The Fundamental Importance of External Oversight

Intro: The alternate eight pillars of low risk DP operation from 2 weeks ago inspired this article - more specifically one of the pillars. I originally listed seven pillars in a reply to Jud and added some extras as an example of possible expansions. External oversight was one of those extras, but the more that I thought about it, the more fundamental I found that pillar was, and made it the eighth pillar when I made pictures. Safe and redundant DP operation needs supported by external oversight, but this is under threat.

Contrast: External oversight is less popular in a cultural environment that sees people as individual atoms and encourages people to do their own thing and find their own way, or in a business environment that encourages challenging and innovating around restrictive realities, and emphasizes short term returns over long term dominance and stability. The feedback, responsibility, and grounding that external oversight provides are even more vital in these environments. DP isn’t about taste, style, or business fashions, but is grounded in reality and has real consequences.

Personal Confession: Yes, I know that I’m the guy who wrote “DP Consultants Aren’t God’s Gift to DP Operators” and “Class Societies Aren’t DP Gate Keepers”, but hear me out. Most of the complaints were about the external oversight being done badly. In this article, I’m talking about external oversight being bypassed by design. This threatens the industry and means that vessel customers need to do a lot more work to protect themselves and the crews.

Downsides: External oversight is inconvenient, expensive, uncomfortable, and can be dangerous. Vessels need to stop working to do surveys and trials and usually have to arrange transport from and to the shore. No one likes having a random stranger looking over their shoulder and judging their work. Random strangers can be helpful experts but they can also be uninformed wastes of time or dangerous zealots. Their findings, true or false, can cause trouble. These are all fair concerns.

Visibility: The threat of negative findings forces company discipline. The company may not want to do maintenance or training when it could be doing work, but knowing that external oversight could find problems encourages them to do the right thing to avoid trouble. This protects their long term interests from short term concerns and helps manage risk. Often the crew needs something important done and the company doesn’t want to invest in it, but while the company can ignore the crew, independent external oversight making the problem visible can help get the problem resolved. The people doing the work shouldn’t be ignored but there are always numerous competing priorities, especially as distance from the vessels increase, but the external oversight can identify important priorities.  

Discipline: External oversight isn’t there to find problems, but to encourage company discipline, so there are none to find. Good external oversight doesn’t just provide feedback but insight. It provides training and shares good practice between vessels. While companies can do all these things on their own, external oversight is an important support of those good intentions.

Oversight Removed: I’ve written before about how the benefits can be undermined and drawbacks managed, or emphasized, by selecting “friendly” or neutered external oversight, and about the difficulty of finding good external oversight, so I’m not going to repeat the discussion from those articles. I’m more concerned about external oversight being removed from industry guidelines. Rigs and then ships doing their trials without oversight is very bad practice. I have no problems with ships and rigs doing their own trials. Ensuring everything works and is done right, before someone comes to look at it, should be standard practice.  

If a Tree Falls and There is No One There… Drills and tests should be normal, but if no one is ever coming to look at it, there is no one to keep companies from fooling themselves. This is an important concern that isn’t addressed by reviewed paperwork. In the company, everyone has more important things to do, but the external oversight has one thing to do and the loss of that focus increases overall risk and reduces visibility. It can be done right, but that is not the tendency or the way that the work pressures align. Removing the external oversight is cheaper and more convenient, and the guidelines have been changed to support it, but it comes at the cost of reduced discipline and visibility.

Under Pressure: This is bad practice, but the question becomes – is it worse than depending on external oversight that has already been degraded by selection bias? It partially depends on the individuals involved. While an external, independent, expert is preferred, their independence and expertise is degraded by the selection process and an internal, independently minded, expert can be just as good, and better than many external options. The problem is that the internal expert is easier to undermine and will not stay in that position forever. Will the next guy be as good? How long will the company see this function as a priority if there are no negative consequences? It’s sustainable for a while, but it isn’t the best long term solution, as company discipline will eventually break down.

Again?! Beyond cost, convenience, and questionable external expertise, there is another valid objection. How much external oversight is needed? Third party witnessing is so degraded by selection bias that some vessel clients demand their own tests and surveys to ensure it is done right. If vessel clients are doing their own assurance anyway, then why is third party assurance needed? Shouldn’t we cut out the middleman? If the vessel owner can make the crew do a better job, then why not? There is an old saying, “Where you stand on a subject often depends on where you sit.” If external oversight is degraded by the selection process, the crew are even more under pressure and even less trusted. Q - “Have you checked that you know the thing you don’t know?” A - “Yep, we think we’re good.”  

What Works? It is more efficient and effective to ensure that the external oversight is independent and expert. Perhaps this is what DNV was thinking when they offered a service to claim trial oversight for themselves from consulting companies. If selection bias is decreased (cheap, malleable surveyors) then supplemental client surveys will be needed less and everyone saves. There are always vessel clients with higher standards or lower risk tolerance that will need to pay for their own additional assurance, but assuring independent, expert, external oversight would eliminate most of this, so everyone else doesn’t need to pay.

For Everything, There is a Season: The industry has been here before and will return here again. There is a cycle of loosening oversight followed by tightened oversight after disasters. This can be seen in many industries over many years, and ours is no different. External oversight was put in place for good reason and will be needed again. In the meantime, the oil companies and vessel clients are forced to do the work themselves. What was convenient and cheaper for the vessel owners is a risk to be managed by the vessel clients. When the ball is dropped, the cycle shall begin anew. It doesn’t have to be that way, be aware of your own, your company’s, and your industry’s limitations and tendencies, so you can plan defensively for long term growth and prosperity.