- November has come and gone – What did we learn? What should we do now?

1. - November has come and gone – What did we learn? What should we do now?

2. Challenges in 2011 Question of the year: What does MMS/BOEMRE/BSEE want?

3. Challenges in 2011 Physical compliance and management system compliance are different

4. Challenges in 2011 Developing documentation that reflected SEMS compliance Implementation was done irrespective of the ability to absorb change Organizations did not take the opportunity to increase their risk control Perception that SEMS is a “nightmare” was strengthened Several organizations attempted changes that were not commensurate with their risk profiles

5. Challenges in 2011 The major challenges from an element perspective were: Hazard Analysis Written Operating Procedure Elements that are not fully linked are: Safety and Environmental Information Mechanical Integrity

6. Challenges in 2011 Hazard Analysis 250.1911 What criteria for hazards analyses must my SEMS program meet? Hazards analysis requirements for simple and nearly identical facilities, such as well jackets and single well caissons, may be fulfilled by performing a single hazards analysis which you can apply to all such facilities

7. Challenges in 2011 Written Operating Procedures 250.1913 What criteria for operating procedures must my SEMS program meet? You must develop and implement written operating procedures that provide instructions for conducting safe and environmentally sound activities involved in each operation addressed in your SEMS program.

8. Challenges in 2011 Safety and Environmental Information 250.1910 What safety and environmental information is required?   Information that provides the basis for implementing all SEMS program elements, including the requirements of hazard analysis

9. Challenges in 2011 Mechanical Integrity 250.1916 What criteria for mechanical integrity must my SEMS program meet? Inspections and tests can be performed more frequently if determined to be necessary by prior operating experience.

10. Challenges going forward Stages of organizational development: Individualized Departmentalized Formalized Focused Learning

11. Challenges going forward Rules for success: Celebrate early successes Identify early adopters Control what is critical Measure, compare, optimize Institutionalize

12. Celebrate early successes Define what success is: It is no use saying “we are doing our best” You have got to succeed in doing what is necessary – Winston Churchill Acceptance in the field Suitability for use Impact “at the valve”

13. Early adopters Early adopters: Try to use the system as intended Provide constructive criticism Convince others

14. Control what is critical Define what is critical: Use hazard analysis to align SEMS Four questions of risk management Precision risk management

15. Measure, compare, optimize Continuous improvement: Prescription without diagnosis is malpractice, be it in medicine or management – Karl Albrecht Measure what you are trying to control not what you are trying to achieve Communicate Safer, better, faster Use technology

16. Institutionalize When SEMS is seamlessly integrated into production, it is REALLY part of my organization

17. Be persistent but flexible