Managing SEMS Audits: Past, Present, and Future

Abstract

Management Safety and environmental stewardship have always been important priorities for the offshore oil and gas industry. In recent years, serious offshore incidents forced the industry to take a hard look at its processes and procedures for ensuring that every operation is conducted with the highest regard for human safety and protection of the sea, land, air, and animal life. While the majority of offshore operators and service companies implemented plans to continuously improve their corporate safety and environmental standards, offshore operators are now legally obligated to adhere to new regulations. In the US Gulf of Mexico (GOM), the US Bureau of Safety and Environmental Enforcement (BSEE) established Safety and Environmental Management Systems (SEMS) regulations, which companies operating oil and gas and sulfur leases in the Outer Continental Shelf (OCS) must meet with regularly audited safety and environmental programs. From Recommendation to Requirement The concept of SEMS was developed in response to the 1990 finding of the National Research Council’s Marine Board that the Bureau’s prescriptive approach to regulating offshore operations had forced the industry into a compliance mentality. Further, the Marine Board found that this compliance mentality was not conducive to effectively identifying all the potential operational risks or developing comprehensive accident mitigation. As a result, the Marine Board recommended, and the Bureau concurred, that a more systematic approach to managing offshore operations was needed. In response to the Marine Board findings, the American Petroleum Institute (API), in cooperation with the bureau, developed Recommended Practice (RP) 75-Development of a Safety and Environmental Management Program for Outer Continental Shelf Operations and Facilities. The API also produced a companion document, RP-14J, for identifying safety hazards on offshore production facilities. API RP-75 was published in May 1993 and, in 1994, the bureau published a notice in the Federal Register that recognized implementation of RP-75 as meeting the spirit and intent of SEMS. RP-75 was updated in 1998 to focus more on contract operations, including operations on mobile offshore drilling units. This recommended practice was updated several times in the following decade; a third edition was published in May 2004, which was reaffirmed in May 2008. The Deepwater Horizon accident in April 2010 dramatically changed the regulatory landscape, leading to BSEE’s implementation of the first mandatory SEMS rule for oil and gas operators in the OCS. Also known as the Workplace Safety Rule, it required all OCS lessees to have a well-documented SEMS program in place by 15 November, 2011. On 15 November, 2013 all operators with facilities in OCS waters of the GOM were required to have a SEMS audit. According to BSEE, 84 operators were subject to the November audit deadline, and 72 ended up completing the initial audit. The 12 operators that did not complete the audit were cited by BSEE for failure to demonstrate compliance with the SEMS requirements of the Workplace Safety Rule, 30 CFR Subpart S.