Operating procedures are a key part of the offshore oil and gas Safety and Environmental Management Systems (SEMS) Rules. If you think of SEMS as a true system, with interlocking parts, operating procedures are the glue that holds the parts together. It is where:
- Hazards analysis is applied to the actual scope of work,
- Specific skills, knowledge, training and safe work practices can be identified and applied, and
- Mechanical integrity has real world meaning (is the equipment or tool fit for purpose, when used?).
If there is a problem or a need for change management, the procedures should be one of the first things to be reviewed.
The focus on operating procedures is not a coincidence. The Bureau of Safety and Environmental Enforcement has long identified operating procedures as critical to offshore safety and environmental compliance. In fact, when the government issued the SEMS Rule in 2010, analysts looked at 42 different accident investigations to determine what parts of the safety rule might have had the biggest impact. Hazard analysis identified in 24 cases, but operating procedures was a very close second with 23. Operating procedures were cited as a cause in more than half of the 19 of those incidents that resulted in fatalities.
And what about since the rule came out? A quick search of the fines that BSEE has levied since SEMS went into place shows that failure to have proper procedures or to follow them was a factor in the following gross fine amounts:
2012 – $90,000
2013 – $255,000
2014 – $205,000
2015 – $264,000
2016 (six months) – $300,000
Those numbers don’t really tell the whole story. They just identify the cases where an investigator saw a clear link. There may be more cases where a weak link in the process might have been identified or a human error prevented if the procedures had been in place and followed.
Are you comfortable with your company’s procedures? Do they comply with the offshore SEMS rule? Can you use them as a tool to focus your safety barriers on the activities that really matter.
Lifeline Strategies offers a one-day class on writing operating procedures that comply with the law, make sense and tie your safety system into your operations. Click here for the Operating Procedures Description and Outline. For more information, contact us at firstname.lastname@example.org.