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From SEMP to SEMS to SEMS II


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SEMP to SEMS to SEMS II We have written an article entitled From SEMP to SEMS to SEMS II for publication in the journal Process Safety Progress. A draft of the article can be downloaded here.

Some of the background to the SEMS II section of the article is provided here.

SEMS II Philosophy

With regard to SEMS II the article suggests that BSEE has focused on "cultural" issues rather than formal risk assessment and quantification that is often associated with Safety Cases.

Of the six elements listed in SEMS II four of them (highlighted in yellow below) are to do with behavior, and probably stem from an analysis of some of the Command-and-Control difficulties that were such a feature of the Deepwater Horizon incident.
  • A Stop Work provision
  • Definition of authority
  • Employee participation
  • Reporting of unsafe conditions
  • The use of independent third party auditors
  • Additional requirements for Job Safety Analyses

It is interesting to note the elements of SEMS II that are not present. These include:

  • Quantification of Risk
  • Acceptable Risk (ALARP)
  • Safety Case
  • Formal Risk Assessment

Director Watson Comments

In the April 20th 2012 edition of the Houston Chronicle the Director of BSEE, Rear Admiral Watson, wrote an op-ed article entitled The lessons we learned for Deepwater disaster. Presumably his comments reflect the thinking of management at BSEE so it is interesting to note that he talked about "advances in three fundamental areas". They were:

  1. The final Drilling Safety Rule;
  2. A new generation of blowout preventers; and
  3. Complexity.

It is the third of these - "complexity" - that invites further analysis. Director Watson states:

   . . . I believe that offshore exploration and production operations – much like commercial aircraft – are now so complex that the traditional, “snap shot” examination of the adequacy of equipment or procedures cannot guard against equipment or human failure. In other words, we not only need to look at whether a complicated piece of equipment works today, but also whether it is being built and maintained to perform to its design over its entire lifecycle. It is similar to the expectation we have of airline engines, for example, for which manufacturers must prescribe when their products must serviced and at what point an aging engine poses too great a risk to fly.

In the comments at the top of this page it was argued that BSEE had chosen to pursue the topic of "culture" over formal risk assessment in its SEMS II document. The above statement would suggest that the agency is also looking at a new way of assessing offshore facilities: Life Cycle performance, with equipment vendors being more closely associated with overall safety than they may have been in the past.


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