SEMS Warning Signs: Paper-Thin Plans Won’t Cut It.

The Center For Offshore Safety held a very successful conference last week.  Generally speakers were upbeat, with a lot of focus on safety culture.   But there were warnings that SEMS plans that look good may just be paper thin.  Based on who was giving the warnings, industry can’t afford to ignore them.

With any safety management system, there will be differences between what is put down on paper (where it looks great) and what is actually going on in the field (where it tends to get messy).   I call that difference the reality gap.   Sometimes the gap is so narrow you can’t see daylight between the plan and the field execution.

However, based on some of the speakers at the COS conference, the SEMS reality gap for some operators is enormous.   Perhaps the most important warning came from the Director of BSEE, Brian Salerno.    His written remarks are here, including this warning:

One of the major disconnects is between operators and contractors. Many contractors are simply not familiar with safety procedures on a facility, nor is the operator making much of an effort to ensure safety consistency. This has had some horrifying results, and remains an area of concern for us as we consider the future of  the SEMS program.

In the Q&A section of the session, Salerno was even stronger saying BSEE would not allow the SEMS audits to be come a “rogue process…prone to being gamed” by industry.

For anyone who might not follow Washington speak, when the head of the agency that oversees offshore oil and gas says many contractors don’t even know what the safety practices are on the facility and operators aren’t trying very hard to inform them, you take the message seriously.   When a regulator used the words “horrifying results” and that they are looking at them as they “consider the future of” a regulation,  that translates as “get your act together before we do it for you.”

Next up was Coast Guard Rear Admiral Joseph Servido who gave industry a spanking over the state of inspection readiness on vessels in the Gulf.   He talked in particular about a vessel company that called the Coast Guard to do a routine inspection of three vessels that already had International Safety Management Code plans in place.   What did the Coast Guard find? Fire-detection systems that had been bypassed and inoperable rescue boats.  Remember, this wasn’t a surprise inspection.  The company had called the Coast Guard to schedule the inspection.    Why is this a concern for SEMS?  Because the Coast Guard is making the case for requiring OSVs and MODUs to have SEMS plans.  These kinds of nonconformities are just ammunition in that debate.

Finally, when a panel of auditors discussed lessons learned form the SEMS audits, one speaker said that they found too many cases where documents they were shown for their review had never made it out to the people working on the facility.

That is a reality gap.   It indicates a battle plan that not only doesn’t stand up in the heat of battle, but has never even been shared with the troops on the front lines.

Five humble suggestions to avoid what may be a regulatory hammer:

  1. Bridging documents and MSAs need to reflect an operator’s real expectations under SEMS.
  2. These documents need to be shared with operations and HSE departments and not be stuck in the sales departments files.
  3. Bridging documents need to stop being templates and start becoming actually dialogues about whose safety practices are going to be followed and why.
  4. Operators need to beef up their orientations so that they actually explain how SEMS is implemented on a facility, how documents are to be shared and kept.
  5. Now that SEMS  plans are in place and established, focus on how those plans are communicated so that the people in the field can understand them and follow them.

Clearly not every one of these problems apply to every operator SEMS plan and it is not right to paint the industry with the same brush.    However,  if these problems are extensive enough to cause regulators need to step in and fix them, won’t everyone in industry have to live with the results?

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