Book: Offshore Safety Management
Chapter 4 - Safety and Environmental Management Systems (SEMS)

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Overview

This chapter describes the Safety and Environmental Management Systems (SEMS) rule that applies to the Outer Continental Shelf of the United States. (The manner in which regulations are created and enforced for the United States offshore oil and gas industries is described in Chapter 1.) The practical implementation of a SEMS program - including timing, cost and schedule development - is discussed in Chapter 5.

In the years prior to the Deepwater Horizon catastrophe, the Minerals Management Service (MMS) - which is now BOEMRE - had been in the process of developing a new rule whose full title was Oil and Gas and Sulphur Operations in the Outer Continental Shelf - Safety and Environmental Management Systems (SEMS). It is Subpart S of 30 CFR Part 250. One of the consequences of that accident was that the agency radically increased the scope and speed of implementation of the rule.

The updated rule was published by the BOEMRE in October 15^th 2010 with an effective date of November 15^th 2010. Covered facilities were given one year in which to comply, i.e., their programs should be finalized by November 15^th 2011. It should be noted that nothing actually happens on that date - it is not like a tax document that must be mailed in on or before the deadline. However, once November 15^th 2011 has passed, owner/operators are subject to full SEMS audits and incident investigations.

The rule covers all oil and gas facilities on the Outer Continental Shelf (OCS) in United States waters, and is based on the SEMP standard that was discussed in the previous chapter. (The single letter change - from SEM'P' to SEM'S' - is significant. SEMS is a system in which the parts link to one another.

Contents

Chapter 4 - Safety and Environmental Management System (SEMS)
Introduction
First Version of SEMS
Final Rule
Organization of the Rule
Scope
From SEMP to SEMS
Compliance
Contractors
   Types of Contractor
      Contract Companies
      Contract Workers
   Design Companies
   SEMS Requirements
   Bridging Documents
Elements of SEMS  
   The SEMS Standard
   Additional BOEMRE Requirements
   Special Offshore Issues
1. Safety and Environmental Information
   The SEMS Standard
   BOEMRE Requirements
2. Hazards Analysis
   The SEMS Standard
   BOEMRE Requirements
   Hazards Analysis Offshore
   Hazards Analysis Techniques
      Major Hazards Analysis
      Hazard Identification (HAZID)
      The Hazard and Operability Method (HAZOP)
      Bow-Tie Analysis
      Failure Modes and Effects Analysis (FMEA)
   Job Safety Analysis (JSA)
   Hazard Register
4. Management of Change
   The SEMS Standard
   BOEMRE Requirements
5. Operating Procedures
   SEMS Requirements
   BOEMRE Requirements
6. Safe Work Practices
   SEMS Requirements
   BOEMRE Requirements
7. Training
   SEMS Requirements
   BOEMRE Requirements
   Subpart 'O'
   SafeGulf
8. Mechanical Integrity
   SEMS Requirements
   BOEMRE Requirements
   Mechanical Integrity Offshore
9. Pre-Startup Review
   The SEMS Standard
   BOEMRE Requirements
   Prestartup Reviews Offshore
10. Emergency Response and Control
   SEMS Requirements
   BOEMRE Requirements
   Lack of Space
   Off-Duty Personnel
11. Investigation of Incidents
   The SEMS Standard
   BOEMRE Requirements
   Incident Investigation Offshore
12. Audits
   The SEMS Standard
   BOEMRE Requirements
   Audit Protocol
      Single Question
      Answers
   Frequency of Audits
   Audit Team
13. Records and Documentation
   SEMS Requirements
   BOEMRE Requirements
   Interaction between the Elements
   Form MMS-131
SEMS II