Tuesday’s Congressional hearing made for interesting political theater. In particular, a lot of hay was made of the apparent similarity among various energy companies’ oil-spill response plans. Here are some facts you might not have picked up from the hearing:
The Minerals Management Service, known as the MMS, requires companies operating offshore to submit oil-spill response plans. The structure and much of the content of these plans are prescribed by the MMS requirements.
For example, in a notice from October 26, 2006, the MMS specifies 22 sections and 10 appendices that must be in oil-spill response plans. ExxonMobil followed this guidance from the federal government in developing our Gulf of Mexico regional plan, which has 650 pages focused on how to respond and protect the environment. The MMS approved this plan.
Our regional oil-spill response plan is designed to link with the MMS as well as U.S. Coast Guard regional and local plans. It is also important to understand that federal law requires companies to contract with common regional spill response cooperatives. This makes sense.
So it should not come as a surprise that response plans across the industry are similar. Given the legal requirements, the necessary linkages to government plans, and the use of common cooperatives, you would expect companies’ oil-spill response plans to look alike.
Response plans are important, but they are by their very definition a response to an incident. We believe it’s critical to prevent incidents through proper well design and execution, which can be done by evaluating risks and identifying ways to mitigate them through effective procedures, training and management oversight.
The real issue is not how companies’ response plans are similar, but how the Deepwater Horizon well design and execution was different than the industry norm. As our chairman and CEO, Rex Tillerson, said during the hearing, “We would not have drilled the well the way they did.”
It’s so important to understand what really happened and take appropriate steps to prevent an incident like this one from happening again.




As an oil industry retiree, I wish XOM and other oil companies would work harder at improving their PR. It seems they are always on the defensive and afraid to project a positive image. It is not fair to their good, hard working, law biding employees to be constantly demonized.
The industry has had requirements under other regulatory requirements too – Oil Pollution Act of 1990, Spill Prevention Control and Containment to name a few that spring to mind. In general the industry has done quite well in responding to the regulatory requitements. It is unfortunate that the people who write the regulations generally do not have a lot of industry background and experience. This makes for compliance requirements that are not all that well thought out in some cases. Nevertheless, I see a rash of regulations as a result of this event (BP) and potential impairment of our national security as drillers are going to either shy away from offshore or the current moritorium from the Whitehouse creates a bigger and bigger dependence on foreign suppliers.
Ken.. I beg to differ. First of all, what are Walruses doing in a Gulf response plan? What next…wilderbeast in your arctic response plans?
I take no exception to having similar response plans…but whoever endorsed such a plan, where a dead marine scientist appears in such, really needs to get their act together…
As your CEO even said…”It is obviously embarrasing”
I think that this results, in fact, from politicians writing regulations and having no background in the industry. The other aspect is that sometimes people get a bit lazy and copy and paste without reading carefully!
Yes, it was definitely an unfortunate oversight. Walruses are listed as a species of concern based on NOAA’s Environmental Sensitivity Index, which we are required to use when developing the response plan. So while walrus protection is applicable in some operations around the world, it isn’t in the Gulf and it should have been removed from the comprehensive list. Inclusion of Dr. Lutz was also an oversight that we’re fixing. His name appeared as a contact at the University of Miami’s Marine Mammal Research Division, which has been and continues to be an important institutional resource for the Gulf Oil Spill Response Plan. My purpose in talking about response plans wasn’t to make excuses. It was to show my disappointment that so much valuable time has been focused on two mistakes — literally two lines in a document that’s more then 600 pages long. Assumptions were being made that the similarity of the plans makes all response plans and capabilities invalid, and that’s simply not the case.
The OIMS system requires the specific manuals and other controlled documentation to have specific update and maintenance plans, so, e.g. the response plan would be subject to review and update on perhaps a 5 year schedule. Out of service phone numbers and unavailable (through death) consultants should have been caught if the plan was being MAINTAINED. Since there is a lot of drilling in northern waters, I am not surprised that arctic animals might be mentioned in boiler plate content – the reference to Walrusses is not the issue.
There is a real increase in risk when ever devices OR plans are not frequently used that they are not functional. We just do not have enough major oil spills in any one company for there to be a company specific response plan worth anything. Furthermore, we do not say to the erudite college professor, no matter how smart he is,when he accidentally sets the apartment on fire from his smoking habit, that he lit it he should put it out. There needs to be a more integrated mutual aid plan or an oil spill equivalent to a fire department. This is apparently the Dutch approach.
So, what was the average annual budget for response preparations and research? The little people in Gulf do not see much difference between the 1980 spill cleanup technology and that of 2010.
Due to the tragic accident on BP’s Deep Water Horizon rig…and the ongoing spill of crude as a result, it reinforces the dangers of drilling and the importance of finding crude for our country. The NY Times article points out the pitiful lack of planning and safety which BP appears to go about in their business with a toss of the dice. I would think with lives and hundreds of millions of dollars in equipment and research at stake, the NY Times is simplifying BP “safety” policies. However, in my opinion, I must say the EOM learned an invaluable lesson from the Valdez tragedy. I could only hope that BP employs a fraction of what EOM has (and does) spend in insuring the safety in each step of oil exploration, production and processing. Perhaps the top levels of BP could spend more time focusing on what it takes to be an industry leader like EOM in overall safety. Having a son-in-law that works for EOM Pipeline, I’m proud to know that stringent safety rules are enforced from the top down, protecting lives, the environment and America’s energy independence.