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This comprehensive guide delves into the SEMS requirements and elements for OCS oil and gas operations, highlighting the importance of promoting safety and environmental protection. Learn about SEMS II modifications, auditing processes, and future considerations for SEMS III, emphasizing the need for continuous improvement in the industry. Stay informed on key players like COS, OOC, and BSEE, and understand the significance of effective communication, employee participation, and performance measurement in SEMS implementation.
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SEMS 101 SAFETY & ENVIRONMENTAL MANAGEMENT SYSTEM
MANAGEMENT SYSTEMS • INTERNATIONAL • SOLAS International Safety Management Code • International Standards Organization • ISO-9001 – Quality Management Systems • ISO-14001 – Environmental Management Systems • NATIONAL • NIST Malcolm Baldrige Performance Excellence Program • Leadership • Strategic Planning • Customer Focus • Measurement, Analysis, and Knowledge Management • Workforce Focus • Operations Focus • Results • BSEE SEMS
ORIGIN OF SEMS • Piper Alpha Disaster (July 1988) • API RP 75 (May 1991) • UK’s Offshore Installation (Safety Case) Regulation (1992) • Deepwater Horizon Disaster (April 2010) • 30 CFR 250 (November 2011) • Mandatory • Performance Based Regulation (not prescriptive)
APPLICABILITY - OPERATIONS • SEMS applies to all OCS oil and gas OPERATIONS under BSEE jurisdiction including: • Drilling • Production • Construction • Well Workover • Well Completion • Well Servicing • DOI Pipeline Activities
APPLICABILITY - FACILITIES • SEMS applies to all OCS oil and gas FACILITIES under BSEE jurisdiction including: • Fixed • MODU • FPS • FPSO • TLP • SPAR • DOI Regulated Pipelines
APPLICABILITY - PHASES • SEMS applies to all OCS oil and gas operations on new and existing facilities under BSEE jurisdiction including: • Design • Construction • Start-up • Operation • Inspection • Maintenance
GOAL OF SEMS • 30 CFR 250.1901 - The goal of your SEMS program is to promote safety and environmental protection by ensuring all personnel aboard a facility are complying with the policies and procedures identified in your SEMS. • Therefore your SEMS program becomes a manual of Policies and Procedures for the “Elements” of Safety & Environmental Management (next slide).
ELEMENTS OF SEMS • General • Safety & Environmental Information • Hazards Analysis • Management of Change • Operating Procedures • Safe Work Practices • Training • Assurance of Quality & Mechanical Integrity of Critical Equipment • Pre-Startup Review • Emergency Response & Control • Investigation of Incidents • Audit of SEMS Elements • Records & Documentation
SEMS II • Modifications to the original regulations published June 2013 • Came into force June 2014. • SEMS II includes the following revisions and additions: • JSAs • Stop Work Authority (SWA) • Ultimate Work Authority (UWA) • Audit requirements, including accredited Audit Service Providers • Employee Participation Program (EPP) • Reporting unsafe working conditions
NEW PLAYERS • Center for Offshore Safety (COS) – 14 Operators • SEMS input to BSEE • Accrediting Body (AB) for Audit Service Providers (ASPs) • Ocean Energy Safety Institute (OESI) • $5M Grant from BSEE • Best Available & Safest Technology (BAST) input to BSEE • Offshore Operators Committee (OOC) – 59 Operators • SEMS Sub-committee • Brand new…at the request of the BSEE Director
HOW’S SEMS GOING? • First Round of Audits completed in November 2013 • 84 Operators audited • BSEE: “Undesirable variation in quality of audit reports” • Most audits were non-compliance checks…not management assessments • Improvements needed for Second Round • Qualitative Assessments • Assess Effectiveness; highlight Best Practices • Need performance measures; leading & lagging indicators • Increase dialogue between Audit report and CAP approval
SEMS III? • Contractor Management (Contactor SEMS?) • BSEE Director sees disconnect between Operator and Contractors • Room for standardization of what Contractors provide Operators • USCG SEMS for vessels on OCS • Measuring SEMS Effectiveness • Performance indicators • Leading, Lagging Indicators • Comparative data • Trained, Calibrated Auditors