BVC_Wood Group – COS SEMS II Webinar Presentation – 21 April 2014
I was going through one of my flash drives and found this webinar that I co-created and delivered back in 2014. Given the current climate for Safety and Environmental Management Systems (SEMS) I thought some people could use this today.
I don’t think this was the final copy, BV has that and I can’t find it on their website anywhere. So, I thought I would use mine and see if it can help explain to some of those new safety guys out there a bit more about SEMS and SEMS II.
It’s really quite simple, but so many make it hard when it doesn’t need to be. Here is the key to understanding the basics of SEMS and SEMS II.
- You must have a written SEMS plan
- It must be known by your employees (they need to know where to find it)
- You will be audited (both in the field and in the office)
- You will be held accountable against what YOUR plan states
It’s that easy. If you say you have a way of doing things, then do it. I’ve come across so many companies that have a written plan that state they do something this particular way, then they do it another way. That’s when the auditors will ding you. As your program grows, the auditors will hold you to a higher standard.
Go to the Code of Federal Regulations (CFR), 30 part 250 and you will find what you MUST have as a minimum in your plan. Then, you can build from there. I’ve built a few SEMS plans for various companies, it isn’t hard, but does require thought and top management commitment, which is sometimes hard to come by with smaller companies.
Anyway, enjoy the presentation. If I can find my copy with my notes, I’ll include it. If you need any help with SEMS, let me know. I am SEMS lead-auditor trained and have been involved with this for many years.
BSEE SEMS Summary
BSEE finally released its SEMS summary of the audits that were completed in November of 2013. Below is a copy if you want to read it, for those that don’t want to read it; here are some key points for us to keep in mind.
- 96% of the operators in the GOM have SEMS, but the system maturity and understanding amongst those operators vary significantly
- BSEE said the audits “did NOT produce a meaningful performance assessment”
- “Emergency Response” and “Auditing” were the best elements of SEMS the operators understood, had documented and implemented. However, lacking was putting into effect “lessons learned” from audits and drills
- A strong focus among all operators : “Training” and “Safe Work Practices”
- “Pre-Startup Review” was lacking by operators and by auditors suggesting “poor understanding”
- A common finding was that operators have a documented MOC process but did not or could not show how they did it
- Some audit reports were nothing more than a checklist which limited BSEE’s ability to asses degrees of implementation or effectiveness (when I was offshore, I was present for a SEMS audit by a non COS approved I3P Auditor and that’s exactly how they did it – a checklist)
Conclusions by BSEE
- Operators, in general did NOT provide evidence that they are implementing SEMS as an effective management tool
- Maturity of the SEMS program must be taken into account when auditing
BSEE focus for 2nd Audit Cycle due by June 5, 2015
- Establishing expectations for data control to encourage fully supporting the audit findings
- Measuring program maturity and effectiveness and incorporating a SEMS maturing measure or performance indicator
- Engaging operators to discuss recognized best practices and lessons learned for HSE
- Conducting “focused audits” on critical process elements
- Continued work with the Center for Offshore Safety to improve its audit protocol and encourage a “more comprehensive analysis for each item”
What do I think all of this means?
- Audit protocol will change again & now become more subjective & dive a bit deeper in “each item” if BSEE has there way, especially in the Elements of MOC, Pre-Startup Review & in my personal opinion based off of previous discussions with BSEE and members of the COS – Training
- I think that many of the clients Wood Group ODL deals with will likely be held to a higher standard since most of them have had a SEMS program (of some sort) for several years now and will now be judged on SEMS system maturity
- All operators will now have to move past just having a SEMS program to now using SEMS as an “effective management tool”
- Pre-Startup Review , MOC , and Data Control has been becoming a hot topic with our clients that we have been helping with for several months now, I have a feeling it will pick up a good deal
You can find the full BSEE report below.
Official magazine of the Association of Energy Servicing Companies.
For those of you that have ever worked in the oil and gas business offshore, you know what Safety and Environmental Management Systems (SEMS) is and if you work on land you know what Process Safety Management (PSM) is. I’ve audited for both and there is a HUGE difference in the application and adoption.
PSM has been around for 25 years, but o&g hasn’t been using it in many places except on a voluntary basis. SEMS has only been around for a few years and only just became mandatory for all operators in the Gulf of Mexico in Federal waters.
In most cases, SEMS and offshore operations in general are taken far more seriously than land based operations, but as you can see from the article, it looks like that just might be changing sometime in the near future. I guess we’ll see