The loss of the world’s largest floating deepwater production platform, Petrobras’ P-36, last month off the coast of Brazil with the loss of 10 men will reverberate throughout the oil industry for years to come. We do not yet know what happened to the unit other than that there were reported to be three separate explosions after which the unit took on severe list of about 24 degrees and sank several days later. Was the unit unsafe? Was it operated improperly? We do not yet know the answers and may never know all the answers. Here in the U.S., the USCG continues to go forward with the regulatory project that would modify the rules on the US Outer Continental Shelf (OCS).