- Skills and knowledge evaluations take center stage – This is one of toughest parts of the SEMS rule for operators and contractors to get their arms around. Watch for the Center for Offshore Safety (COS) to release a major initiative on best practices for evaluating whether personnel know how to do their jobs safety and effectively. Also watch for operators like Fieldwood (formerly the Apache shelf properties) and BP to come down hard on contractors that can’t prove their people are competent.
- SEMS II training requirements – By June, industry will need to provide training to everyone who works offshore in BSEE’s requirements on JSAs, Stop Work Authority, Ultimate Work Authority, Employee Participation and Reporting Unsafe Conditions. Six Months from now. On your mark, get set, go!
- Ultimate Work Authority (UWA) – SEMS II makes it clear that someone needs to be in charge at all times. Most operators still need to determine who that person is and how the system will work. How will one person keep track of every operation on a project with multiple facilities? Does the contractor become the UWA when a crew goes to an unmanned platform to do maintenance and what liability does that involve? API, the Offshore Operators Committee and COS are trying to sort out the interpretations, but that is still a work in progress.
- Contractor audit protocols – Multiple audits of contractors are an expensive, inefficient burden on operators and contractors alike. COS is said to be working on the framework of what a SEMS-style plan for contractors would look like and then how it can be audited. Industry has been talking about shared audits for a decade. Maybe 2014 is the year.
- Contractor INCs – Incidents of Noncompliance citations are BSEE’s main enforcement tool for operators. In 2012, the agency started applying them to contractors. At least one (and possibly two) contractors are in court challenging whether BSEE has a right to INC them. At the very least, BSEE may have to go through a rulemaking process to change the regulations on INCs. Watch for the legal challenge to play out this year.
That is where I see the offshore safety rules going in 2014. If your company needs help with any aspect of this, give us a call.