Safety is a necessary practice for all operations, and new regulations for oversight seem to be missing some key components.The US Bureau of Safety and Environmental Enforcement (BSEE) released its Safety and Environmental Management Systems (SEMS) II rule in April and the topic remained on the minds of delegates on the final day of the Offshore Technology Conference (OTC).
The SEMS II rule aims to provide greater employee participation, allowing those in the field to identify hazards and stop work if it is unsafe. The rule also sets oversight guidelines, requiring audits to be conducted by accredited third-parties.
The morning session on SEMS II regulations drew panelists from Lloyd’s Register, Acu Tech Consulting Group, PEC, and DNV to discuss how operators as well as their contractors could better implement the new safety requirements.
The biggest problem with SEMS II, as presenter Michael Hazzan, of Acu Tech Consulting Group, noted is the lack of outside auditors approved by BSEE, which are required to examine an operator’s safety program. “There are no accredited bodies,” Hazzan says. “The Center for Offshore Safety is the likely and preferred candidates, but today they are not one.” (At press time, the Center for Offshore Safety selected Bureau Veritas as its official SEMS audit service provider.)
With the lack of approved auditors, comes another problem: when should these audits occur? SEMS I required companies to get their systems in place by last year and submit results by November, and then repeat every three years. SEMS II dictates that third-party audits should be conducted prior to June 2015.
BSEE Director James Watson, who attended the panel, says that companies do not need to wait three years between the second round of audits. The first round of audits are due at the two-year point, and urged companies not to wait until the end of the cycle to conduct the audits as BSEE has final approval and can require additional follow-ups.
While there are kinks that need to be worked out with regards to the rules, Hazzan praised management systems as a necessity for institutionalizing practices.
“Having the policy is not the hard part; implementing is hard,” he says. “Audits are mandatory and there’s a chance that you may find something – and that’s why people don’t like them, but it’s an opportunity to find out what is working.”
Extending SEMS to contractors
Pisces Carmichael of Lloyd’s Register says SEMS should apply to contractors. She says that BSEE’s district reports from the end of 2012 showed 29 accidents were related to human error, of these 54% were with named contractors. Another statistic, this time of medevac rescues in the Gulf of Mexico, showed that of the rescues made, 64% were of service company employees compared to 32% of oil and gas company workers.
Carmichael stressed that contractors need to have an effective HSE process and need to show consistent performance and not just safe work practice (SWP) agreements.
When asked if SEMS II applies to EPC contractors, Carmichael says she believes it does. Director Watson left it more open-ended, saying that BSEE is not yet writing SEMS for contractors; however, SEMS applies to all operations, cradle to grave.
Ken Wells of PEC pointed out that BSEE estimates 90% of those who work offshore work for contractors. There is a definite problem with getting a contractor’s safety guidelines to mesh with an operator’s own program. Most subcontractors have no legal relationship with the majors and hence do not want to make legal declarations about their safety culture, Wells says.
Carmichael says human error is about a company’s safety culture. Wells pointed to the conflicting mind set of “operator dictates, contractor follows, and workers do it” and SEMS II regulations that say workers should stop if they feel a job is unsafe. He says that the best way to target zero accidents is by engaging staff.
Robin Pitblado, of DNV, says a company’s top management needs to employ a “management loop idea” called PDCA or plan-do-check-act.
“Safety management systems won’t work without leadership,” he says. OE