The US Bureau of Safety and Environmental Enforcement should modify some existing practices in evaluating offshore safety and environmental systems (SEMS) programs' effectiveness, a National Research Council committee report recommended.
The report from the National Academies of Science emphasized using cooperation and consultation to promote safety, suggesting this approach include inspections, operator audits, bureau audits, key performance indicators, and a whistleblower program.
The US Department of the Interior implemented offshore oil and gas SEMS requirements last year following the April 2010 Macondo deepwater well blowout and crude oil spill in the Gulf of Mexico.
The report said employees throughout a corporation must accept a SEMS program if the program is to succeed.
"Only then can an effective culture of safety be established and grow," the committee said.
For the most part, the committee's recommendations were consistent with the BSSE's proposed changes to SEMS.
More than checklists
An effective offshore SEMS program requires more than simply providing checklists, the report emphasized.
The committee consulted with the US Department of Labor's Occupational Safety and Health Administration and Mine Safety and Health Administration, the US Coast Guard, and the California State Lands Commission domestically; UK's Health and Safety Executive and Norway's Petroleum Safety Authority.
These government agencies have found engagement with the industry more productive than punishment, the committee said, noting that the agencies "maintain the threat of punishment if needed."
BSEE should consider allowing inspectors to spend more time offshore interacting with operating staff and observing daily operations, the report said.
To help enable this, the report suggested operators might provide transportation and accommodations for inspectors.
Audits by both BSEE and operators are critical, the report asserted. Risk-based audits by the operator's own qualified independent team or by a third party with at least one operator employee who is not directly involved will help encourage an appropriate safety culture, the report said.
"BSEE, in consultation with the industry and, potentially, the Center for Offshore Safety (COS), should develop an approach to certify auditors, develop audit standards, and establish the process by which audits themselves are conducted," the report said.
BSEE audits
BSEE should perform complete or partial offshore SEMS program audits when justified by reports from inspectors, reviews of operators' audit reports, incidents, or events, according to the report. "Because of the comprehensive nature of the SEMS requirements, BSEE's oversight of internal and third-party audits needs to include a range of techniques, each of which focuses on a different aspect of an operation's safety system," it said.
The committee suggested BSEE develop key performance or other indicators that would be effective in evaluating an offshore operator's or installation's SEMS program and safety culture.
A whistleblower program also enables employees to anonymously report dangers not obvious to BSEE inspectors, the report said.
"Care should be taken in devising this program to make sure that it does not become a tool for disgruntled employees seeking to punish perceived wrongs," the committee said.
The committee noted that as it wrote its report in early September 2011, BSEE published a list of proposed changes in its offshore oil and gas SEMS requirements.
The committee said all but one of the proposed changes—a requirement that SEMS audits be performed by independent third parties—is consistent with the report's findings. Complete or even heavy reliance on outside auditors potentially could contribute to a compliance mentality and undermine establishment of an effective offshore safety culture, it warned.
A BSEE spokesperson said that the agency appreciated the committee's work on the study, which was produced at BSEE's request, and would closely review the report's findings and recommendations.
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