Insights: Jane Bugler - Technical Director, IMCA

Marine News

Our Offshore Annual edition of MarineNews headlines Jane Bugler, the Technical Director of the International Marine contractors Association (IMCA). Jane is a chartered chemical engineer who worked in the chemical industry for several years before joining the UK Health & Safety Executive (HSE), where she worked in a variety of roles (including work regarding pipeline regulation) before joining IMCA in 1997, when she became Technical Director. Today, Jane has overall responsibility for the extensive and varied technical program of IMCA and for liaison between IMCA and external organizations, including other trade associations such as OGP, OCIMF and IADC, as well as regulators such as PSA, HSE, and the U.S. Coast Guard. 
For her part, Bugler says enthusiastically, “Anything and everything marine and technical is my passion. IMCA is a great forum for debate and leadership.” Jane is IMCA’s authority on technical issues, and her work includes coordination of IMCA’s technical team through their own work with IMCA’s committees and workgroups, drafting of guidance and briefing, review of third-party drafts, oversight of technical audits of both applicant members and those seeking recognition of certain training courses. In the absence of IMCA Chief Executive, she steps up to fill that role as necessary. IMCA is a trade association and exists for the benefit of its members across the offshore, marine and underwater engineering industry. IMCA’s regional sections enable members to address issues specific to their local area and ensure the global applicability of the association’s world-wide activities. IMCA was founded in 1995 through the merger of the Association of Diving Contractors (AODC) and the Dynamically Positioned Vessel Owners Association (DPVOA). This month, Jane Bugler weighs in on the offshore industry, where it is today, and what can be done to strengthen its position looking forward.     

What are the biggest risks facing your member companies today?
The price of oil: the vast majority of our 1,000+ members in more than 60 countries work for the offshore oil and gas industry. Some have become involved with the offshore renewables industry, but that is not without its own problems and delays. We are, no doubt, heading to a period that will see mergers and acquisitions taking place.

Has the issue of Jones Act and the question of registered tonnage carrying goods and materials offshore U.S. Gulf of Mexico been fully resolved or is it an ongoing bone of contention?
IMCA members and their oil company clients are continuing to work with U.S. Customs and Border Protection to ensure longstanding interpretations of the Jones Act continue to be applied in a straightforward and pragmatic way.

IMCA is focusing on “maintaining safety in the current challenging environment.” Has there been an uptick in offshore safety issues and/or incidents, or do you see this effort as a pre-emptive measure?
This is very much pre-emptive. We publish annual safety statistics, and encourage members to send us information on incidents for our safety flashes, and are certainly not seeing any upturn in incidents or safety issues. Indeed, we are seeing members eager to maintain high safety standards.

You’ve talked about the need to look at developing solutions that are “fit for purpose, but not necessarily gold plated.” That sounds good, but what does it mean? Give us a garden variety example of that in operation today.
I was recently at a conference in Stavanger where this was much discussed. Engineers like, indeed thrive on, improving solutions. However, it is important that their improvements do not add cost. There was discussion in Stavanger about solutions being “good enough.” Those words it seemed had an almost negative connotation, we have to understand that “good enough” means that it does the job, it’s fit for purpose, it does not need further improving, we are looking for cost effective solutions. We have our contracts workshop coming up soon, and no doubt so-called ‘gold-plating’ will be on the agenda. The words of introduction to the event spell out our position: “The event will look at the contractual allocation of risk in a difficult market - from the perspective of contractors and insurance brokers seeking a fairer apportionment of risk as a means of reducing contractual uncertainty and duplicative insurance costs inherent in current EPIC contracting models.” Realism is the name of the game.

IMCA prides itself on adding value; not cost. Give us another example of that metric in play.
All our guidance is aimed at adding value and not cost – the last thing we want to recommend in guidance is adding to operating costs. Working on behalf of our members through our contracts group, we aim to ensure that we help IMCA members give value at realistic cost levels. As an aside, all of our guidance documents can, of course, be downloaded free of charge by members and non-members alike.
In the last big oil downturn, occurring in the mid-1980’s, the offshore and oil industries shed so many employees so fast that many, if most, never came back, once things turned around. What do you see happening this time?
It’s really too early to tell; in a tight market, though, it is inevitable that people leave the industry.  One thing that IMCA is doing is looking at ROV (remotely operated vehicle) training – there may be a downturn now, but there is always a need to look to the future. Standardization of training globally will certainly bring benefits to the industry.

With over 1,000 member companies in more than 60 countries, IMCA says it is well-placed to take the ‘temperature’ of this vital part of the supply chain. In what areas are you benchmarking performance, and what do you see? 
We don’t run benchmarking exercises, but members of the technical team at IMCA (my team comprises a Technical Manager and up to eight Technical Advisers) travel the globe, attending our regional section meetings (we have five regional sections), holding niche workshops and generally working with members in their part of the world. While there we listen and learn.

IMCA strives to “champion better regulations and enhance operational integrity.” Talk a bit about the regulations you hope to influence, and how you intend to do just that.
The news, carried by your own publication, that the International Maritime Organization (IMO) has agreed to use the International Marine Contractors Association (IMCA) proposals as the basis for the review of the IMO Guidelines for vessels with dynamic positioning (DP) systems (MSC/Circ.645), is just one case in point. Taking an active part in other IMO discussions remains crucial and is a service to our entire membership. So, too, do relationships with other key organizations, for example the U.S. Coast Guard – we are providing feedback on their proposals for  new regulations on DP systems and an update of the rules for Commercial Diving Operations. We continue to monitor activity on the regulatory front and put forward view and suggestions. By means of maintaining good working relationships with regulatory bodies, we can bring our influence to bear. Recently appointed regional directors in Asia, and Australia and New Zealand help us in those areas; and we look forward to making more similar appointments in key oil provinces around the globe.

Has the current dip in oil pricing impacted IMCA’s membership roles in a similar way?
We are happy to report that we certainly haven’t seen a sizeable dip. We do expect some consolidation thanks to mergers and acquisitions, but we are still seeing inquiries about membership, for there is no doubt that in difficult times, trade association membership can be a financial help, as member companies can get on with day-to-day business and rely on the trade association to monitor and respond to consultations on new regulations and other similar moves.

The need to ensure that safety levels remain high despite a lower oil price is easier said than accomplished. IMCA also says that changing behavior will be the key to that effort. This involves – in your words – people, efficiency, logistics and planning, standardization and simplification. Name one place where this approach has worked well.
The adoption globally of the IMCA competence assessment framework has been invaluable – or so we are told by companies and their clients. A competent workforce is a safer and more efficient workforce, and what’s more, it has a knock-on effect with clients implementing their own competency schemes.

In the UK, regulators are concerned about the drop in oil prices that, in the past, this has led to deterioration in structures and cutbacks on maintenance. Has this manifested itself just yet or are we too early in the ‘oil crunch?’
It is too early to tell, but we must remember that the offshore industry is heavily regulated and monitored, so any drop in quality of maintenance would most certainly be picked up quickly. Member companies are heavily involved with IRM (inspection, repair and maintenance) contracts.

We are almost five years on to the anniversary of the Macondo Deepwater blowout. Compare today’s offshore oil industry – in terms of safety, standards & preparedness – to that which existed on the day of the tragic casualty.
The U.S. new regulatory regime has been implemented and is looking at key issues – such as DP, for example. In the U.S., the introduction of Safety and Environmental Management Systems (SEMS) has had a knock on effect for IMCA members, particularly via the contractor management requirements, where once again the IMCA competence frameworks and guidance have proved a useful tool for demonstrating compliance. 

The cutting of the UK Petroleum Revenue Tax (PRT) from 50% to 35% to support production in older fields is helpful. And the reduction of the supplementary charge for oil companies from 30% to 20% will also free up some capital. Similar moves are being considered elsewhere. Will they be enough to bridge the gap between solvency and disaster?
This is really an oil company issue. However, IMCA members have experience of rising costs and lowering investment in oil and gas from previous oil price slumps. However, the key really is how contractors respond to oil price recovery. Reduction of the workforce and the layup of vessels can be the easiest choice to reduce costs, sometimes followed by the sale of assets. Members are cognizant of the fact that the retention of necessary skill sets and assets during this market downturn can, for those who ride the storm, create a position whereby they can quickly take full advantage of any market recovery.

(As published in the May 2015 edition of Marine News -

Marine News Magazine, page 12,  May 2015

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