Safety and Environmental Management System (SEMS)

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The Bureau of Safety and Environmental Enforcement (BSEE) has issued its rule for the implementation of an offshore "Safety and Environmental Management System (SEMS)" as part of 30 CFR Part 250. It can be downloaded here.

The key to the rule is found in the following quotation, "The Workplace Safety Rule covers all offshore oil and gas operations in Federal waters and makes mandatory the currently voluntary practices in the American Petroleum Institute's Recommended Practice (API RP 75)."

Timing

The SEMS rule became effective November 15th 2010. Discussions with management at BSEE have made it clear that no additional grace period will be allowed. Full compliance is required immediately. The rule includes all phases of offshore operations on the Outer Continental Shelf (OCS) including drilling, production and covered pipelines.

Elements of SEMS

The rule is based on the well-established Safety and Environmental Program (SEMP) as described in API Recommended Practice 75, the first edition of which was published in 1991. The elements of SEMS are listed below.

1. General provisions for implementation, planning and management review and approval of the SEMS program.
2. Safety and environmental information.
3. Hazards analysis.
4. Management of change.
5. Operating procedures.
6. Safe work practices.
7. Training.
8. Mechanical integrity.
9. Pre-startup review.
10. Emergency response and control.
11. Investigation of Incidents.
12. Audits.
13. Records and documentation.

A brief overview of each of these elements is provided below. Detailed guidance for each of the elements is provided in the book Process Risk and Reliability Management.

1. General Provisions

SEMP starts with a General section. Background information to do with the management of process risk and safety programs is available from our Management and Process Safety Management pages.

2. Safety and Environmental Information

Guidance to do with the collection and management of technical information is provided at our Process Safety Management page. 

3. Hazards Analysis

With respect to hazards analysis the MMS stated the following in a previous publication:

This element would require that a hazards analysis (facility level) be conducted for all facilities. The purpose of the analysis is to identify, evaluate, and where unacceptable, reduce the likelihood and/or minimize the consequences of uncontrolled releases of oil and gas and other safety or environmental incidents. With respect to analysis methods, MMS suggests that operators use API RP 14 C, Recommended Practice for Analysis, Design, Installation, and Testing of Basic Surface Safety Systems for Offshore Production Platforms, Seventh Edition, March 2001; or API RP 14J, Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities, Second Edition, May 2001, as guides, as well as other accepted documents and practices. In addition, this element would also require that a job hazard analysis (operations/task level) be performed to identify and evaluate hazards of a job/task for the purpose of hazards control or elimination.

Further information to do with hazards analysis is available from the following sources:

• Hazard and Operability Analysis (HAZOP).
• Process Hazards Analysis.
• Failure Modes & Effects Analysis (FMEA).
• Chapters 3 and 4 of Process Risk and Reliability Management.
  

4. Management of Change

With respect to Management of Change the MMS states the following (also in a previous publication): 

This element would require lessees/operators to document and analyze all proposed facility changes to determine possible adverse safety and environmental impacts, with the exception of replacement in kind. There are a number of specific topics to be covered in this analysis, including changes in: facilities and procedures, personnel, work practices, equipment (including addition of new equipment or modifications to existing equipment), and the safety and environmental implications of these changes.

5. Operating Procedures

With respect to Operating Procedures the MMS stated the following:

This element would require OCS oil and gas operators’ management officials to include requirements for written facility operating procedures designed to enhance efficient, safe, and environmentally sound operations. 

While operating procedures are reviewed as part of MOC procedures, MMS would also recommend that these procedures be reviewed separately to ensure that they reflect current practices.

6. Safe Work Practices

7. Training

The topic of training includes contractors.

8. Mechanical Integrity

The BOEM has stated the following regarding Mechanical Integrity:

This element would require that procedures are in place to ensure that equipment is designed, fabricated, installed, tested, inspected, monitored, and maintained in a manner consistent with appropriate service requirements, manufacturer’s recommendations, and industry standards to promote safe and environmentally sound operations in the OCS.

Further information to do with mechanical integrity is available from Chapters 6 and 7 of the book Process Risk and Reliability Management.