SEMS Audit Deadline is Right Around the Corner
All Outer Continental Shelf (OCS) oil and gas facilities have a deadline rapidly approaching. Operators impacted by the Safety and Environmental Management Systems (SEMS) rule must submit their first SEMS audit to the Bureau of Safety and Environmental Enforcement (BSEE) by November 15th, 2013.
Effective October 2010, the Bureau of Ocean Energy Management, Regulation and Enforcement published SEMS to reduce the frequency and severity of offshore accidents, injuries and spills by identifying, addressing and managing safety hazards and impacts. Also referred to as the Workplace Safety Rule, SEMS provides a flexible, performance-based approach to systematic safety in order to keep up with evolving technologies.
SEMS incorporates the previously voluntary 13 element system of the American Petroleum Institute’s Recommended Practice 75 (API RP 75) into a mandatory regulation. The 13 element system provides the framework for a SEMS comprehensive audit, consisting of elements such as hazard analysis, incident investigation, management of change, training and mechanical integrity.
Although the ultimate responsibility of meeting SEMS requirements rests with the operators, contractors must also be aware of the regulations to support operators in their efforts. Contractors are not required to have a SEMS plan but BSEE auditors may interview and/or test contractors during onshore or offshore SEMS audits. The BSEE may also review the operator’s SEMS program to confirm that it addresses how they evaluate the skills, knowledge and training of its contractors. Therefore, operators must have proper verification of their contractors’ skills and training in the event that the BSEE requests it.
To assist operators in verifying contractor competency, ISN has partnered with its customers to use the Training Qualification (TQ) tool within ISNetworld. Owner Client and Contractor Operator subscribers can create a configurable training matrix that assigns training requirements to each contractor job title. Contractors are able to access the training matrix, enter training details, upload certificates and generate and view reports capturing their training history. ISN simplifies the process of inputting employee and training data by offering templates that can be uploaded into the account.
In order to comply with the upcoming November 15th, 2013 audit deadline, oil and gas operators affected by the SEMS requirements must adhere to the following:
– SEMS plan must be formally audited by an Independent Third Party (I3P) or Designated and Qualified Personnel (DQP)
– Written audit plans must be submitted to the National SEMS Coordinator for the Office of Offshore Regulatory Programs at least 30 days before the audit
– Initial formal audit must be conducted within two years of a SEMS program implementation and once every three years thereafter
– Auditor will conduct a comprehensive evaluation of all 13 elements on at least 15 percent of the operator’s facilities, with a minimum of one facility
– Within 30 days after the audit concludes, the I3P of DQP must submit an Audit Report with their Corrective Action Plan, if applicable, to the National SEMS Coordinator
The BSEE has also been performing evaluations on operators since November 15, 2011 to verify that a SEMS program addressing all 13 elements is adhered to and effectively protects the environment and health and safety of its workers. To verify that your operations will pass a BSEE evaluation, the agency posted a list of Potential Incidents of Noncompliance (PINCs).
At the ISN Annual Users Conference, Doug Slitor, Acting Chief of the Office of Offshore Regulatory Programs, is presenting the new regulations and best practices for offshore operators and contractors as previously set forth by BOEMRE. BOEMRE, the Bureau of Ocean Energy Management, Regulation and Enforcement, was reorganized on October 1 into two separate entities: the Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE). Mr. Slitor explains the function and scope of these new bureaus’ work.
