The deadline for the first round of SEMS audits was Friday, a date which was celebrated by…nobody. So what does BSEE, the agency that required the audits in the first place, do with the results?
Just one guy’s opinion, but I wish BSEE would to the following:
1. Tell us how many oil and gas operators there are in offshore U.S. waters, based on the ones that turned in audits. Sounds like a simple piece of information but I don’t think anyone really knows. The SEMS rule estimated there were 160, but, given how many offshore facilities are shut-in, that was a guess.
2. Related to that, operators had to give BSEE a company contact when SEMS when into effect. Compare that to the number of audits turned in and tell us how many operators have exited the Gulf of Mexico since the rule went into effect. We know it has happened; let’s quantify it.
3. Scrub the names of the companies from the audit reports and let us know the general results. SEMS is about continuous improvement. Let’s start with the lessons learned from the audits. Rent a very large room. Invite operators and contractors alike and do a “hot-wash” of what has worked and what hasn’t.
4. Issue a Notice to Lessees that clarifies BSEE’s expectations on audits and what the agency’s role will be in future audits. One of the biggest complaints you hear about the audits is over the inconsistencies among audit providers. It is also time BSEE explained whether its job is to audit SEMS plans or to audit auditors.
That’s what is on my wish list. I have made my own study of the types of discrepancies the different auditors found and those lessons learned are a large part of my SEMS workshops and consulting with contractors. But it would be good if BSEE would share its information with industry.