BSEE’s New Boss Weighs In

The Director of  the Bureau of Safety and Environmental Enforcement (BSEE), Brian Salerno, took over the job in late August, but with the government shutdown, he hasn’t had much of a chance to outline his priorities.   In the last week, he did give a speech at an international regulator’s forum, where he talked about BSEE’s approach under his watch.

His approach seems to be very much in line with his predecessor, Jim Watson.   That should be no surprise.  Both were admirals in the Coast Guard and both cut their teeth in the maritime safety space.   So it should also be no surprise that Director Salerno’s approach to industry looks a lot  like the Coast Guard’s approach.   Just as BSEE was shaped by the aftermath of the Macondo disaster, the modern Coast Guard was shaped by the Exxon Valdez spill.   The Coast Guard’s approach of working with (rather than against) industry to address spill prevention and response has produced exceptional results.   Salarno’s speech reflects that:

We will continue our outreach efforts, and I am personally committed to four key principles in our interactions: clarity, consistency, predictability, and accountability. We will continue to work closely with the industry to reduce risks, while never forgetting that we work for, and are accountable to, the American people.

He talked a lot about safety culture, saying the regulations are just the “basic ground rules” and industry needs to go beyond the regulations:

So what do we mean by “safety culture” and how should we measure “safe?” Is it merely the absence of accidents? Is it compliance with regulations? Is it how you approach complex activities? I believe it is how you approach risk. How do you balance risk to your employees and the environment with the need to stay on schedule, to complete the well, or to start production? It goes far beyond management decisions. How do your people approach risk? Are they afraid to speak up when they see something wrong? Will they immediately halt operations if their colleagues are in danger? Or, do they only pay attention to the missing handrail when they see the helicopter with a BSEE inspector approaching their facility? How much risk – to themselves – are they willing to accept?

One clear message of the speech was that BSEE is searching for reliable leading indicators.  As Salerno put it: “Past incidents or accidents are a consideration, but this also may not be the best indicator of risk mitigation when you are dealing with low probability – high risk events.”

Click here to read the full test of Director Salerno’s speech.

Work/Life Balance: 100 Percent Tie-Off

 

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I saw this sign at the exit to one company’s parking garage today.   Now, I know there was construction going on at the site and that “100% Tie Off Required Beyond This Point” refers to the need for workers  to tie of fall protection to an anchor.   But I couldn’t help but think, talk about a perfect message to send employees at the end of a long day at work:    “No ties past this point! 100% required.”     Its all about life balance and its a rule worth following.

Seats Still Available For SEMS Workshop for Contractors

Big changes are coming to SEMS.  If you are a Contractor, are you ready to meet your customer’s requriements?

Please join us for a special workshop focused on helping Contractors sort through the offshore SEMS requirements and prepare for the SEMS II changes that are on the way.   We are partnering with the Association of Diving Contractors International to present this half-day workshop on Thursday, November 7th at Houston’s Hilton Garden Westchase from 9 a.m. to 1 p.m.

In addition to helping you understand this important safety regulation and how to meet your customer’s SEMS requirements, we will look at how the first round of audits have turned out and what it means to you, as well as what will change as the SEMS II requirements kick in.

You can find more information on the session here.   To register, call ADCI at (281) 893-8388.

SEMS Skills and Knowledge Part 3: What The Offshore Industry is Doing About It

Under SEMS,  offshore Operators must verify that Contractor personnel have the skills, knowledge and experience to do their jobs safely and correctly.  So far the results have been sketchy at best.    The industry doesn’t have standard skills or training requirements.  For many jobs there aren’t even standard job descriptions or paths to competency.   This month we have been looking at the challenge this faces for industry.  Today let’s look at what two industry groups are doing to solve it.

The Center for Offshore Safety (COS) represents large Operators and a few Contractors.  Its focus is on deepwater operations, but what starts in deepwater has a way of migrating onto the shelf.   For nearly a year now, a COS volunteer group has been working on guidelines for verifying offshore skills and knowledge.   I have participated as a member of that group and its recommendations still need to be approved by the COS Board, but there have been presentations at public forums that give you an idea of the direction they are headed.

The COS group supports a concept it calls the Skills and Knowledge Management System (SKMS).  In a nutshell, Contractors would need to:

  1. Figure out the critical tasks a worker performs that address specific safety needs(or, for those who are familiar with a Bow Tie Hazard Analysis, act as a barrier  to a safety or environmental hazard);
  2. Determine what training and skills workers need to perform that task;
  3. Regularly evaluate them to on those tasks; and
  4. Create a records system so Operators can verify the worker skills and knowledge.

To put it simply, what does a guy need to know to do his job safely and how do we make sure he knows it.

Again, this is a 10,000 foot view of a detailed process and the COS Board will determine what the final version looks like, but the take-away is that Contractors really need to look at a competency/evaluation process for their workers. Some Operators already require them, but look for that number to jump.


The second initiative comes from the International Association of Drilling Contractors (IADC).   While limited to the drilling side of offshore operations, IADC is tackling both what a good system is and what tasks should be evaluated.   On the system side, IADC has an accreditation process where it reviews a company competency program and gives it a seal of approval if it meets IADC’s criteria.   On the task side, the association has been involved for some time in what it calls the Knowledge, Skills & Abilities (KSA) Project.   This is a massive undertaking to determine critical tasks for a number of drilling positions.  The project started in 2000 and had developed competency guidelines for 12 positions.  Now the program has been stepped up to expand the number of jobs covered and to put more meat into the specific competencies.   While still a work in progress, this process will give the drilling sector new tools to standardize positions and evaluate workers from a common view.

So, two groups with two very valuable approaches to the skills and knowledge challenge.   In the meantime, Contractors still have a lot of work to do in developing systems that work for their companies and the jobs they do.  In a future post, we will look at one program that may help.

Special SEMS Workshop For Contractors – November 7th in Houston

 

 

Are you a Contractor trying to get your arms around SEMS?   Lifeline Strategies is partnering with
the Association of Diving Contractors International to hold a special half-day workshop on November 7th in Houston.

Click here to access the details:  SEMS for Contractors Workshop Announcement – 7 November 2013.

Call the ADCI offices at (281) 893-8388 for registration and information.

This workshop will cover:

  1. Commonsense explanations of the SEMS rules
  2. Lessons learned from the first round of SEMS audits –  As the first round of audits winds up, we will cover  some  of the early trouble spots that are sure to be on the minds of oil and gas customers.
  3. What to expect from SEMS II:  The new revisions to SEMS kick in in June of 2014.   The workshop will  help contractors stay ahead of the changes.
  4. Bridging to SEMS: Contractors may not adopt a formal SEMS plan, but they do need to have a safety management approach that allows them to prove to customers how their safety program matches their customer’s requirements.

Evolving Safety Culture: Leading Indicators to Look For

 

Interesting article on growth of safety culture in the Marcellus Shale area in the east.    It was based on a presentation given by Laura Helmrich-Rhodes, an associate professor of safety sciences at Indiana University of Pennsylvania.   Dr. Rhodes looks at seven signs of an emerging safety culture within a company.   She says these indicators are taking hold in the Marcellus.   How does your company match up?

 

  • Is there true top management commitment to safety?
  • Are employees really empowered to stop work if they see an unsafe situation? Are employees involved?
  • Is there an effort to choose contractors that emphasize safety — even vendors for noncore activities like janitorial or catering services?
  • Is there an instant investigation into any near-miss scenarios so that change can be made.
  • Are near-miss and incidents reported not just to management but to all employees so lessons can be learned?
  • Are risk takers terminated and not celebrated?
  • Is safety given its share of the budget?

Two things that make this notable –  First, drilling in the Marcellus only started about five years ago.  There have been growing pains and a steep learning curve for companies and workers.   The second thing is that Dr. Rhodes believes the safety culture that is taking hold in the Marcellus drilling fields could hold important lessons for other industries, like construction.

Better Double Check the Paperwork: Ohio Man Finds Out He is Still Dead

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Done a check of your records lately?  An Ohio man, who disappeared in 1994 and was legally declared dead,  went to court recently to try to have that decision reversed, in as much as he is still very much alive and would like to get a drivers license.  However, the judge said that a three-year time limit for changing a death ruling and, since that had passed, the man is still dead in the eyes of the law.  The judges calls it a “strange, strange situation” and the man says “”It kind of went further than I ever expected it to.”   Read more here.

OK, so this isn’t about  safety management, but it is about making sure you can keep your documents up to date and that is a big part of safety management, so the lesson here is, make sure your records and documentation are in order, or you may have a hard time proving you have a living, breathing safety program.

Skills and Knowledge Under SEMS 2: A Tough Issue for Operators & Contractors

Last week we started a series of blog posts looking at the SEMS requirement for Operators to verify that Contractor personnel have the skills, knowledge and experience to perform their jobs safely and effectively.  Today we continue that series by focusing on the unique challenges this creates for the industry.

The Problem for Operators

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In the old days, oil companies hired Contractors for their ability to do the job.  It was up to the Contractor to figure out what their employees needed to know in order to do the job right.  The proof was in performance; it was right or it wasn’t.  True, you can only judge performance after the fact, so everything was viewed through the rear view mirror.   But it was a pretty simple system to manage; “You mess up, your fired.”

SEMS changed that.  Now, Operators need to look beyond the performance of the companies they bring in on a project and determine whether each worker has the skills and knowledge to do the job before the job starts.  In fact, in one guidance document, BSEE indicates that Operators need to verify the skills and knowledge of each and every contractor employee who is involved in the project.   Wow!  That’s like saying you need to make sure the newspaper delivery boy knows how to ride a bike before you subscribe to the paper.

First, it is an overwhelming task given the thousands of contractor personnel involved in the industry.   Second, the truth is the Operators don’t really know all that much about many of the jobs that are done offshore.   If they wanted to be in the welding business, they wouldn’t need to hire welders.

The Problem for Contractors

The challenge for Contractors is a complex one.   First we need to start with an understanding that, statistically, the offshore world is a pretty safe place to work.   According to the U.S. Bureau of Labor Statistics, in 2011, the offshore injury and illness rate was 0.8 incidents per 100 full-time workers, compared to a rate of 5.0 for the transportation sector and 4.4 for manufacturing.   A lot of that success is because offshore workers are pretty good at what they do.   So the issue is not so much competence, as how we measure competence.  That is where Contractors are having trouble.

For starters, we don’t even have common job titles and descriptions offshore, much less standardized skills and knowledge requirements.   Two completely different jobs may have the same title (try figuring out whether a mechanic  does maintenance or installation of equipment) and two different titles may describe the same job (Does a Field Service Specialist need to know more than a Field Service Technician?).   To give one specific example, the master of a liftboat and the master of an OSV are both captains, but their daily jobs are very different.

The other problem is that, while we may believe our crews are, we don’t have objective criteria to prove it.   If you ask the owner of a small Contractor company how he knows he has the right people on the job, the answer will probably be “because I have been doing this for 25 years.”

Unfortunately SEMS doesn’t care if we have really good intuition that workers are skilled. Verifying skills and knowledge under SEMS involves having a process that backs up “having a good gut feeling that kid will make a good wireline operator” with objective, documented and auditable proof.

That is the challenge that will define this issue for the next year or two.  In a future blog post, we will look at how one industry successfully addressed that problem and the lessons that may hold for the offshore world.

The Five Stages of SEMS

I was talking with Katherine Warren of the Boxley Group, who works with works with oil and gas clients on information management and process improvement, and she jokingly referred to contractors wrestling with SEMS going through the five stages of grief.  It struck me as pretty apt.   So here is my take on the “Five Stages of SEMS:”

  1. Denial“SEMS doesn’t apply to us.  That’s something the oil companies have to do.”    (or “We hardly ever go offshore”  and “We don’t work in deepwater.”)
  2. Anger – “What do you mean, I have to fill out a training matrix?”   (Or “ Why should I send you my Safe Work Practices?  My company has been working for you for 15 years!”)
  3. Bargaining“Just let us finish this job and we will have the records straightened out the next time you need us.”
  4. Depression “Not another audit!”
  5. Acceptance “So we hired someone to just fill out the online questionnaire, we’ve uploaded all our RAVs, we met all the training requirements….what?  The project got delayed?”   

So where is your company on the Five Stages of SEMS?

The Hot Issue on SEMS Right Now: Skills and Knowledge

The SEMS issue that you hear the most about right now is probably the requirement that Operators verify the skills and knowledge of Contractor personnel.  We are going to devote the next few blog posts to exploring the issue, where companies are today and some of the solutions that are starting to emerge.

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This is certainly one of the toughest parts for both Operators and Contractors to get their arms around.   The SEMS and SEMS II regulations have something like 11 references on the need for Operators  to verify skills, knowledge or experience of personnel,  such as:

  • You are responsible for making certain that contractors have the skills and knowledge to perform their assigned duties and  are conducting these activities in accordance with the requirements in your  SEMS program.” (30 CFR 250.1914 (b) (2))
  • “Periodic training to …verify  adequate retention of the required knowledge and skills.” (30 CFR 250.1915 (b))

The requirement doesn’t just involve personnel who go offshore either.  Shoreside activities like maintenance and design work may also fall under the regulations.

For industry it has been a huge shift in focus, from hiring companies and then expecting them to do the job safely and correctly to making sure that each worker knows how to do his or her individual job before they start work, at least under a strict reading of the SEMS rules.

So how has industry addressed this?  For the first year or two of SEMS, the focus has been on collecting pieces of paper – certificates, diplomas, class rosters, resumes – anything that shows evidence that a worker was at least  taught required aspects of the job.

The concern is that that is not enough.   Sitting through a class doesn’t prove you know how to do something or that you know the right way to do it.  After all. how many of us really want to go back and try to pass that geometry test we took back in Junior High?   Besides that,  a lot of the most skilled workers in the industry learned through on the job training.   How do we track that?

Over the last few months Operators are increasingly looking at worker skills evaluations as a way to drill down to whether the individual has the specific skills to do the job right now.   Apache (whose shelf assets have now been sold to Fieldwood Energy) led the way on this by requiring Contractors to provide evaluations of their personnel every year.  Apache/Fieldwood doesn’t tell Contractors how to do that, just that it needs to be documented and auditable.

As more and more Operators adopt that model, the focus is turning towards and effective and standardized model for the evaluations.  More on that in a future blog.  If you are looking for help complying with this area, feel free to contact us.