Background to SEMS
IntroductionJust as the Flixborough incident in England triggered the development of what is now known as Process Safety Management, so the Piper Alpha catastrophe created a demand for the management of safety offshore. The European offshore oil and gas industry elected to do this through the use of Safety Cases; in the United States the Minerals Management Service (MMS) elected to work with industry on the implementation of voluntary standards, particularly RP 75, RP 14C and RP 14J from the American Petroleum Institute (API). SEMP is based on API 75 Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities.
In the United States, which in practical terms means mostly the Gulf of Mexico (GoM), a different response to the Piper Alpha catastrophe was taken. There are roughly 3500 platforms in the GoM - most of them are small, are quite similar to one another and are located in shallow water. It is neither technically nor economically feasible to prepare a Safety Case for each platform. Instead, a set of generic standards were developed. Most of these standards came from the American Petroleum Institute (API). From the point of view of SEMS, the most significant was Recommended Practice (RP) 75 that called for companies to prepare a Safety and Environmental Management Program (SEMP).
The two approaches to the development of Safety Management Systems are are illustrated in Figure 1 below.
Figure 1 shows the two tracks, and also shows that serious accidents have taken place in both provenances in recent years: Deepwater Horizon in the Gulf of Mexico (2010), and the Montara blowout in Australian waters (2009).
From SEMP to SEMS
The SEMP standard was, as shown in Figure 1, introduced in 1994; it has been updated on a number of occasions since then, with the latest version being from the year 2004 (and validated in 2007). The Minerals Management Service (MMS) decided to use SEMP as the basis for the rule that they called Safety Environmental Management Systems (SEMS) - the full tile of which is "30 CFR Part 250 Subpart S, Oil and Gas and Sulphur Operations in the Outer Continental Shelf". The rule covers all oil and gas facilities on the Outer Continental Shelf (OCS) in United States waters.
The move from SEMP to SEMS came in three phases.
First Version of SEMS
A draft version of SEMS was introduced in 2006. In order to define its scope the Minerals Management Service (MMS) analyzed their own incident data, totaling 1,950 incidents, and determined that four of the twelve elements of SEMP contributed the most to incidents. The elements that they selected and the data that they used are shown in Table 1.
With the promulgation of the SEMS rule BOEMRE (now BSEE) has transformed a Recommended Practice (RP 75) into a legal requirement (the word “must” occurs approximately 293 times in the SEMS rule). However, BOEMRE went further - it has added many more requirements. In their words,
In addition, BOEMRE is highlighting certain requirements from API RP 75 and further describing those requirements in the regulatory text to clarify compliance requirements.
Use of the word “clarify” in this context is disingenuous. In fact, the agency has expanded the scope of SEMP considerably.
The MMS held a public hearing on the proposed rule in New Orleans in September 2009. At that hearing representatives from industry challenged the need for the new rule (Parker 2009). Their response focused on three areas: on-going favorable safety trends, contractor management and the distinction between JHAs and JSAs.
And then came Deepwater Horizon.
Final Version of SEMS
Following the Deepwater Horizon catastrophe, the MMS was renamed BOEMRE, and then BSEE. One of the many acts of this new agency was to include all twelve elements of SEMP in the SEMS rule, which was published in October 15th 2010 with an effective date of November 15th 2010. Covered facilities were given one year in which to comply, i.e., their programs should be finalized by November 15th 2011. It should be noted that nothing actually happened on that date - it is not like a tax document that must be mailed in on or before the deadline. However, now that the November 15th 2011 deadline has passed, owner/operators are subject to full SEMS audits and incident investigations.
Companies on the OCS that need to implement SEMS face two particular challenges. The first is to do with the tight deadline. The second concerns the owner-operator/contractor interface.
Further information to do with SEMS is available at our SEMS page.
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