Beginning June 4, 2014, operators of production platforms on the U.S. Outer Continental Shelf (OCS) must be in compliance with revisions to the safety and environmental management system (SEMS) final rule issued by the Department of Interior’s (DOI) Bureau of Safety and Environmental Enforcement (BSEE).  The SEMS was originally published in October 2010 by DOI’s Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE).  The revisions, called SEMS II, are intended to address safety concerns that were not covered in the first SEMS, according to the BSEE, a successor agency to the BOEMRE. 

SEMS II primarily provides greater employee participation in safety and environmental activities and programs, empowers field-level personnel with safety management decisions, and strengthens oversight by requiring that compliance audits be conducted by accredited third parties.

First response to Deepwater Horizon                        

The first SEMS was issued to reduce the potential occurrence of an event similar to the Deepwater Horizon blowout in the Gulf of Mexico in April 2010.  That SEMS incorporated the American Petroleum Institute’s Recommended Practice 75 (Development of a Safety and Environmental Management Program for Offshore Operations and Facilities) and made the practice mandatory with respect to regulated OCS operations and activities. 

At that time, the BOEMRE said Recommended Practice 75 constitutes “a complete safety and environmental management system program.”  The BSEE later determined that the SEMS needed to be strengthened.  According to the BSEE, the revisions also respond to comments received after SEMS II was proposed in September 2011.

Employee empowerment

SEMS II includes the following changes:

• Job safety analysis (JSA).  Requires that a JSA be conducted for all tasks addressed in the SEMS.
• Auditing.  Requires that all SEMS audits be conducted by audit service providers (ASPs) accredited by a BSEE-approved accreditation body (AB).
• Stop work authority (SWA). Creates procedures that establish SWA and make responsible any and all personnel who witness an activity that is creating imminent risk or danger to stop work.
• Ultimate work authority (UWA).  Clearly defines requirements establishing who has the UWA on the facility for operational safety and decision making at any given time.
• Employee participation plan (EPP).  Provides an environment that promotes participation by employees and management to eliminate or mitigate hazards on the OCS.
• Reporting unsafe working conditions.  Empowers all personnel to report to the BSEE possible violations of safety or environmental regulations and requirements and threats of danger.

First audit still required

The BSEE notes that the October 2010 rule required that operators implement a SEMS program by November 15, 2011, and that they must still submit their first completed SEMS audits to the BSEE by November 15, 2013.  The final SEMS rule does not affect an auditor’s first audit cycle. 

The final SEMS II rule was published in the April 5, 2013, FR.