The requirement to address all 13 elements of a SEMS plan is a new challenge for some offshore operators. (BP photo)

Coming to Grips with SEMS

Requiring offshore operators to submit and then audit a Safety and Environmental Management Systems plan means their training and safety management elements will stay current.

The U.S. Interior Department's Bureau of Safety and Environmental Enforcement required all operators and lessees working the Outer Continental Shelf to submit a Safety and Environmental Management Systems (SEMS) plan by Nov. 15, 2011. The SEMS final rule took effect one year earlier, only five months after the Deepwater Horizon drilling rig explosion and oil spill in the Gulf of Mexico, but the concept of SEMS originated years before. It incorporates by reference an American Petroleum Institute standard originally published in 1993: RP 75, Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities.

Still, the requirement to address all 13 elements of a SEMS plan is a new challenge for offshore operators. Both SEMS and the investigations of the 2010 oil spill have affected the operators' training, said Chris Kuiper, founder and president of Environmental Health & Safety Inc., a Woodlands, Texas-based consulting firm that works with many oil and gas companies.

"BSEE expects the operator to provide the necessary training to ensure personnel have the necessary skills and knowledge to accomplish their work safely, and the petroleum industry has done much to enhance training quantity and quality over the past 10-plus years," he said. "Operator personnel are generally well trained and skilled in their work. The contractor community has also improved training to better prepare their employees for the skills and knowledge needed for their work. Some core safety training provided to contractors has been standardized -- and while the concept is right, not all operators have implemented the program.

"The Deepwater Horizon has caused the entire industry to evaluate what it does and how it does it from safety, environmental, operational, training, and other aspects. The good news is many operators had already implemented some form of a HSE management system before the incident. The even better news is the Deepwater Horizon loss was not in vain, and the industry is continually improving programs and processes to further identify, assess and manage risks to the business," Kuiper said.

"Employee training has always been taken very seriously by the industry," said Angelo Pinheiro, CSP, CPEA, a renowned Houston-based HSE expert in the upstream oil and gas industry and API's primary representative on the ANSI Z10 Occupational Safety and Health Management Systems Standard. "And training-related overload is often complained about by individuals who must attend courses or classes during time off," he continued. "There are numerous API safety and environmental training standards in addition to the Safegulf curriculum, which has been adopted by most operators as the minimum offshore safety training standard. As well, operators are increasingly training their employees on company HSE management systems, safety leadership, safe transportation, and hazard awareness. Competency requirements are mandated for offshore positions such as rig managers, toolpushers, drillers, offshore installation managers, crane operators, riggers, ballast control operators, subsea operators, medics, radio operators, and maintenance/trades positions. Emergency response crews are trained and exercised regularly. The Deepwater Horizon incident will cause operators to pause and review their existing training and competency assurance programs for comprehensiveness and effectiveness, and that could further strengthen these programs."

The Minerals Management Service, predecessor of Interior's BSEE and Bureau of Ocean Energy Management agencies, proposed mandating four parts of SEMS (hazard analysis, management of change, operating procedures, and mechanical integrity) in 2009, the same year in which an MMS study found 60 of 130 offshore operators did not have a SEMS program in place. Many small to mid-sized operators did not, Pinheiro said.

"BSEE's SEMS requirement is significant in the sense that operators who were long used to dealing with defined, prescriptive regulations of the MMS and Coast Guard must now implement a performance-based management system," he explained. "This will require a paradigm shift in the cultural mindset, particularly by smaller operators who did not have a SEMS program or one that only partially fulfilled the requirements. Operators will need to perform a detailed gap analysis of their SEMS against the RP75 standard, identify and prioritize corrective actions to close out the deficiencies, and allocate additional resources to come into compliance. As a significant portion of the work is performed by contractors, large and small, ensuring that they have policies, programs, processes, and procedures that are compatible with the operator’s SEMS will pose a challenge."

Kuiper agreed. "The SEMS requirements are more robust ... and are performance driven. The rule lists management system elements every company should have in place, but it is not overly directive in how the company should implement the programs," he said. "BSEE does expect a company's safety management system to be functional and to demonstrate continual improvement. For example, API RP 75 only asks whether a company has a Risk Assessment process, not how it is done. BSEE expects the company to demonstrate how the process is implemented at all levels of the organization."

The International Association of Drilling Contractors (IADC) released a SEMS Toolkit in August 2011 that helps operators demonstrate their compliance with the SEMS requirement. The staff of Houston-based IADC worked with an Offshore Operators Committee task force, in cooperation with the Center for Offshore Safety, to develop the readiness and implementation tools, including matrices for mandatory safety training on numerous OSHA topics (fall protection, electrical safety, HAZWOPER, lockout/tagout, respiratory protection, confined spaces, and more) that operators and contractors can use. IADC has two accreditation programs, WellCAP® for well control and Rig Pass® for safety orientation of new rig workers, that accredit dozens of training providers.

The toolkit also contains an audit checklist, PowerPoint presentations, and worksheets for documenting employees' knowledge, skills, and work experience. "That's a lot of what the SEMS is focused on: Enabling companies' customers to document their compliance," said Steve Kropla, group vice president of operations and accreditation for IADC. "We put a lot of horsepower into it. It's there not only for [operators], but also for the contractors."

Kuiper agreed that SEMS by extension affects contractors. "This presents a fantastic opportunity for contractors who support the petroleum industry offshore and onshore to build and further enhance their HSE management systems," he said. "I frequently hear contractors say the SEMS rule is does not apply to them, so why are they being audited? The reality is, operators we work with expect their contractors to partner with them and to share a vision and process to enhance safety for everyone. Operators are often open to helping contractors who want to improve their HSE management systems by sharing sample programs, procedures, and materials and provide mentoring. Contractors who take the SEMS process as seriously as the operators are more likely to enjoy continued business than those who see SEMS as 'just another program.'

"Managing HSE is just as important as any other business element, such as engineering, operations, or finance. The way contractors and operators respond to and implement their SEMS is directly reflective of the company's culture. The days of 'just get it done' without much consideration for safety are gone," he added.

Third-Party and Internal Audits
BSEE says the SEMS plans must be audited by independent third parties or qualified personnel. Kuiper said the audit is a comprehensive evaluation of the implementation of the 13 SEMS elements and a field evaluation of at least 15 percent of the company's facilities, done within two years of initial implementation of the operatorh's program and then every three years thereafter.

"This does not preclude an operator conducting internal audits more frequently. And in the spirit of continuous improvement, many companies have implemented planned internal reviews to ensure their management system functions as intended," he said. "There is difficulty with the independent third party auditor -- I3P -- aspect of the rule. Simply put, there are few qualified professionals available to do the audits. Some larger consulting companies have been working with the operators to help them develop their SEMS. But, ethically, they cannot audit their own work, so finding qualified I3Ps -- and what constitutes 'qualified' is a major point of discussion -- is somewhat problematic. I think a key aspect of the audit implementation will be identifying teams of experienced safety, operations, and training professionals who will audit a company's system and site implementation. Finding a seasoned safety auditor with extensive offshore operations experience is a significant challenge and a great opportunity for those who have the expertise."

He said BSEE has stipulated that independent auditors should perform the regulatory required audits. "The advantage to a company conducting its own audits is they know their system better than anyone, including the opportunities for improvement," said Kuiper. "As a safety professional with extensive audit experience, I find the key advantage to using an external expert is the myopia that sometimes develops looking at one's own system is averted. The I3P can provide an unbiased perspective."

Moved Too Fast?
Pinheiro said he believes the federal agency should have worked more closely with the regulated community as the SEMS requirement was being developed.

"Although I am a firm believer in safety management systems, I believe RP75 SEMS was hastily legislated post-Macondo without fully engaging and resolving the concerns of stakeholders," he said. "Management standards are performance based by design and do not lend themselves easily to legislation. There are nuances and interpretations to consider within the language of a management standard which makes it difficult to demonstrate compliance on certain aspects. Industry made its concerns known through API, IADC, and others throughout the public comment periods. A phased approach to SEMS might have allowed the wrinkles to be ironed out."

For More Information
www.iadc.org/sems-toolkit/
http://bsee.gov/
http://www.iadc.org/accreditation/iadc-hse-rig-pass-program/hse-rig-pass-accredited-training-providers/
http://www.iadc.org/accreditation/iadc-accreditation-programs/accredited-wellcap-providers/

This article originally appeared in the February 2012 issue of Occupational Health & Safety.

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