MMS – Electronically Stored Records
NTL No. 2008-G13
The U.S. Dept. of the Interior, Minerals Management Service (MMS) issued a notice to lessees and operators in the Gulf of Mexico OCS region, NTL No. 2008-G13 to clarify the policy of the availability and inspection of electronically stored records and documents. Pursuant to the requirements of 30 CFR 250.804(b) and 1630(b), operators must maintain testing records for each installed surface and subsurface safety device “at the lessee’s field office nearest the OCS facility or other locations conveniently available to the District Manager.” Other MMS regulations require operators to maintain various additional records related to operations, testing, training, and inspections at OCS facilities, including, but not limited to: crane records; pollution inspection records; operating pressure-recorder charts; records of flaring and venting gas and burning liquids; measurements or estimates of volumes of gas lost or used; and meter site security seal records.
Many lessees and lease operators currently use compliance management systems (CMS) to schedule and document testing and inspections. One of the major benefits of using an electronic system over paper is that information can be immediately and remotely available. Use of electronic systems to manage inspections and follow-up activity is recognized and encouraged by MMS and is viewed as a tool that has the potential to reduce incidents of non-compliance and improve compliance with the regulations if used properly.
If you use a CMS and store your test records and other documentation in an Internet-accessible central database or electronic filing system, MMS may recognize this as your official records storage location pursuant to 30 CFR 250.186(a)(3) if your system meets certain criteria. If you would like MMS GOMR to use your electronic CMS for records inspection, submit a letter to the MMS GOMR regional office requesting approval of an alternate procedure under 30 CFR 250.141.
Effective date for NTL 2008-G13 is July 9, 2008.
For more information or the full text of NTL No. 2008-G13, contact Jessica Roger.
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