Proceedings Of The Marine

SPR 2016

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.

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19 Spring 2016 Proceedings of prescriptive and performance-based requirements that address specifc equipment or operations, includ- ing specifc requirements for drilling (Subpart D of BSEE regulations — 30 CFR 250), well completion (Subpart E), well workover (Subpart F), well control (Subpart O), and decommissioning (Subpart Q). Addi- tional requirements address production safety (Sub- part H), the safe design and operation of platforms and structures (Subpart I), and pipelines (Subpart J). The SEMS regulations (Subpart S) build on these requirements by specifying that companies must man- age the human interfaces and interactions required to operate on the outer continental shelf and to handle the complexity of information fow in oil and gas work to ensure safe operations. A fundamental principle of SEMS is that operators assess and evaluate all hazards associated with their operations, then work to eliminate or mitigate the unacceptable risks associated with those hazards. Detailed regulations focusing on specifc pieces of equip- ment or specifc tasks are often not broad enough to ensure safe operations in every possible scenario. Safety and envi- ronmental management systems, on the other hand, guide operators to look at the big picture, taking into account how activities or changes in one area may impact safety and environmental aspects of operations in another. Detailed equipment-related regulations addressing specifc issues may take years to develop and promulgate. A perfor- mance-based regulation such as SEMS allows the regulator to focus on broader safety objectives and the mitigation of risks. This gives industry the fexibility and responsibility to determine the best way to achieve such objectives without waiting for new regulatory requirements. Adding SEMS requirements into the BSEE program is a clear indication that the bureau is moving toward adopting more performance-based requirements into its existing hybrid regulatory regime. Challenges in Adopting Performance-Based Regulations The industry view toward adding a performance-based requirement (i.e. SEMS) to the OCS regulatory program was mixed. Early on, some of the regulated community approached the SEMS requirements as a mandate to write a series of procedures as outlined in the regulations, and then show them to the regulator whenever asked. Auditors were also hesitant to share their observations, whether they were areas of excellence or weakness in the management system approaches. The emphasis appeared to be on documenting compliance instead of assessing performance. From BSEE's perspective, we needed to establish alternate approaches to enforcement, looking at the overall commit- ment and application of a management system approach rather than looking at each activity within the management system as a compliance vs. nonconformance opportunity. Thus, the Bureau of Safety and Environmental Enforcement made the decision not to issue incidents of noncompliance for defciencies identifed through a safety and environmen- tal management systems audit unless the overall conclusion was that the management system did not really exist. To further demonstrate our commitment to viewing safety and environmental management systems differently than the way we enforce our other regulatory requirements, the bureau lists a limited number of items by which SEMS com- pliance can currently be assessed (see table above). By focusing solely on compliance during a safety and environmental management system audit rather than assessing system effectiveness, the auditee creates a barrier to achieving the full potential of SEMS. An excessive focus on compliance with specifc requirements can also create a false sense of safety within the workforce, as individuals may assume that everyone is following the same procedures and standards, and that they are all effective. The Bureau of Safety and Environmental Enforcement, building on its enforcement foundation, also needed to view safety and environmental management systems differently, shifting from inspecting for compliance to inspecting for safety. For the most part, BSEE compliance expectations for SEMS largely deal with creating, rolling out, and main- taining a SEMS program. If there is evidence of a demon- strated, ongoing commitment to fnd and fx weaknesses in the management system, then the bureau will support those commitments. SEMS Compliance Requirements 1. A safety and environmental management system (SEMS) has been defned. 2. It addresses all provisions of 30 CFR 250, Subpart S. 3. There is evidence of ongoing attempts to implement it in the feld. 4. An independent and accredited third party audits it at least once every three years. 5. The associated SEMS audit plans, SEMS audit reports, and corrective action plans are submitted to BSEE within the timeframes listed in Subpart S.

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