Bureau seeks industry input on SEMS implementation, KPIs
Chief of Offshore Regulatory Programs, Bureau of Safety and Environmental Enforcement
WASHINGTON, D.C. - It has been over four years since the Bureau of Safety and Environmental Enforcement (BSEE) issued the Safety and Environmental Management Systems (SEMS) regulations, which provide the cornerstone of our hybrid regulatory approach. Our goal for the SEMS program is to encourage the offshore oil and gas industry to adopt an approach to safety that looks beyond baseline compliance with regulations toward an underlying safety culture that promotes continuous improvement in safety and environmental performance. SEMS is meant to be a tool through which companies manage the impacts of human behavior, organizational structure, leadership, standards, processes, and procedures – not simply a compilation of required documentation.
Our review of the first round of SEMS audit reports revealed that there is a wide range of comfort and experience levels among operators with respect to using management systems to identify and reduce process safety and environmental risks on the outer continental shelf.
The most common approach to SEMS audits was simply to utilize a Center for Offshore Safety (COS) checklist to document differences between the operator’s written management system requirements and the BSEE regulatory requirements.
While the overall compliance for this first round of audits was excellent, there is a need for more detailed information in each of the submitted audits to demonstrate that an operator’s SEMS plan is comprehensively being implemented in the field.
A SEMS program is not meant to be a check-the-box compliance exercise; rather, it is meant to increase the value of “lessons learned” during audits and help to identify potential areas for improvement in the overall safety culture of the industry. For this to happen, auditors will need to be well-trained and perform comprehensive assessments of the implementation of management systems in the field to reduce operational risks. The focus of BSEE in the next cycle of its SEMS program will be to ensure that the audits and reports accurately demonstrate the status of the program’s implementation on a daily basis.
Several other areas were identified that we feel warrant further discussion and more engagement from stakeholders, these include: the interaction between contractors and subcontractors; data sharing; key performance indicators; and the identification and management of risks and safety barriers.
Another lesson learned both from SEMS audits and from a dialogue with key industry stakeholders is that there is a need for more robust coordination between operators, contractors, and subcontractors to ensure that a SEMS program adequately applies to all entities involved in operations. There has been considerable discussion on this topic at nearly every COS meeting that I have attended, though there does not seem to be consensus on this issue. So I am asking you, the reader, should the SEMS program be expanded to directly apply to contractors or is there an alternative means to improve SEMS implementation when multiple entities are working together on a project or facility?
A key part of a good safety culture within an organization is a willingness to share safety data and lessons learned. For this to happen, there has to be a mechanism in place to allow for the collection and dissemination of important proprietary data. With that in mind, we have partnered with the Bureau of Transportation Statistics to create a confidential near-miss reporting system called SafeOCS. It will be a program that can take in confidential audit information, aggregate data, and analyze trends that will help to inform the whole industry on safety trends.
Another potentially important measure of the efficacy of a SEMS program is key performance indicators. KPIs are quantifiable measurements reflecting critical success factors of an organization.
BSEE would like to hear from you on what KPIs should be used for beyond those that measure occupational health and safety issues and whether the Bureau should provide guidance on how to develop and use operator-specific KPIs.
In the years following the Deepwater Horizon tragedy, numerous investigations were conducted that highlighted the need for enhanced risk management – more specifically, focusing on identifying process safety hazards and ensuring that there are enough properly maintained safety barriers in a well to minimize the risk of another catastrophic event like the Macondo blowout. The Bureau is supplementing the current process safety requirements through the proposed well control and production safety systems rules. At this time, we are also considering supplementing the SEMS requirements to include additional process safety management requirements related to the analysis of hazards, risk mitigation measures, and the identification and maintenance of safety barriers.
In the months ahead, we will be asking for stakeholder input on ways to better achieve the goals of a robust SEMS program. We will be working with the Ocean Energy Safety Institute to hold a workshop on this important issue on July 29, 2015 in Houston. I hope that you will join us for that discussion and help us to further enhance this critical safety program.