Controlling Sub-Sea Infrastructure


The recent implosion of the 
Titan, a sub-sea submersible used for taking elite, high-paying tourists to see the wreck of the Titanic, brought the safety protocols of both vessels into focus. There were no statutory requirements for regulating the Titan and neither were there any when the Titanic sank in 1912! As a reactive measure, the maritime community came up with the Safety of Life at Sea (SOLAS) Convention soon after the sinking of the Titanic. Ironically, after the Titan submersible imploded, we have come to realize there are no requirements covering this vessel. Perhaps with time, the involved counties will react.

The question is, why was nothing done proactively? Tourists go up in hot air balloons all the time. Is there any statutory requirement that these tourist companies must meet? Is there even a requirement to have a management system in place so that these companies work systematically, appreciate the risks in the context of the organization, and plan their operations keeping risks in mind? It is true that entrepreneurs do not like regulations and consider requirements a hindrance in a free business environment. And yet the Titanic, which was declared to be “unsinkable,” did, in fact, sink! In the United States, the domestic towing vessel industry functioned without statutory requirements until recently. The industry avoided regulation, but tragedies occurred, and now the industry is regulated under the U.S. regulatory framework. A process-based management system is the best systematic structure to produce conforming products and services, ensure continual improvement, and implement the statutory requirements if available.

The intent of this article is to proactively start a discussion on the need for regulating sub-sea infrastructure to reduce its affect on the marine transportation system. The phrase “sub-sea infrastructure” refers to equipment and technology placed on or anchored to the ocean floor. This infrastructure may include, but is not limited to, cables for telecommunication, cables for power transmission, pipelines for transmission of fluids, and other stationary equipment for scientific research.

The growth of sub-sea infrastructure is a global phenomenon. As an example, is in the interest of all nations, and particularly here in United States, to promote wind farms, which are a source of renewable energy. When these wind farms are placed in selected geographical locations along the continental shelf, they need sub-sea cables. But are there any laws controlling the systematic development of the industry to enable an effective marine transportation system and its protection of maritime community interests and environmental interests? Is there a central agency responsible for this coordination to allow for a balanced approach to risks? The amount of cabling piling up needs management and oversight.

Sub-sea infrastructure, the definition of the problem

Numerous industries have a stake in sub-sea infrastructure. Examples include oil and gas, telecommunications, fishing, scientific research, and perhaps military/defense applications such as sonar and other arrays and obstacles. This infrastructure is a requirement, but it also faces various challenges including those that can lead to accidents, environmental damage, and possible breaches in national security. All these bring out very significant concerns related to sub-sea infrastructure and the lack of comprehensive and globally accepted standards, requirements, obligations, and assurance mechanisms. It is not that organizations such as the United States Coast Guard, the National Oceanic and Atmospheric Administration, the Bureau of Safety and Environmental Enforcement, the U.S. Army Corps of Engineers, the Environmental Protection Agency, and other federal and state agencies do not look at these issues.

Nevertheless, it remains a concern that there is no single agency or overarching requirement to provide a framework to the industry on harmonized implementation of requirements. This lack of harmonization can mean inconsistencies in design, installation, and maintenance practices which may not address risks uniformly. This can generate consequential risks, leading to increased accidents, mechanical failures, and costs to the industry and the nation.

Recent tragedies and accidents

Recent tragedies and accidents involving sub-sea infrastructure have been limited, and yet must not lead to complacency by the agencies involved. The few that have occurred indicate the challenges and trends pointing to the need for proactive requirements. The recent tragedies include:

  • Deepwater Horizon. The potential consequences and challenges inherent in deep-water oil drilling were brought out by the Deepwater Horizon tragedy in 2010. The oil rig explosion in the Gulf of Mexico caused a massive oil spill and resulted in the loss of 11 lives. Although not technically a sub-sea incident, it highlighted a series of failures in design, maintenance, and company oversight—all factors pointing to the importance of robust safety standards and requirements, and the implementation thereof. The Deepwater Horizon incident was not directly related to sub-sea infrastructure; however, it heightened the risks associated with offshore oil and gas production and the potential for catastrophic environmental damage.
  • Nord Stream 1 and Nord Stream 2. Occurring in September 2022, the damage to these gas pipelines in the Baltic Sea highlighted concerns around sub-sea infrastructure. These pipelines transport natural gas from Russia to Europe; in this incident, they sustained multiple leaks. The exact cause of the damage is unclear, though deliberate sabotage was suspected and is still under investigation. Regardless of the ultimate findings, this incident exposed the vulnerabilities of sub-sea infrastructure to sabotage, and the potential for significant environmental and economic consequences are real. Intentional attacks to the sub-sea infrastructure have the potential for widespread disruption of energy supplies. Apart from the Nord Stream, there have been other sub-sea incidents affecting the gas and oil industry. In 2021 a fire broke out on a sub-sea production control umbilical off the coast of Brazil, causing significant damage to the underwater equipment and resulting in a major oil spill.
  • English Channel Internet Disruption. In 2021, a ship dragging its anchor on the seabed in the English Channel cut the three main internet cables to the Channel Islands. Although this only resulted in slower broadband speeds in this instance, there remains the possibility that it could have resulted in a complete outage.

Looking ahead

These incidents represent leading indicators of a tragedy in the making should proactive action not be taken. The critical importance of safety for sub-sea infrastructure underscores the need for a more comprehensive and rigorous approach to standards and assurance. Industry stakeholders together with regulatory bodies within the United States and global organizations such as the International Maritime Organization must work together to establish a harmonized set of safety standards, implement robust assurance mechanisms, and foster a culture of safety throughout the sub-sea industry.

The increasing reliance on sub-sea infrastructure for various industries (including wind farms) necessitates a proactive approach to safety and risk management. There is definitely a need to invest in research and development to enhance the resilience and monitoring capability of sub-sea infrastructure. The various companies in the sub-sea industry are holding their proprietary information close to the vest. This is understandable. However, these organizations are in competition with totalitarian governments, in which control of business practices is the exclusive dominion of the state. It is necessary to enhance transparency and information-sharing among industry stakeholders to facilitate better risk assessment and incident prevention.

Conclusion

Promoting a culture of safety that prioritizes risk identification, risk mitigation, and continual improvement is essential. There is no common ISO standard for sub-sea management systems. Of course, ISO 9001 is interpretable and can be used as the basis for now. Environmental protection is a challenge for a developing industry, and as such, even greater urgency is needed for statutory requirements encompassing all aspects of stakeholder interests, the marine industry in general, and the protection of the environment for generations to come.

Marine transportation remains the most important way for goods to be shipped across the world, as approximately 80 percent of the world’s goods are transported by ships. Vessels need a place to anchor in normal operating conditions as also in emergencies. A crowded seabed in harbors makes this a challenge for the entire maritime industry.

Without adequate and effective regulatory oversight, it may be too late to take action once cables and other sub-sea equipment have already been laid. Further, multiple agencies regulating the same aspects of the industry can potentially lead to bureaucratic delays.  There is therefore an urgent need to create a single statutory body to regulate the sub-sea infrastructure industry, which will greatly benefit all parties invested in the maritime transportation system.

Exemplar Global Publication “The Auditor”

Aspects and Impacts: Let’s start here

Every organization needs to consider the aspects of their organization, and the impacts they have on the planet.  Understanding the impacts is critical to the sustainability of the organization, and in the long run, the planet.

Most organizations only consider the impacts of their processes in relation to waste created and materials used.  While these are important, an organization should consider all aspects of their operation and processes before they start a business.  This includes the facilities, people, materials and other elements of their operations.  Once operational, they need to continually evaluate all process to look for improvement.

Many aspects are considered by organizations in order to borrow money to launch a product or service.  This is a good place to start.  Clearly understanding the impacts the organization will have on the local environment and community is a good step toward launching a sustainable business.  Lenders, both private and public, will be more generous lending if they know the organization is considering all three pillars of sustainability; social, environmental and economic.

Generally speaking, recycling an existing structure to a new operational use has less impact than building a new facility.  Applying building technics recommended under Leadership in Environmental and Energy Design (LEED) and Energy Star, will also reduce environmental impacts, and improve the operational economics.  If new structures are required, considering the site location, building facing direction and proximity to water, public transportation, and workers, will also help the organization conform to LEED and other building Standards.  Local communities will be much more accepting of an organization operating in their community if the proper design considerations are considered before construction is begun.

Once operational, every group in an organization needs to evaluate their processes on a regular basis to determine what improvements can be made to the aspects of the organization, and the impacts of there processes.  Management is accountable for the operation of the organization, but every department needs to be responsible for their processes.  This is not just the manufacturing or production departments, but also sales, marketing, receiving, packaging, shipping and customer services.  Organizations are also responsible for the performance of their products and/or services, and often the potential recycling of products. 

The International Organization for Standardization (ISO) has established Standards that can be used by an organization to help improve their management system processes and reduce risks.  ISO 14001:2015 Environmental Management Systems and ISO 9001:2015 Quality Management Systems can be used separately, or together, to provide guidance in improving an organization’s operations.  Lenders and communities appreciate the value of a well-run organization that understands the aspects of their operations and addresses the impacts.

Environmental Best Practices in Vineyards

The number of vineyards in the United States, and abroad, have grown substantially over the last 20 years.  New technology and controlled stainless steel fermentation processes have improved the product of even relatively small vineyards.  Many of the best vineyards are also focusing on their environmental impacts to ensure sustainability.  They are finding that taking a hard look at some of their processes can reduce negative environmental impacts, and in fact, reduce operating costs. 

Implementing an ISO 14001:2015 based Environmental Management Systems can help a vineyard archive sustainability and reduce operating costs.  It can also get the organization recognized as a responsible business neighbor in the community with happy and proud employees.  It starts with the owner’s decision to implement an environmental management system, then getting all employees aware, and on onboard to help improve operational processes.  

Environmental Management Systems (EMS) address recycling, and water conservation. These are important elements that are common to all vineyards.  One company that was spending over $50,000 a year on recycling, not only reduced their recycling cost, they actually saved over $7,000 a year after introducing a new recycling program as a part of their EMS. The program included 95% of its solid waste, packaging, and recycling.  New approaches to water use and heat exchange were able to reduce water use by over 35%.  Water used in the winemaking process is now processed on site and used in the vineyards, instead of being flushed down the drain. 

An EMS gets organizations to address the environmental aspects of their business and the impact they have taken into consideration the business environment they operate in, the needs of the stakeholders and risks associated with their business. Let us consider the aspect of energy use and the impact it has on the business including the organization’s carbon footprint. Taking the example further installing solar panels on buildings reduces energy operating costs and produces no carbon emissions.   One company was able to use solar for 75% of its energy use. 

QMII, with its 32 plus years of experience, can help a vineyard educate its employees so they are aware of the requirements of the internationally recognized and accepted standard for Environmental Management Systems – ISO 14001. Our course will outline the next steps the vineyard can take to begin implementing an EMS within their business.  We offer introductory environmental management system courses that will help a vineyard conform and/or become certified to the Standard.