Third-Party Audits Proposed for Offshore Operations

BOEMRE has decided independent audits are needed, plus procedures authorizing any employee to stop work upon seeing a regulated activity that endangers a person, property, or the environment.

The Bureau of Ocean Energy Management, Regulation and Enforcement, the federal agency recently created to regulate safety in offshore energy operations, proposed Sept. 14 to require operators to undergo independent third-party audits of their Safety and Environmental Management Systems (SEMS) programs. BOEMRE is removing the option for operators to use their own designated and qualified personnel to audit their SEMS programs.

Aggregated data from the audits will be made public under BOEMRE's proposed rule, which applies to oil, gas, and sulphur operations in the Outer Continental Shelf.

BOEMRE proposed the SEMS requirement last October. If a facility's activities fall under the purview of Coast Guard or DHS regulations, however, those regulations would take precedence.

BOEMRE says the SEMS regulation is needed to prevent a repeat of the Deepwater Horizon explosion, well blowout, and oil spill that began April 20, 2010. The explosion killed 11 workers. (BP continues to explore and operate in the Gulf of Mexico, with the company’s chief executive, Bob Dudley, announcing a new successful appraisal well Sept. 7 in a previously untested part of the Mad Dog field located about 140 miles south of Grand Isle, La. BP said it has a 60.5 percent working interest in the field.)

Other changes in the new BOEMRE proposed rule include requiring operations covered by the rule to establish procedures that authorize any employee on the facility to implement a Stop Work Authority program when he or she witnesses an activity that is regulated under BOEMRE jurisdiction and creates a threat of danger to an individual, property, and/or the environment. They'd also have to have clearly defined requirements establishing who has the ultimate authority on the facility for operational safety and decision making at any given time; as well as an action plan showing how operator employees are involved in implementing the American Petroleum Institute's Recommended Practice for Development of a Safety Environmental Management Program for Offshore Operations and Facilities (API RP 75), which is referenced in subpart S of the SEMS final rule.

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