced by its limited progress implementing key strategic  initiatives as well as its inability to address long-standing oversight  deficiencies. Without higher-level oversight within Interior addressing  leadership commitment deficiencies within BSEE—including by  implementing internal management initiatives and ongoing strategic  initiatives (e.g., ERM and performance measure initiatives)—in a timely  manner, the bureau is unlikely to succeed in implementing internal  management initiatives, including its key strategic initiatives for ERM and  performance measures, in a timely manner. Without a higher-level  organization within Interior addressing leadership commitment  deficiencies within BSEE, including by implementing internal  management initiatives and ongoing strategic initiatives (e.g., ERM and  performance measure initiatives) in a timely manner, the bureau is  unlikely to succeed in implementing internal management initiatives,  including its key strategic initiatives for ERM and performance measures,  in a timely manner. Recommendations for Executive Action

In this report, we are making four recommendations.
Why GAO Did This Study

On April 20, 2010, the Deepwater Horizon drilling rig exploded in the Gulf of Mexico. The incident raised questions about Interior's oversight of offshore oil and gas activities. In response, in May 2010, Interior reorganized its offshore oil and gas management activities, and in October 2011, created BSEE to among other things, develop regulations, conduct inspections, and take enforcement actions. In February 2011, GAO added the management of federal oil and gas resources to its High-Risk List. In December 2015, BSEE issued a strategic plan outlining initiatives to improve offshore safety and environmental oversight as well as its internal management.
This report examines what efforts BSEE leadership has made in implementing key strategic initiatives to improve its (1) offshore safety and environmental oversight and (2) internal management. GAO reviewed laws, regulations, policies, and other documents related to the development of BSEE's strategic initiatives. GAO also interviewed BSEE officials.

What GAO Found

The Department of the Interior's (Interior) Bureau of Safety and Environmental Enforcement (BSEE) leadership has started several key strategic initiatives to improve its offshore safety and environmental oversight, but its limited efforts to obtain and incorporate input from within the bureau have hindered its progress. For example, to supplement its mandatory annual regulatory compliance inspections, in 2012, BSEE leadership began developing a risk-based inspection initiative to identify high-risk production facilities and assess their safety systems and management controls. During pilot testing in 2016, several deficiencies—including the usefulness of its facility risk-assessment model and unclear inspection protocols—caused BSEE to halt the pilot. According to bureau officials, during the development of the initiative, BSEE headquarters did not effectively obtain and incorporate input from regional personnel with long-standing experience in previous risk-based inspection efforts, who could have identified deficiencies earlier in the process. GAO previously found that when implementing large-scale management initiatives a key practice is involving employees to obtain their ideas by incorporating their feedback into new policies and procedures. Instead, BSEE leadership appears to have excluded the input of regional personnel by, for example, not incorporating input beyond the risk-assessment tool when selecting the first pilot facility, even though it was prescribed to do so in the bureau's inspection planning methodology. This undercut the pilot effort, raising questions about whether the bureau's leadership has the commitment necessary to successfully implement its risk-based program. Without higher level leadership within Interior establishing a mechanism for BSEE to obtain and incorporate input from personnel within the bureau, BSEE's risk-based inspection initiative could face continued delays.
Similarly, since 2013, BSEE leadership has started several key strategic initiatives to improve its internal management, but none have been successfully implemented, in part, because of limited leadership commitment. For example, BSEE's leadership identified the importance of developing performance measures in its 2012-2015 strategic plan. BSEE began one of three attempts to develop performance measures in July 2014 by hiring a contractor to develop measures, but the bureau terminated this contract in January 2015 after determining a need to complete its internal reorganization before developing such measures. A second effort to develop performance measures started in December 2015, using the same consultant, and yielded 12 performance measures in March 2016, but BSEE did not implement them, in part, because data did not exist to use the measures. By the time BSEE received this consultant's report, it had already begun a third effort to internally develop performance measures; as of November 2016 had identified 17 draft performance measures, but BSEE leadership missed repeated deadlines to review them. BSEE officials told GAO that after leadership approval, the bureau plans to pilot these measures and develop others. BSEE leadership has not demonstrated continuing oversight and accountability for implementing internal management initiatives, as evidenced by its limited progress implementing key strategic initiatives. Without higher-level oversight within Interior addressing leadership commitment deficiencies within BSEE, the bureau is unlikely to succeed in implementing internal management initiatives.

What GAO Recommends

GAO is making four recommendations, including that higher-level leadership within Interior (1) establish a mechanism for BSEE management to obtain and incorporate input from bureau personnel that can affect the bureau's ability to achieve its objectives and (2) address leadership commitment deficiencies within BSEE, including by implementing internal management initiatives and ongoing strategic initiatives in a timely manner. Interior neither agreed nor disagreed with our recommendations.