An E&P operator's contracts team approved a stimulation contractor for a multi-well completions program. The contractor's COI showed $5 million in commercial general liability coverage - sufficient on its face. The MSA required, in addition to CGL, contractor's pollution liability with a minimum limit of $10 million, control of well coverage if the contractor was performing wellbore work, and the operator named as additional insured on all lines. The COI showed no pollution liability. The control of well coverage section was blank. The AI designation was on the CGL only. None of this was caught because the COI was checked against a generic oilfield standard rather than the specific MSA requirements.
Six weeks later, a pressure event during a frac job resulted in a wellbore incident and a spill. The contractor's CGL had a pollution exclusion. The contractor had no CPL policy. The cleanup and containment costs were $3.8 million. The operator's own coverage responded, but the operator had no right of indemnification from the contractor because the contractor's coverage was inadequate - and the operator could not demonstrate the contractor had ever been required to have the missing coverages on file.
This checklist is designed to prevent that outcome.
Checklist Overview: What Makes O&G Contractor Compliance Different
Oil and gas contractor COI compliance differs from standard commercial contractor compliance in three ways:
- Specialized coverage types - pollution liability, control of well, operator's extra expense, and contractor's pollution liability are standard requirements in upstream O&G that do not appear in most commercial contractor programs
- Complex MSA structures - oil and gas MSAs typically have multi-tiered insurance exhibits with site-specific addenda that modify base requirements; verification must be against the complete MSA package, not a single insurance clause
- High consequence of error - a missed coverage gap in upstream O&G can produce a single incident costing millions; the verification standard must match the risk profile
The Complete O&G Contractor COI Checklist
Section 1: Mandatory Commercial Lines Coverage
Commercial general liability (CGL)
- Per-occurrence limit meets or exceeds MSA minimum
- Aggregate limit meets or exceeds MSA minimum
- Coverage does not include blanket pollution exclusion without CPL coverage to fill the gap
- Operator named as additional insured
- Waiver of subrogation in favor of operator endorsed
- Primary and non-contributory language confirmed
Workers' compensation and employer's liability
- Statutory workers' compensation coverage confirmed
- Employer's liability limits meet MSA minimums (typically $1M/$1M/$1M)
- Coverage applicable to state(s) where work is performed
- USL&H coverage if offshore or navigable waters work included
- Waiver of subrogation in favor of operator endorsed
Commercial auto liability
- Combined single limit meets MSA minimum
- Covers owned, hired, and non-owned vehicles
- Operator named as additional insured
- Waiver of subrogation in favor of operator endorsed
Umbrella/excess liability
- Follows form over underlying CGL, auto, and employer's liability
- Limits meet MSA minimum when combined with underlying coverages
- Operator named as additional insured
- Does not contain aggregate limits that create gaps not present in underlying coverage
Section 2: O&G-Specific Coverage Requirements
Contractor's pollution liability (CPL)
- Coverage is present (not excluded, not blank)
- Per-claim and aggregate limits meet MSA minimums
- Coverage applies to the types of pollutants relevant to the work scope (hydrocarbons, H2S, produced water)
- Transportation of pollutants covered if contractor transports produced fluids
- Operator named as additional insured where MSA requires
Control of well / blowout and cratering
- Coverage present if contractor is performing wellbore work (completions, workover, drilling services)
- Per-occurrence limit meets MSA minimum
- Coverage includes redrilling/restoration costs as specified in MSA
- Operator named as additional insured
Operator's extra expense / OEE
- Review MSA to confirm if this is required of the contractor or only the operator
- If required: coverage present with limits meeting MSA minimum
Professional liability / errors and omissions
- Required for contractors providing engineering, geoscience, or technical advisory services
- Per-claim limit meets MSA minimum
- Claims-made policy: prior acts coverage confirms no gap
Section 3: Named Insured and Additional Insured Verification
Named insured match
- Named insured on COI matches the legal entity name in the MSA exactly
- If the contractor operates under a trade name, confirm the legal entity behind the name
- Multiple named insureds: confirm which entity is performing the work
Operator as additional insured
- Operator's legal entity name matches AI designation exactly
- AI designation present on CGL, umbrella, CPL (if applicable), and control of well (if applicable)
- AI endorsement form identified (blanket or scheduled)
- Completed operations AI included if work involves wellbore or structural completions
Landowner and royalty owner AI requirements
- Review MSA for additional AI requirements beyond the operator
- Landowner AI required in some MSAs and surface use agreements
- Royalty owner AI is uncommon but present in some legacy MSAs
Section 4: Endorsement Requirements
Waiver of subrogation
- Confirmed on workers' compensation (always required)
- Confirmed on CGL (required if in MSA)
- Confirmed on umbrella (required if in MSA)
Primary and non-contributory
- Confirmed on CGL where required by MSA
- Endorsement language matches MSA requirement (not just checked on ACORD form)
Notice of cancellation
- 30-day advance notice of cancellation confirmed
- 10-day notice for non-payment of premium confirmed if required by MSA
Section 5: Limit Verification Against MSA
| Coverage Type | MSA Required Limit | COI Shown Limit | Compliant? |
|---|---|---|---|
| CGL per occurrence | $__M | $__M | Y/N |
| CGL aggregate | $__M | $__M | Y/N |
| Auto CSL | $__M | $__M | Y/N |
| WC/EL (each accident) | $__M | $__M | Y/N |
| Umbrella/excess | $__M | $__M | Y/N |
| CPL per claim | $__M | $__M | Y/N |
| COW per occurrence | $__M | $__M | Y/N |
Complete this table for every contractor COI. Any cell showing "N" is a compliance deficiency that must be resolved before the contractor is authorized to mobilize.
Section 6: Coverage Dates
- All policies have effective dates on or before the contractor's mobilization date
- All policies have expiration dates that cover the expected work period
- If any policy expires during the work program, a commitment to provide renewal certificates is documented
- No coverage gaps (period between expiration and renewal) for any line
How Manual MSA Reading Fails in Practice
The checklist above requires reading the MSA insurance exhibit carefully to populate the "MSA Required Limit" column. For a contractor pool of 30-50 contractors, each governed by a slightly different version of the operator's standard MSA (some with site-specific addenda, some without), that reading requirement is where manual compliance programs break down.
A contracts manager who is also managing land issues, lease obligations, and AFE approvals will not give a fresh read to each MSA insurance exhibit every time a COI is submitted. They will work from memory of the "standard" requirements - missing the site-specific modifications that change the requirement in a particular MSA version.
Automated contract-to-COI comparison through platforms like Bramble addresses this by reading the full MSA - including exhibits and addenda - extracting the complete requirements package, and running comparison against the submitted COI automatically. The checklist logic is applied consistently, without the cognitive shortcuts that produce missed deficiencies in manual programs.
For E&P operators managing large contractor pools, the operational investment in automated compliance is directly proportional to the reduction in undetected compliance gaps - and the financial exposure those gaps represent.
See how Bramble handles oil and gas MSA compliance - from requirement extraction through contractor COI verification. Book a demo at getbramble.com/demo to walk through the O&G compliance workflow.