Proceedings magazine is a communication tool for the Coast Guard's Marine Safety & Security Council. Each quarterly magazine focuses on a specific theme of interest to the marine industry.
Issue link: http://uscgproceedings.epubxp.com/i/665311
21 Spring 2016 Proceedings www.uscg.mil/proceedings and adopts these or similar performance indicators, they will provide an indication not only as to whether safety and environmental management systems infuence OCS behaviors, but also if change in those behaviors is making a measurable difference. Finally, BSEE will assess if SEMS effectively guides better safety and environmental performance throughout the oil and gas OCS industry by monitoring and promoting the sharing of information on risk areas and best practices with the rest of industry. To assist industry in this regard, the bureau has partnered with the Bureau of Transportation Statistics (BTS) to set up a near-miss reporting system. BTS is one of the 13 principal statistical agencies Congress authorized under the Conf- dential Information Protection and Statistical Effciency Act to collect and handle information in ways that protect the confdential and proprietary nature of such information and their sources while still using it to provide actionable intel- ligence for others in the industry. Reports can be made in confdence at www.SafeOCS.gov or by calling 1-844-OCS- FRST (1-844-627-3778). Auditing The audit report is the main source of detailed information BSEE receives on what's working in the safety and environ- mental management system and what is not. The bureau's SEMS regulations require that lessees and operators receive a third-party-led audit of their management system every three years, and that this triennial audit sample the effec- tiveness of the management system in controlling safety and environmental risks on 15 percent of each operator's OCS facilities. When SEMS was frst put into effect, the audit reports BSEE received focused more on statements of compliance rather than on evidence of effectiveness. While it's easy to have a documented management system that contains verbiage referenced in a regulation, it is much more diffcult to defne and test a system that management willingly supports, pro- motes, and actually empowers all workers to think and participate in safety and environmental protection, and is subsequently used in disciplined ways every day. One way to ensure the audit reports provide better value to the operator and to BSEE is to create and enforce stan- dards on how an audit should be conducted and reported. To support this, the Bureau of Safety and Environmental Enforcement requires that accredited auditors lead each SEMS audit, working with the Center for Offshore Safety, 2 to change the way lessees and operators approach these third-party-led audits. Just as an effective safety and environmental management system must be based on knowledge of the hazards that need to be managed, BSEE is working with the Center for Offshore Safety to adopt a systematic approach to auditing in which specifc, observed hazards in a facility or in an operation become the starting point for exploring how (or if) the management system has recognized the hazards, miti- gated the risks, and improved the risk controls over time. This approach will give the audit team an opportunity to evaluate whether the elements of the management system are integrated into the full operating process. Furthermore, audit service providers are being asked to try to begin the assessment of possible root causes for any fnd- ings to determine if an observation refects a random occur- rence or a more systemic issue. Both scenarios pose different risks to the safety of operations, and such an assessment can guide the operator to adopt the appropriate mitigation steps to prevent a recurrence. The bureau's current regulations require that reports sum- marizing the SEMS audit be submitted to BSEE and that they highlight the audit team's fndings, observations, and conclusions, identifying defciencies. This then enables BSEE to fulfll its regulatory obligation to determine if the associ- ated corrective action plan proposed by the lessee or opera- tor will be effective in closing the gaps and improving the ability of the management system to control risks. To help in this regard, the bureau is also working with the Center for Offshore Safety to create a more detailed defni- tion of the evidence that should be provided in an audit report. By providing guidance on what should be included in a safety and environmental management system audit report, BSEE anticipates receiving a more representative assessment of OCS operator safety performance than has been provided in the past. Continual Improvement A recurring theme in all management systems, and in BSEE's approach to SEMS, is the belief that an effective management system must be continually tested and quickly improved every time it is found to be weak in 1) recogniz- ing hazards that exist, or 2) in empowering every person who faces those hazards with the knowledge, protocols, equipment, and support they need to control them. As we learn more, we will consider modifying our approaches or employing more of the tools at our disposal. The bureau's approach to SEMS promotion can be summa- rized as follows: • Learn from operators who have a robust safety and envi- ronmental management system by focusing on what is