http://www.rawstory.com/rs/2010/11/activist-lab-tests-show-dangerously-toxic-substances-present-gulf-shrimp/

By Stephen C. Webster
Wednesday, November 10th, 2010 — 8:09 am

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Experts operating states apart confirm toxic content in not just shrimp, but crab and fish too

The federal government is going out of its way to assure the public that seafood pulled from recently reopened Gulf of Mexico waters is safe to consume, in spite of the largest accidental release of crude oil in America’s history.

However, testing methodologies used by the government to deem areas of water safe for commercial fishing are woefully inadequate and permit high levels of toxic compounds to slip into the human food chain, according to a series of scientific and medical professionals interviewed by Raw Story.

In two separate cases, a toxicologist and a chemist independently confirmed their seafood samples contained unusually high volumes of crude oil and harmful hydrocarbons — and some of this food was allegedly being sent to market.

One test, conducted by a chemist from Mobile, Alabama, employed a rudimentary chemical analysis of shrimp pulled from waters near Louisiana and found “oil and grease” in their digestive tracts.

The National Oceanographic and Atmospheric Administration’s (NOAA) tests, which are approved by the Food and Drug Administration (FDA), have focused on the animal’s flesh, with samples shelled and cleaned before undergoing examination.

Unfortunately, many Gulf coast residents prepare shrimp whole, tossing the creatures into boiling water shells and all.

“I wouldn’t eat shrimp, fish or crab caught in the Gulf,” said Robert M. Naman, a chemist at ACT Labs in Mobile, Alabama, who conducted the test after being contacted by a New Orleans activist. “The problems people will face, health-wise, are something that people don’t understand.”

Naman also found that the oil was at an unusual high concentration: 193 parts-per-million (PPM).

Though Naman’s test did not provide a complete fingerprint of the chemical spectrum, his results are still “an important finding,” according to Dr. Susan Shaw, a marine toxicologist at the Marine Environmental Research Institute in Blue Hill, Maine.

“193 parts-per-million of petroleum in a crustacean is very high,” she told Raw Story. “You have to ask, what is the meaning from a human health perspective?

“This is another signal that oil is in the food chain in the Gulf. Oil has been found in subsea plumes, in seafloor sediments, where it will degrade very slowly and can be re-released into the food chain.”

Tainted seafood allegedly headed to market

In another series of tests, Dr. William Sawyer, of the Sanibel, Florida-based Toxicology Consultants & Assessment Specialists, replicated findings of oil in shrimp digestive tracts, but he noted an even higher content of harmful hydrocarbons in the flesh of other edible creatures.

And, Dr. Sawyer said, some of his test samples came from seafood on its way to market, pulled from waters recently classified as safe for commercial fishing activities.

“They did not test the [total petroleum hydrocarbons] (TPH) in their samples,” he said, calling his testing methodologies a much more comprehensive way of examining compounds present in seafood.

“The sensory test employed by the FDA detects compounds that are volatile that have an odor; we’re detecting compounds that are low volatility and are very low odor,” he added. “We found not only petroleum in the digestive tracts [of shrimp], but also in the edible portions of fish.

“We’ve collected shrimp, oysters and finned fish on their way to marketplace — we tested a good number of seafood samples and in 100 percent we found petroleum.”

The FDA says up to 100-PPM of oil and dispersant residue is safe to consume in finned fish, and 500-PPM is allowed for shellfish.

Dr. Sawyer, who has long been a vocal critic of these rules, called the government’s tests “little more than a farce.”

“[The FDA’s safety threshold] is borderline absurd,” Naman added. “It’s geared so that shrimpers can go back to work, and that’s great — but if we’re talking about human health and the environment, you need to proceed slowly.”

The FDA ignored multiple requests for comment on this story.

Long-term health effects still unknown

Direct exposure to crude oil can cause a number of health issues for humans, but most of them are short-lived or relative and none of the potential long-term effects are guaranteed.

While the full array of effects are still being studied and debated by the medical community, crude oil does contain benzene, which can cause cancer, along with polycyclic aromatic hydrocarbons (PAH), which are toxic to the brain and nervous system.

The latter has been found in virtually all NOAA samples of Gulf seafood, but very few samples exceeded the maximum allowable levels set by federal safety regulators. Even so, according to Dr. Sawyer, PAH levels detected by the NOAA in Gulf region shrimp were almost always 10 times that of levels found in shrimp farmed inland.

The FDA recently declared that out of 1,735 samples of Gulf seafood tested from June through Sept., only 13 showed levels of residues above its allowable threshold.

It is unclear whether regular consumption of this content of oil would sicken a person, how quickly its symptoms would begin to show, or in what ways they would manifest.

The initial effects of oil toxicity from ingestion include headaches, nausea, fatigue and rapid changes in mental state, according to Dr. Cyrus Rangan, assistant director of the California Poison Control System, who spoke to The Los Angeles Times in June.

Those changes in mental state may actually be the most damaging lasting effect of the BP oil spill, according to Dr. Russell W. H. Kridel, a member of the American Medical Association (AMA) Council on Science and Public Health.

Kridel, whose specialty is actually in plastic surgery and ear-nose-and-throat disorders, spoke to Raw Story because the AMA’s council has prepared a comprehensive report on the health effects of the BP oil spill.

“Most of the problems encountered [along the Gulf coast] were more mental health problems than anything else,” he said. “There are respiratory health problems just from burning oil. You can get rashes from skin contact, headaches, vomiting or nausea, which has affected a lot of relief workers.

“There’s a lot of chronic stress and mental health disorders too, and those last longer than the acute, short-term effects. We cannot really tell you the long-term effects, just because of lack of long-term studies.”

He added that while he could not comment on evidence of oil in the digestive tracts of shrimp, some marine life have consumed oil content for centuries due to natural seepage near fault lines thought to account for over 600,000 metric tonnes of oil released across all the world’s oceans every year.

By comparison, scientists with the US Geological Survey and US Department of Energy estimate BP spilled at or near 4.9 million barrels — or approximately 666,400 metric tonnes of crude.

“[Most other oil spills] don’t show any long term effects on the local populations, but the size of previous oil spills are not this large,” he said. “This was the largest oil disaster in US history so I really can’t say what the full effect will be.”

Yet still, “no group has issued a warning or concern that it could affect human health by eating seafood,” Dr. Kridel emphasized.

The AMA has been active in coordinating efforts to track the health effects of BP’s oil spill. A report, recently passed by the group’s house of delegates, committed the AMA to continued monitoring of spill-related health effects.

Risk-factors remain

Despite declaring safety, even the NOAA’s own tests show regular consumption of Gulf seafood will dramatically heighten one’s intake of polycyclic aromatic hydrocarbons.

This, combined with a lack of testing for total petroleum hydrocarbons — and questions as to whether samples were in great enough number to declare wide swaths of water safe for fishing — should be enough to convince any skeptical eater to avoid Gulf seafood for the time being.

“I’m not eating fish. I wouldn’t advise anyone to eat fish,” chemist Robert Naman insisted. “[The government is] more worried about livelihoods and tourism, but I’m ultimately more concerned with human health.”

Dr. Sawyer agreed: “I don’t recommend eating Gulf seafood, not with the risk of liver and kidney damage,” he said. “The reason FDA has not made that advisory is because they’ve relied on this sensory test. You may as well send inspectors out to look at the fish and say they look nice. They’re sniffing for something they can’t detect.”

Because of the unknown nature of the threat posed, chemically sensitive populations like women, children, the elderly and people with depressed immune function or existing illness would be especially well advised to exercise caution when choosing seafood.

“Once oil enters, it can damage every organ, every system in the body,” Dr. Shaw concluded. “There is no safe level of exposure to this oil, because it contains carcinogens, mutagens that can damage DNA and cause cancer and other chronic health problems. Many people in the Gulf have been exposed for months — not just workers but residents. There are hundreds of health complaints from local people with symptoms that resemble symptoms of oil exposure.

“It will be years, possibly decades, before we understand the extent and nature of the health effects caused by this spill.”

Special thanks to Richard Charter

From: U.S. EPA

Sent: Friday, November 12, 2010 12:01 PM
Subject: Research News Release (HQ): EPA Releases Reports on Dioxin Emitted During Deepwater Horizon BP Spill

CONTACTS:

Enesta Jones

Jones.enesta@epa.gov

202-564-7873

202-564-4355

LaTisha Petteway

Petteway.latisha@epa.gov

202-564-3191

202-564-4355

EPA Releases Reports on Dioxin Emitted During Deepwater Horizon BP Spill

Reports find levels of dioxins created during controlled burns were below levels of concern

WASHINGTON – The U.S. Environmental Protection Agency (EPA) today released two peer reviewed reports concerning dioxins emitted during the controlled burns of oil during the Deepwater Horizon BP spill. Dioxins are a category that describes a group of hundreds of potentially cancer-causing chemicals that can be formed during combustion or burning. The reports found that while small amounts of dioxins were created by the burns, the levels that workers and residents would have been exposed to were below EPA’s levels of concern.

Controlled burning of oil on the surface of the ocean (also called in situ burning) was one method used by the Unified Command during the Deepwater Horizon BP oil spill, to reduce the spread of oil and environmental impacts at the shoreline. A total of 411 controlled burn events occurred of which 410 could be quantified, resulting in the combustion of an estimated 222,000 to 313,000 barrels of oil (or 9.3 to 13.1 million gallons).

With support from the U.S. Coast Guard, EPA conducted sampling of emissions at the source of the controlled burns in the Gulf of Mexico to determine if dioxins were present. The sampling was conducted to identify potential dioxin exposures and determine the potential risks from inhalation to workers in the vicinity of the fires, risks from inhalation to the general population and risks to the general population from consuming fish caught in the area.

The first report summarizing EPA’s sampling effort indicates that while dioxins were created from the burning of oil on ocean water, they were created at low levels – levels similar to the emissions from residential woodstoves and forest fires.

The second report, co-authored with scientists from the National Oceanic and Atmospheric Administration (NOAA), presents the results of a screening risk assessment for the dioxins emitted from the controlled oil burns. The results indicate that increased cancer risk due to exposure to the dioxins released from the controlled burning of oil was small – less than a 1 in 1,000,000 increased cancer risk. Additional cancer risks for inhalation by workers and onshore residents and fish consumption by residents were lower than risk levels that typically are of concern to the agency. Typically, the agency has a concern when the risk is greater than 1 in 1,000,000.

Had the spill of oil continued, the results of these measurements would have been used by the Unified Command to determine if burning should continue. However, the well was capped on July 15, 2010 and the last in situ burn occurred on July 19, 2010. Consequently, these results are most useful to inform and improve the agency’s ability to respond to future oil spills.

EPA and other federal agencies have developed a broad set of questions and answers to provide the public with general information on dioxins, including what they are, where they can be found, and major sources of dioxins. The questions and answers explain the review process for the dioxin reassessment and discuss possible effects of dioxin exposure in humans, including advice about consumption of food that might contain dioxins.

Both reports and questions and answers about both reports: http://www.epa.gov/research/dioxin/

General information on dioxins: http://www.fda.gov/Food/FoodSafety/FoodContaminantsAdulteration/ChemicalContaminants/DioxinsPCBs/ucm077524.htm

Special thanks to Richard Charter

http://www.nola.com/news/gulf-oil-spill/index.ssf/2010/11/scientists_wary_of_bp_oil_spil.html

Times-Picayune
Published: Wednesday, November 10, 2010, 8:56 PM Updated: Wednesday, November 10, 2010, 9:05 PM
Mark Schleifstein, The Times-Picayune Mark Schleifstein, The Times-Picayune

Federal officials planning the recovery from the effects of the BP Macondo oil spill should remain on guard for signs of the collapse of fish or wildlife species in and around the Gulf of Mexico in the years to come, say more than 40 scientists gathered in Sarasota, Fla., to discuss long-term scientific responses to the spill.

The Associated PressScientists on Wednesday said they are ‘seeing clear evidence of impacts as recently as the end of the past week, with vivid photographs of deepwater coral impacted by what was referred to as a brown substance.’

At the top of their recommendations is the creation of a unified research and monitoring effort to detect the first signs of trouble with Gulf species and provide that information to management agencies to head off disastrous effects, said marine biologist Michael Crosby, senior vice president for research at Mote Marine Laboratory.

“Right now there is no agency that pulls together and coordinates all the information we need about the Gulf,” Crosby said Wednesday at the conclusion of the two-day symposium. “Scientists at different institutions might be collecting different pieces of data — but if we don’t put those together, we could miss the big picture until populations crash.”

The gathering at the private Mote Marine Laboratory was co-sponsored by the National Wildlife Foundation and the College of Marine Sciences at the University of South Florida. Attending were representatives of regional fishery management councils; local, state and federal resource management agencies; fishing and other industries; academic and independent research institutions; and environmental groups.

The participants focused on the potential for “trophic cascades,” changes affecting a single or multiple species in the Gulf food chain that could cause stress or declines in populations of organisms at other stages in the food chain.

Such a cascade is believed to have caused the collapse of the Pacific herring fishery in Alaskan waters in 1993, four years after the Exxon-Valdez oil spill.

“We’re seeing clear evidence of impacts as recently as the end of the past week, with vivid photographs of deepwater coral impacted by what was referred to as a brown substance,” Crosby said during a Tuesday news conference, referring to the findings of scientists at locations seven miles away from the BP Macondo well in coral fields nearly a mile beneath the ocean’s surface.

“They have seen oil in the gills of shrimp,” said William Hogarth, dean of South Florida’s marine sciences college and former assistant administrator for fisheries with the National Marine Fisheries Service, referring to varied reports of scientists along the Gulf coast. “There may not be an immediate effect on species right now, but we could be seeing such an effect in a year, three years, five years from now.”

Indeed, some scientists at the conference expressed concern that the effects of oil on endangered shark species or on their food sources could be the “tipping point” that pushes them into extinction, Crosby said.

Other species that could face long-term changes include shrimp, menhaden, blue crabs, various types of plankton, coral reefs, sargassum algae, seabirds, tuna, dolphins, sea turtles, and mackerel, tarpon and other key sport fish.

Scientists at the conference also raised concerns that information being gathered by federal, state and BP researchers as part of the federal Natural Resource Damage Assessment process will be kept from public distribution because of concerns it will be needed during possible court challenges.

“There are outcomes that should be shared with the general public and with organizations with the capability to act now on that data, and integrate it into strategic restoration and recovery projects,” he said.

A report on the symposium’s findings to be released in January also will include recommendations to create a Gulf-wide response group involving research institutions, state and federal governments, nongovernment organizations, and people who live and work on the Gulf.

It also will recommend creation of science-based models of how oil could affect the Gulf, creation of long-term research sites to monitor for future oil spill effects and other environmental problems, and money to pay for the new research programs.

Mark Schleifstein can be reached at mschleifstein@timespicayune.com or 504.826.3327.

Special thanks to Richard Charter

http://www.nola.com/news/gulf-oil-spill/index.ssf/2010/11/gulf_of_mexico_oil_spill_commi_2.html

Times-Picayune
Published: Wednesday, November 10, 2010, 7:00 AM
Bruce Alpert, Times-Picayune Bruce Alpert, Times-Picayune

Some early critics of President Barack Obama’s national oil spill commission are now praising the panel for conducting a thorough investigation of the BP oil spill in the Gulf of Mexico, although they say a final assessment awaits completion of the commission’s report in January.

“I’ve been happy with their interest in addressing the (drilling) moratorium because they indicated they weren’t responsible for that issue,” Rep. Steve Scalise, R-Jefferson, said Tuesday. He alluded to the advocacy by commission co-chairs Bob Graham and William Reilly for an early end to the Obama administration’s six-month moratorium on deepwater drilling, which was eventually lifted Oct. 12.

“Of course, we need to see what the final report says, but I think they’ve conducted a fairly thorough investigation,” Scalise said.

After Obama appointed the seven-member commission in July there was criticism that it lacked representation from the oil and gas industry and included members who have been industry critics.

“They’ve done a good job of discovery so let’s give credit where credit is due,” Rep. Bill Cassidy, R-Baton Rouge, said.

But Cassidy said his initial complaint that the panel lacked deepwater drilling expertise was borne out at Monday’s session when representatives of BP and Halliburton disagreed on responsibility for failing to detect a possible cementing failure the commission staff believes may have contributed to the disaster.

“If the commission had a petroleum engineer on its panel, it would have had an easier time dealing with the issue,” Cassidy said.
oil_spill_commission_bartlit.jpgView full sizeJ. Scott Applewhite, The Associated PressFred Bartlit Jr., chief investigator of the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, said he agreed with 90 percent of BP’s report on the Gulf of Mexico oil spill. He was photographed giving a detailed presentation of the operation of an offshore oil rig Monday for panel members, from left, Cherry A. Murray, William Reilly, Bob Graham, Christopher Smith, Frances Ulmer and Donald Boesch.

The commission won over some of its critics by spreading blame around, including some for the administration that appointed its members.

The commission last month criticized the Obama administration for not more quickly revealing that initial spill estimates from BP were substantially low and for not conducting more analysis on the environmental consequences of the massive use of chemical dispersants to dilute the spilled oil. Administration officials dispute those critiques.

The commission received some of its toughest public criticism after its chief counsel, Fred Bartlit, said Monday that the investigation found no evidence that BP, Transocean, Halliburton or any of the other companies involved with the Macondo well had cut corners on safety to save money.

“Why cut corners if it is not for money?” asked Plaquemines Parish President Billy Nungesser.

U.S. Rep. Ed Markey, D-Mass., also criticized the finding, saying BP had a history of not putting enough money into safety precautions.

But Graham, the commission co-chair, said the counsel’s statement might have been interpreted too broadly.

“The statement was that there was no evidence that there were conscious decisions made to trade off safety for profit,” Graham said. “I agree with that statement as it relates to those things that occurred on the oil rig itself.”

But he said the culture at the Macondo well “did not promote safety.”

“Leaders did not take serious risk seriously enough, did not identify risk that proved to be fatal,” Graham said.

Sen. David Vitter, R-La., asked to comment about the commission, didn’t offer any specific criticism. Instead, he suggested in a statement that its efforts might be in vain.

“Unfortunately, the oil spill commission has no real authority because the actual power lies with Carol Browner (energy policy coordinator) at the White House and Michael Bromwich at (Department of) Interior,” Vitter said. “Those Obama administration officials continue to fail the Gulf Coast by issuing ambiguous, sometimes unworkable regulations that prevent our people getting from back to work.”

Reilly also expressed concern that Congress, which hasn’t granted the commission its requested subpoena power, might not finance the robust regulatory staff needed to monitor future drilling operations.

Athan Manuel, director of the Sierra Club Lands Protection Program, said he has no complaints about the commission’s efforts to broker an early end to the deepwater moratorium, despite his group’s opposition to expanding drilling.

It was done in a way, Manuel said, that put into place new tougher safety standards.

“They’ve also been fairly creative in looking at the issues,” said Manuel, citing the commission’s review of whether safety protocols for nuclear power regulations could be applied to deepwater drilling.

________

photo: Dave Martin, The Associated Press Oil spill workers continue cleaning tar balls and oil from the beaches of Orange Beach, Ala., on Tuesday. A BP official said deep cleaning operations would continue along the coast for some time.

Washington bureau reporter Jonathan Tilove contributed to this story.
Bruce Alpert can be reached at balpert@timespicayune.com or 202.383.7861.

Special thanks to Richard Charter

http://www.fresnobee.com/2010/11/09/2153323/testimony-indicates-poor-cementing.html

McClatchy Newspapers

Posted at 05:06 PM on Tuesday, Nov. 09, 2010
By MARK SEIBEL – McClatchy Newspapers

WASHINGTON — Drilling engineers and government officials are almost lackadaisical in their approach to the critical steps of closing down an offshore oil drilling rig and sealing it, two days of testimony before a presidential commission investigating the explosion of BP’s Deepwater Horizon drilling rig indicate.

In testimony that concluded Tuesday, government officials, representatives of the companies drilling the well and outside engineers all testified to shortfalls that showed that the critical task of sealing the well with cement was filled with missteps and what commission co-chairman Bob Graham called “a series of almost inexplicable failures.”

More significantly, however, the panel’s deputy legal counsel, Sam Sankar, used the two days of detailed questioning to suggest that the failings aboard the Deepwater Horizon rig were not a one-time event but the result of lax oversight, inadequate regulation and inattention to detail that may exist on all deepwater drilling operations.

William K. Reilly, the panel’s other co-chairman, said regretfully that he had reached the same conclusion. “It is a systemic problem,” he said.

Those conclusions are likely to influence the commission’s final report, which is intended to both explain what happened in the Deepwater Horizon case and propose regulations to ensure that a similar disaster doesn’t take place in the future.

One example of the problems that emerged Tuesday was illustrated on BP’s drilling application for the Deepwater Horizon well in the Gulf of Mexico, which Sankar said called for using only a fraction of the cement needed to seal such a well. That fact didn’t trigger any questions from government engineers who approved the plan.

It was during those last phases of drilling that the Deepwater Horizon well exploded April 20, killing 11 rig workers and setting off a torrent of oil that caused billions of dollars in environmental and economic damage.

Investigators now think that the cement intended to seal the well failed and that crude oil and natural gas surged up the Deepwater Horizon’s drilling pipe when the rig’s crew began to remove heavy drilling mud and then replaced it with lighter seawater.

Sankar painstakingly built a case that while cementing – pouring a cement mixture into a well to block hydrocarbons from entering the pipe and the open areas surrounding it – is the most important guarantee that a well won’t explode, it’s often not the focus of intense engineering attention.

Worse, the operation, undertaken at the very end of a drilling job that has lasted months, often is overseen by engineers and crews who already are focused on their next assignment, not the one they’re completing.

“There’s a tendency for engineers to move on to the next thing,” Steve Lewis, a drilling engineer for Seldovia Engineering Consultants, which had no role in the Deepwater Horizon well, said in response to Sankar’s questioning.

Lewis added that in his experience, both engineers and the rig crews on offshore rigs tend “to lose focus” as they near the end of a job.

“Vigilance tapers off at the end of the process,” he said. “Temporary abandonment” – the phase the Deepwater Horizon was in – “deserves as much attention as all other aspects” of drilling a well.

In the Deepwater Horizon incident, this lack of vigilance, the testimony showed, led to a number of actions that seemed to defy best practices.

According to the testimony:

Halliburton, the company contracted to cement the Deepwater Horizon well, began pouring the cement before tests were complete that would show whether the mixture it was using would produce a stable seal.

Projecting Halliburton’s testing form on a screen in the hearing room, Sankar noted that the test had begun on April 18 and that the test takes 48 hours. But Halliburton already had begun pouring the cement before the test would have been complete.

The test was critical, because three previous tests of the cementing mixture had shown it would be unstable.

“Perhaps someone will explain to us why you didn’t wait for the test results,” Graham asked in his concluding remarks Monday.

-Halliburton failed to highlight in its earlier reports to BP that it believed BP’s well design would allow hydrocarbons to seep into the well and didn’t tell BP explicitly that tests on the cement it planned to use at the well had shown that it would not work.

Halliburton’s cementing manager for the Gulf of Mexico, Richard Vargo, said Monday that BP should have understood from the March 8 report that Halliburton foresaw problems. Sankar responded by displaying copies of the Halliburton report and asking if a small green shading on a graphic of one page of the report was the information BP should have detected.

He then asked Vargo on what page that graphic appeared. When Vargo demurred, Sankar blew the page number up on the screen – 23.

BP and Transocean, which BP had hired to drill the well, began removing heavy drilling mud from the Deepwater Horizon’s drill pipe only hours after Halliburton completed the cementing job. But Sankar, in a question he put to both Halliburton’s Vargo and BP’s Mark Bly, who oversaw BP’s internal investigation of the explosion, sought to show that the removal was premature. He asked if they didn’t agree that it took 48 hours to determine if cement in a well was going to hold. Both agreed.

Sankar continued his emphasis on a lack of attention to cementing in his questioning of Walter Cruickshank, the deputy director of the agency that oversees offshore drilling, now known as the Bureau of Ocean Energy Management, Regulation and Enforcement. It was called the Minerals Management Service at the time of the Deepwater Horizon explosion.

Displaying BP’s application, Sankar noted that it showed that BP planned to use 150 cubic feet of cement – an amount he said was equal to 26 barrels or 1,092 gallons – to close the well, even though federal regulations would seem to require more. In the end, Halliburton used 60 barrels; Sankar said BP had characterized even that amount as low.

Sankar also noted that there was nothing in federal regulations that specified what sort of cement should be used to close a well or how that cement should be tested.

Finally, Sankar asked Cruickshank what MMS had done about a study it had undertaken in 2007 that showed poor cementing as the reason for a huge number of well blowouts.

Cruickshank said MMS had brought the study to the attention of the American Petroleum Institute, a lobbying organization for large oil companies, and “discussed the need for better standards.” Cruickshank said API put together a committee and came up with those standards, which MMS implemented in May – a month after the Deepwater Horizon exploded.

Special thanks to Richard Charter