Representatives from the US Bureau of Safety and Environmental Enforcement (BSEE) assessed the progress of the agency’s Safety and Environmental Management System (SEMS) initiative at an Offshore Technology Conference breakfast in Houston on May 7.
After the program’s first cycle requiring SEMS implementation and a subsequent audit, 96% of operators were in compliance. Three of the 86 participating operators failed to meet the first-cycle requirements and were assessed a civil penalty. Those three are now in compliance, according to Susan Dwarnick, head of BSEE’s Offshore Safety Improvement branch.
Dwarnick said there was significant variability in the understanding of management systems, system maturity, and audit formats. The depth of information in audit reports were submitted in a wide variety: everything from a blank spreadsheet to a very comprehensive narrative similar to a financial audit.
Compliance variations
The first cycle was characterized by two camps of operators. “Those with existing SEMS programs mapped them to the new requirements, essentially validating what they already have in place,” said Dwarnick. “And operators without an existing SEMS program that had to develop and implement a program to formalize the practices they were already engaging in.”
This bifurcation revealed gaps in SEMS development and implementation. In many cases, said Dwarnick, hazard analysis and management-of-change are implemented as stand-alone programs rather than integrated as part of a SEMS program.
“Pre-start up review observations showed a lack of implementation of procedures and the relationship between SEMS elements did not always seem to be understood,” she said. “These are interrelated systems that are being managed as independent entities and operators are not getting the business value of SEMS by separating these elements.”
Strengthening SEMS
As the second cycle of SEMS continues with audits due in June, BSEE is looking to improve the program. “We need to emphasize that compliance requires operators to demonstrate that they are implementing SEMS as a performance-based standard and not just checking off items on a list,” said Stan Kaczmarek, BSEE SEMS section engineer.
One of the most important considerations for Kaczmerek is how to measure performance. He believes the agency must define success and give better guidance and support in the auditing process in order to get better reporting on the back end.
“We need to measure management-system maturity and modify our audit approach based on it,” he said. “We need to refocus the second cycle of SEMS audits as a test of the effectiveness and integration of each of the program’s elements.”
Kaczmerek believes that effectiveness will be increased by looking at the interfaces between operators and contractors, improving the exchange of data, and investigating the success and challenges for various risk-control methodologies, especially those that examine critical human factors.
Contact Michael T. Slocum at [email protected].