Most offshore oil and gas companies are getting ready to do their next round of audits of their Safety and Environmental Management Systems (SEMS) plans and these audits promise to be very different (and possibly tougher) than the last audits. New audit rules went into effect for SEMS plans in June. As of June 4, 2015, all audits of an oil and gas operator’s SEMS plan must be done according to the requirements of the SEMS II rules. Under the change, the team lead for audits must be independent from the operator and must be part of an accredited audit provider. Also in June, BSEE, the agency in charge of SEMS, named the Center for Offshore Safety (COS) as the accrediting body for audit providers.
This promises to have a significant impact on how SEMS is done for two reasons. The first is that upcoming audits must be done under the COS rules. That means new training, new guidelines and possibly more expense for most offshore operators. This is a whole new approach for most of the companies that hold offshore leases.
The bigger change may be in how audits are performed. BSEE made it very clear that the first audits were all about getting the programs into place and beginning the process. The agency expected to see SEMS programs evolve and improve, or else. In its recap of audit results last year, BSEE said:
Based on the first cycle of BSEE audits, the general finding is that the current status of SEMS
implementation is geared toward compliance. Operators, in general, did not provide evidence
that they are implementing SEMS as an effective management tool.
In May, BSEE officials went further in their presentation to the Offshore Technology Conference, saying that many of the audit protocols in the first round did not capture the level of documentation, implementation and effectiveness of operator programs.
Need help preparing for your next SEMS audit or making sure your safety program lines up with your customer’s requirements? Contact Lifeline Strategies at KenWells@LifelineStrategies.com or call (985) 789-0577.
What does this mean? It means Operators will be under great pressure from both BSEE and the COS to perform systems audits rather than compliance audits. The simplest explanation of this is that in a compliance audit, you may look at whether written procedures are in place and whether they are done according to the SEMS rule. In a systems audit, you may look at whether the operator has a system in place that allows it to ensure that the right procedures are in place and are being followed. For contractors, it means operators will put even more pressure on them to ensure that they have their own systems and that procedures are effective.
Remember, what gets audited gets done and when the audit rules change, it can change the way everyone does business.