Abstract

The Bureau of Ocean Energy Management has issued guidance for the implementation of Safety Environmental Management Systems (SEMS) for offshore oil and gas operations in the United States that are under federal jurisdiction. SEMS is based on the Safety Environmental and Management Program (SEMP) as described in API RP 75.

Introduction

Deepwater Horizon

The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) has issued its rule for the implementation of an offshore “Safety and Environmental Management System (SEMS)” as part of 30 CFR Part 250. It can be downloaded here. Further details are provided here.

The rule, which covers offshore waters under federal jurisdiction, is more comprehensive than the original proposed standard that was published in 2009 (see the knol From SEMP to SEMS). The increase in scope came about as a result of the Deepwater Horizon accident (April 2010).

The key to the rule is found in the following quotation, “The Workplace Safety Rule . . . makes mandatory the currently voluntary practices in the American Petroleum Institute’s (API) Recommended Practice (RP 75).”

The effective date for the new rule is November 15, 2010. Companies have one year in which to achieve compliance. Prior to the issuance of this document, there had been considerable discussion as to whether safety cases would become a requirement. At this point in time they have not.

Elements of SEMS

The proposed standard is based on the well-established Safety and Environmental Program (SEMP) as defined by API Recommended Practice 75. The elements of SEMS are listed below. Guidance for these elements is provided in the book Process Risk and Reliability Management. The pertinent chapter titles are shown.

General provisions for implementation, planning and management review and approval of the SEMS program.
Safety and environmental information: safety and environmental information needed for any facility, e.g. design data; facility process such as flow diagrams; mechanical components such as piping and instrument diagrams; etc.
Hazards analysis: a facility-level risk assessment. (Chapters 3 and 4).
Management of change: program for addressing any facility or operational changes including management changes, shift changes, contractor changes, etc. (Chapter 13).
Operating procedures: evaluation of operations and written procedures (Chapter 9).
Safe work practices: manuals, standards, rules of conduct, etc.
Training: safe work practices, technical training – includes contractors (Chapter 10).
Mechanical integrity: preventive maintenance programs, quality control (Chapters 6 and 7).
Pre-startup review: review of all systems (Chapter 8).
Emergency response and control: emergency evacuation plans, oil spill contingency plans, etc.; in place and validated by drills (Chapter 11).
Investigation of Incidents: procedures for investigating incidents, corrective action and follow-up (Chapter 12).
Audits: rule strengthens RP 75 provisions by requiring an audit every 4 years, to an initial 2 year reevaluation; and then subsequent 3-year audit intervals.
Records and documentation: documentation required that describes all elements of SEMS program.

A brief overview of each of these elements is provided below.

General Provisions

Information to do with the management of process risk and safety programs is available from the following: Management, Process Safety Management and Risk and Reliability.

Safety and Environmental Information

Guidance to do with the collection and management of technical information is provided at Process Safety Management.

Hazards Analysis

With respect to hazards analysis the MMS stated the following in a previous publication:

This element would require that a hazards analysis (facility level) be conducted for all facilities. The purpose of the analysis is to identify, evaluate, and where unacceptable, reduce the likelihood and/or minimize the consequences of uncontrolled releases of oil and gas and other safety or environmental incidents. With respect to analysis methods, MMS suggests that operators use API RP 14 C, Recommended Practice for Analysis, Design, Installation, and Testing of Basic Surface Safety Systems for Offshore Production Platforms, Seventh Edition, March 2001; or API RP 14J, Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities, Second Edition, May 2001, as guides, as well as other accepted documents and practices. In addition, this element would also require that a job hazard analysis (operations/task level) be performed to identify and evaluate hazards of a job/task for the purpose of hazards control or elimination.

Further information to do with hazards analysis is available from the following sources:

Management of Change

With respect to Management of Change the MMS states the following (also in a previous publication):

This element would require lessees/operators to document and analyze all proposed facility changes to determine possible adverse safety and environmental impacts, with the exception of replacement in kind. There are a number of specific topics to be covered in this analysis, including changes in: facilities and procedures, personnel, work practices, equipment (including addition of new equipment or modifications to existing equipment), and the safety and environmental implications of these changes.

Operating Procedures

With respect to Operating Procedures the MMS has stated the following:

This element would require OCS oil and gas operators’ management officials to include requirements for written facility operating procedures designed to enhance efficient, safe, and environmentally sound operations.

While operating procedures are reviewed as part of MOC procedures, MMS would also recommend that these procedures be reviewed separately to ensure that they reflect current practices.

Safe Work Practices

Information to do with safe work practices is available at Inherent Safety and Behavior Based Safety.

Training

The topic of training includes contractors.

Mechanical Integrity

The BOEM has stated the following regarding Mechanical Integrity:

This element would require that procedures are in place to ensure that equipment is designed, fabricated, installed, tested, inspected, monitored, and maintained in a manner consistent with appropriate service requirements, manufacturer’s recommendations, and industry standards to promote safe and environmentally sound operations in the OCS.

Prestartup Review

Information to do with prestartup reviews and operational readiness is provided in the free ebook Prestartup Safety Reviews.

Emergency Response and Control

One of the reasons that the Deepwater Horizon event was so serious was that the emergency response was not as effective as it should have been, resulting in additional fatalities.

Investigation of Incidents

Information to do with incident investigation and root cause analysis is provided at Incident Investigation and Root Cause Analysis.

Audits

Regarding audits, the BOEMRE has previously stated that,

This proposed rule would require lessees and operators to have their SEMS program audited at least once every 3 years by either an independent third party or by qualified personnel designated within the company. A knowledgeable and experienced auditor would audit the SEMS program to determine if an OCS lessee and operator is complying with the SEMS plan.

These audits would be conducted in an office environment and/or in the field, and cover both a broad range of activities or be focused on a particular area (e.g., records, gas compressors, blowout preventers, or documentation) as appropriate. Auditors must meet the qualifications as proposed in this rule.

The BOEMRE may approve independent third parties to conduct audits.

Audit protocols written for the SEMP program for four of the elements can be downloaded here:

Records and Documentation

The SEMS program must be fully documented (which gives it some of the features of a safety case)

suttonbooks

Safety and Environmental Management System (SEMS)