History of SEMS Outcomes, Challenges, and the Path Forward

Transcription

1 History of SEMS Outcomes, Challenges, and the Path Forward Sue Dwarnick 17 October 2016 To promote safety, protect the environment and conserve resources offshore through vigorous regulatory oversight and enforcement.

2 Presentation Overview Safety and Environmental Management Systems What is it? The Evolution of BSEE SEMS Ongoing Lessons Learned Changing a Culture The Path Forward Building on a Solid Foundation Risk-Based Inspection-a Hybrid Approach Wind Energy starting with a blank canvas Questions and Discussion

3 SEMS---What is it? Management System: Framework of processes and procedures used to ensure that an organization can fulfill all tasks required to achieve its objectives. Safely Environmentally Responsibly Consistently Sustainably

4 BSEE SEMS REGULATION Company XYZ SEMS Road Map BEHAVIORS CORPORATE Company XYZ SEMS Standards Guidance docs Goals/Targets LEADS Safe Behaviors DEPARTMENT Alignment Doc IMPLEMENTATION PLANS Supplemental Procedures - Audit plans/action plans - Training plans - Bridging Doc DEFINES Safe Behaviors FACILITY STANDARD OPERATING PROCEDURES RECORDS JSA Permits Training Records Stop Work Program MANAGES Safe Behaviors INDIVIDUAL COMPETENCY Know Safe Behavior Follows procedures Can and will stop work PERFORMS Safe Behaviors consistently

5 The Evolution of the BSEE SEMS Program --Objectives Cornerstone of BSEE s move toward a hybrid regulatory approach Performance based requirements to expand beyond a strict focus on compliance Incorporation of risk-based management strategies Evolving enforcement approaches Goal to drive improvements in Safety Culture within all stakeholders of O&G OCS

6 The Evolution of the BSEE SEMS Program --Timeline May 1991 API RP 75 Published; promoted by MMS May 2006 SEMS Notice for Proposed Rule Making (NPRM) Jul SEMS Proposed Rule Published for Public Comment; portions of RP 75 required Apr 2010 Macondo/Deepwater Horizon Oct SEMS I Final Rule Published/Effective Nov 2011 Sep 2011 SEMS II NPRM; JSA, SWA, UWA Apr 2013 SEMS II Final Rule Published Nov Deadline for First Operator SEMS Audit Jun 2014 SEMS II Effective Jun 2015 COS named by BSEE as an Accreditation Body

7 The Evolution of the BSEE SEMS Program --Lessons Learned SEMS awareness and understanding among OCS operators varies significantly Full range of program maturity observed Industry majors and others well along the path to full implementation Others just beginning to formalize the management system around their operations

8 The Evolution of the BSEE SEMS Program --Lessons Learned Historical focus on strict compliance is difficult to change Frequent requests for further program definition and BSEE approvals Tendency to hire a third party to write a SEMS Plan rather than to develop a SEMS Plan Focus has been on the documenting processes not our processes Managing performance to goals vs. standards

9 The Evolution of the BSEE SEMS Program -Lessons Learned Underlying Safety Culture supporting and driving SEMS is evolving within both Industry and BSEE Focus has been on: The process not the results Program development not implementation Standardization over fit for purpose Compliance to regulations and procedures Growing % of resources and attention on managing occupational safety Leadership support within Industry is critical

10 The Evolution of the BSEE SEMS Program -Lessons Learned Assessing status of SEMS implementation is more challenging than assessing Compliance to Regulations Incidents of Non-Compliance vs. failure to fully implement Assessing performance based expectations the operator must develop criteria and assess needs. the operator must determine what constitutes a significant safety hazard.

11 The Evolution of the BSEE SEMS Program -Lessons Learned Assessing status of SEMS implementation is more challenging than assessing Compliance to Regulations cont. Skill sets of BSEE inspectors and third party auditors---knowing the regulations. vs. understanding the operations and risks 3-Way Evaluation: People/Technology/Systems Time requirements to fully assess a SEMS performance

12 The Evolution of the BSEE SEMS Program -Lessons Learned Assessing status of SEMS implementation is more challenging than assessing Compliance to Regulations cont. What to report back to the regulatory authority Operator vs. Contractor roles under SEMS Shift in role: Enforcement vs. Collaboration Near-miss reporting Sharing of lessons learned and best practices Tolerance for diversity Focus on action plans and audit follow-up

13 Are we In Compliance? Can we Sustain Compliance? Possible Hints: A management system that is too cumbersome and complicated to effectively manage the organization Common themes found after incident investigations or audits Failure to follow procedures Failure to recognize risk Growing shift of resources and attention to managing occupational safety vs. process safety

14 SEMS Impacts the way we review for Compliance! and Performance!! Verify Validate Is the process in place Process Driven- current state or conditions Q&A Discussions Focus on multiple subject/operating areas Skills-management system/process oriented Output- observations /recommendations Trust but Verify Is the process working Task Driven-actions or behaviors Listening Sessions Focus on the critical few areas in depth Skills-operating systems/practical exp. Output-implementation assistance

15 SEMS Going Forward Areas of Emphasis Increased oversight and partnership with COS Accreditation Body for Audit Services Providers Publication of a SEMS Effectiveness Tool BSEE Guidance on Audit Planning Triggers for a Directed Audit National (BSEE-wide) approach to SEMS Enforcement Support of API RP 75 update BSEE audits of SEMS Corrective Action Plans Staff training

16 The Path Forward-Building on a Solid Foundation BSEE currently has: A well established Inspection and Enforcement Program supported by a strong team of experienced Inspectors Five+ years of experience gathering information from the BSEE SEMS audit program Extensive experience conducting and analyzing incident investigations

17 National Inspection Program Annual Inspections Safety Performance SEMS Audits RBI (focused inspections)

18 Risk Based Inspection Program Annual inspections of offshore production facilities required. Industry/BSEE data supports the observation that 80% of reportable incidents (on OCS platforms) occur at ~20% of the facilities. By focusing on higher-risk facilities and operations, BSEE will: Focus limited inspection resources on higher risk activities Systematically monitor and manage facility and operational risk profiles.

19 Offshore (OCS) Wind Energy Creating a new BSEE Program Regulatory Guidance is currently in a state of flux BOEM to BSEE transition Current regulations set performance expectations US offshore wind energy program is still in its infancy International experience is available BSEE definition of good design and inspection Hybrid regulatory model likely to be proposed Industry standards and regulatory requirements Safety and Environmental Management System a must! Inspections: third party, accreditation body, BSEE validations.

20 BSEE Website: BSEEgov Bureau of Safety and Environmental Enforcement 20 To promote safety, protect the environment and conserve resources offshore through vigorous regulatory oversight and enforcement.

21 21 Applicable Elements (1) General (see ) (2) Safety and Environmental Information (see ) (3) Hazards Analysis (see ) including Job Safety Analyses (4) Management of Change (see ) (5) Operating Procedures (see ) (6) Safe Work Practices (see ) (7) Training (see ) (8) Assurance of Quality and Mechanical Integrity of Critical Equipment (see ) (9) Pre-startup Review (see ) (10) Emergency Response and Control (see ) (11) Investigation of Incidents (see ) (12) Auditing (see ) (13) Recordkeeping (see ) (14) Stop Work Authority (SWA) (see ) (15) Ultimate Work Authority (UWA) (see ) (16) Employee Participation Plan (EPP) (see ) (17) Reporting Unsafe Working Conditions (see ).