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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20 Proceedings Spring 2016 Companies can demonstrate a commitment to use safety and environmental management systems to drive safe behaviors and continual improvement in safety and envi- ronmental performance by providing evidence regarding which aspects of the management system are working and which are not, and then demonstrating that steps to close those gaps have been identifed and are being implemented. The Bureau of Safety and Environmental Enforcement also sponsors research to defne quantifable, SEMS-appropriate key performance indicators for individual operators, which it will share with industry. Eventually, if industry accepts How BSEE Assesses SEMS Success Further, the Bureau of Safety and Environmental Enforce- ment works with stakeholders to determine and document what effectiveness and performance in the safety and envi- ronmental management system elements look like, and how they can be measured. For example, the bureau uses infor- mation from several sources to assess whether individual operators use safety and environmental management sys- tems effectively, including feedback from BSEE's inspectors, incident investigations, audit plans, audit reports, and cor- rective action plans that regulations require be submitted to BSEE. Safety and Environmental Management System Regulations SEMS regulations required that operators and lessees design and implement an outer continental shelf management system by November 2011. The components of that manage- ment system were based in large part on an American Petro- leum Institute Recommended Practice for a Safety and Environmental Management Program (API RP 75) last updated in 2004. Both the Bureau of Safety and Environmental Enforcement regulation and API RP 75 defned those management system components as: • management responsibilities and practices, • safety and environmental information, • hazard assessment, • change management, • operating procedures, • safe work practices, • training, • quality assurance and mechanical integrity, • pre-startup review, • emergency response, • incident investigation, • auditing, and • records management. Then, in 2013, the Bureau of Safety and Environmental Enforcement proposed additional requirements beyond those contained in API RP 75 for each operator's or lessee's safety and environmental management system. These proposals became requirements in 2014 and 2015 and included: • establishing stop work authority, • naming an ultimate work authority, • formalizing an employee participation program, • reporting unsafe working conditions, • enhancing job safety analyses through review and signa- ture by all workers and management involved in a job task, and • accreditation for lead auditors performing the SEMS audits called for in the regulation. Through conversations with ofshore industry representatives and other stakeholders, BSEE is currently exploring whether additional or alternate approaches are needed to enforce the SEMS regulations or if revisions to API RP 75 are desired so that the performance-based aspects of the regulation can be further strengthened. The focus of these inquiries surrounds the best ways to close perceived gaps in the following areas: • contractor SEMS (BSEE is currently requiring only oper- ators and/or lessees to implement 30 CFR Part 250, Subpart S); • risk assessment methodologies (the current regulations do not specify how the hazard assessment is to be used to mitigate risks); • human factors (the current regulations do not specify what types of human factor considerations are essential to growing a safety culture); • performance indicators (though SEMS is a performance- based regulation, there is little attention as to how to measure performance); and • SEMS auditing requirements (the content of audit reports needs to be improved to ensure that the efectiveness of the programs and audits can be measured). BSEE is working with the API committee that is responsible for RP 75 as well as the Ofshore Energy Safety Institute to iden- tify and frame any opportunity for making SEMS both a more efective regulation and a widely adopted standard practice.

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