22 January 2014 | Houston Gulf Coast Branch of IMarEST Centre for Offshore Safety (COS) Charlie Williams Executive Director williamsc@centerforoffshoresafety.org
http://www.bsee.gov/Regulations-and-Guidance/Safety-and-Environmental-Management-Systems---SEMS/Safety-and-Environmental-Management-Systems---SEMS.aspx 2
COS Membership Drilling Contractors Owners / Operators / Leaseholders Diamond Offshore Drilling • Ensco • Anadarko • Noble Corp • Apache • Pacific Drilling • BHP Billiton • Seadrill Americas • BP E&P • Transocean • Chevron USA • Service/Equipment Providers Cobalt • Baker Hughes • ConocoPhillips • Cameron International • Exxon Mobil • Halliburton • Hess • Oceaneering • Marathon OCS Group • • Schlumberger • Murphy E&P • Affiliates Shell International E&P • IADC • Statoil North America • NOIA • TOTAL E&P • PESA • 4
Safety & Environmental Management Systems What are the elements of SEMS in API RP-75 Leadership Mechanical Integrity Safety and Environmental Information Pre-Start-Up Review Hazard Analysis Emergency Response and Control Management of Change Incident Investigation Operating Procedures Audit Safe Work Practices Records and Documentation Training Charlie Williams, Executive Director info@centerforoffshoresafety.org www.centerforoffshoresafety.org
Safety and Environmental Management Systems (SEMS) Goal: Safe & Reliable Operations / Operational Integrity • SEMS is a key mechanism to reduce the likelihood of • major incidents 6
Core Functions • Find SEMS Gaps - Data Collection, Analysis & Reporting • Close Gaps with Good Practices • Effectiveness Assurance & Measurement – Auditing, Accreditation & Certification • Outreach & Communication IMPROVE & SUSTAIN INDUSTRY SKILLS & KNOWLEDGE 7
SEMS Toolkit and Accreditation/Certification SEMS Audit Protocol COS-1-01 (Revision 2 complete) • Compliance Readiness Worksheet COS-1-02 • Operator-Contractor Letter Templates COS-1-03 • Audit Guidance Document (Revisions starting) • COS-2-01 Qualification & Competence Requirements • Audit Leads & Auditors COS-2-02 Training Program Requirements Auditors • COS-2-03 Certification API RP 75 • COS-2-04 Accreditation Audit Service Providers • COS-2-05 Audit Report Form • 8
SEMS Audit Protocol Checklist 13 sections that corresponds with API RP 75 and 30 CFR 250 – Subpart S (SEMS) Audit Has a management representative been appointed Question that is responsible for establishing, implementing and maintaining the SEMS? § 250.1909(b) [Specifically you, through your management, must:] (b) Appoint management representatives who are responsible for establishing, implementing and maintaining an effective SEMS program. 5 RP 75 1- [This recommended practice is based on the following 1.2.2(c) principles:] c. Management appoints specific representatives who will be responsible for establishing, implementing and maintaining the safety and environmental management program. 9
SEMS II “…working with the COS workgroups on developing • indicators to gauge industry OCS performance other stakeholders. …” COS-2-01, Qualification & Competence Requirements for • Audit Teams & Auditors COS-2-03, Requirements for Third-party Auditing & • Certification COS-2-04, Requirements for Accreditation of Audit Service • Providers (ASPs) must be accredited by a BSEE-approved • accreditation body (AB) .. Like COS 10
COS SEMS Accreditation and Certification • Accreditation of Audit Service Providers – Four accredited by COS (ABS, BV, DNV, ERM); two additional by end of 1Q 2014 • Certification of COS Members – One certified by COS (Statoil); preparing to issue additional certificates to Members 11
Bow Tie Approach 12
Operator/Contractor Interfaces 13
Core Functions & Activities Effectiveness Assurance and Measurement • – SEMS Auditing, Accreditation and Certification Find Gaps - Data Collection, Analysis and Reporting • – Safety Performance Indicators – Improving Industry Learning Capability Close Gaps with Good Practices • – Leadership Site Engagement – Skills & Knowledge Management System Guideline – Ultimate & Stop Work Authority FAQ and Answers Outreach and Communication • – COS Annual Forum April 9 & 10 – COS Breakfast, Tech. Session & Lunch at OTC May 8 – External Stakeholder Group 14
Challenge Identified Under 30 CFR 250.194(b), the operator is required to document that each contractor working for you is knowledgeable and experienced in the work practices it will be performing. This documentation needs to be available to BSEE should we ask to see it during a BSEE-conducted evaluation of your SEMS program. BSEE has not specified a format for you to use in preparing this documentation. Acceptable verification procedures include but are not limited to the following or combination thereof: In 30 CFR 250.194(e), the operator is required to perform “ periodic evaluations” of the performance of contract employees to verify they are fulfilling their obligations. These periodic evaluations may included the verification techniques listed above in relation to complying with 30 CFR.250.1914(b), or they may include other operator-conducted verification techniques. These periodic evaluations need to be available to BSEE should we ask for them during a BSEE-conducted audit of your SMES program.
Elements of an effective Skills & Knowledge Management System (SKMS): 1. Commitment & Objectives 2. Overview & Scope 3. Accountability & Responsibility 4. Roles &/or Tasks 5. Assessment & Remediation 6. Auditing & Quality Assurance 7. Records & Documentation
COS Learning from Incidents Definition Voluntary collection of information about major safety • events, COS SPI 1 and 2 events, and near misses (“High Value Learning Events” or HVLE) Purpose Complement information from the COS Safety Performance • Indicators Program Improve understanding of circumstances that led to these • incidents and events, and of steps that were taken to reduce the likelihood of recurrence Sharing industry knowledge • 17
Stop Work Authority and Ultimate Work Authority Guidance • Developed guidance to industry on these closely related topics as a collective of trade associations (COS, API, OOC, IADC, OMSA, and IMCA) • Developed Frequently Asked Questions (FAQ) and Answers • Developed white paper that explains relationship between BSEE UWA and USCG PIC
The Future of COS - SEMS Work SEMS Effectiveness Measures, Tools, & Techniques – Continuous Improvement Expand Audit Protocol Guidance Respond to SEMS Regulatory Changes • Drilling focus • Projects & Construction • Contractors • Marine • Lead Auditor Training & Individual Certification Coast Guard Safety Culture 19
COS Annual Forum – April 9 & 10, 2014 COS Safety Management Systems Sessions at OTC – May 8, 2014 • Breakfast • Morning Technical Session • Luncheon 20
COS Upcoming Events • COS Annual Forum – April 9 & 10, 2014 • COS Safety Management Systems Sessions at OTC – May 8, 2014 • Breakfast • Morning Technical Session • Luncheon
THANK YOU Questions Charlie Williams Center for Offshore Safety Executive Director williamsc@centerforoffshoresafety.org
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