Update: Introducing New Workshop To Help Contractors Pass Audits – January 28 In Houston

Learn The Secrets Of A Successful Audits

On January 28th in Houston, we will present a unique workshop to help contractor get ready for and manage the audit process.   We’ve gathered best practices and expert advice to give you a commonsense approach to turning audits from a near-death experience to a way to let your company’s safety program shine, including:

  1. Setting up your documentation system
  2. Preparing for an audit
  3. The different types of audits
  4. What do do when the auditor arrives
  5. Follow-ups after the audit is over

We will also reveal new research into the costs of audits and industry trends.

Registration

The class will be held in Houston
January 28th at 2 p.m.

If you register by January 20th, you will qualify for an early bird discount.

Click here to register

Reefer Madness – USCG Weighs In On What Is Legal

The states of Washington and Colorado have legalized recreational marijuana use and 20 states have legalized some form of medicinal marijuana use.  Some employers may feel they are heading into uncharted waters when it comes to their drug and alcohol policies, especially when the question is whether the employee is “under the influence.”

Now the Coast Guard has spoken loud and clear.  From a maritime perspective, the policy is still zero tolerance.  The agency released a Marine Safety Information Bulletin (MSIB) this week that says very clearly that marijuana is still a prohibited Schedule 1 prohibited substance and any trace in a drug test may cost mariners their credentials or be a factor in an incident investigation.   A good source of maritime news is the blog run by Dennis Bryant and you can find the announcement that he posted here.

This is good news for maritime employers because it says there is no grey area.   It makes it much easier for them to impose a zero tolerance policy because they are following the policy of the agency that regulates them.

However it doesn’t make their job any easier in educating their employees on the rules.   It is very likely that a mariner will take a g”Rocky Mountain High” vacation in Colorado on the assumption that it is legal, only to take a surprise drug test that can cost him his job when he gets home.  Employers need to make their policies very clear.

It is also possible that the question of impairment comes up in the future.   According to online sources, a DOT urine test shows traces of alcohol for up to 24 hours, but marijuana can show up for 7-60 days depending on the use.  Some court somewhere may wind up having to answer the question of whether use a month ago equals impairment today.  For for now, the Coast Guard has probably done everyone a real favor.

Evaluating Workers Under SEMS Webinar

logoWe held our webinars on evaluating worker Skills and Knowledge under SEMS and rolling out our SEMSReady program to help contractors meet the requirements.   We had great participation, which indicated that the industry is working hard to address the requirements.   Many, if not most, of the operators have some sort of requirement for contractors to evaluate their personnel on an annual basis, but contractors have had a hard time figuring out how to meet that requirement.   Our conversations with operators indicate they plan to really push that requirement this year and the Center for Offshore Safety will soon release industry guidance on developing a skills and knowledge management system.

We talked about the industry trend Wednesday and then explained how the SEMSReady program teaches contractors to produce an evaluation system that really represents the work their employees perform and offers follow-up assistance to put that system in place.  You can see more on SEMSReady at www.semsready.com.

Anyone who missed the webinar and would like the see the presentation can contact me at kenwells@lifelinestrategies.com and I will send it to you.

Customer Audits – Chance to Shine or Near-Death Experience?

Learn The Secrets Of A Successful Audits

On January 28th in Houston, we will present a unique workshop to help contractor get ready for and manage the audit process.   We’ve gathered best practices and expert advice to give you a commonsense approach to turning audits from a near-death experience to a way to let your company’s safety program shine, including:

  1. Setting up your documentation system
  2. Preparing for an audit
  3. The different types of audits
  4. What do do when the auditor arrives
  5. Follow-ups after the audit is over

We will also reveal new research into the costs of audits and industry trends.

Registration

The class will be held in Houston
January 28th at 2 p.m.

If you register by January 20th, you will qualify for an early bird discount.

Click here to register

Safety Culture – How Hard It Can Be

Safety culture is a hot topic in industry.    Google “Safety Culture” and you find 749 million references!   In the offshore oil and gas world, the regulating agency BSEE has made helping to foster safety culture one of its primary goals.

But we always have to remember that creating a safety culture is hard work.   Read this article  from the Harvard Business Review’s blog concerning the efforts of one mining company to change its culture and you can see just how hard it can be.  It included the indefinite shutdown of a South African mine while its safety program was revamped and the retraining of thousands of individuals.

Hopefully no one in the U.S.  oil and gas industry faces those kinds of challenges or has to take such drastic steps.  But we do know it takes a focused, tough-minded effort.   As a term, “safety culture” can be hard to define, but it doesn’t happen without work.   When you talk to companies that have a strong safety culture, they always say it is worth it, but they never say it is easy.

New Classes To Start The New Year Off Right

Lifeline Strategies will be holding a number of classes and workshops to help keep you on top of your game when it comes to safety management.   Go to our Classes and Workshops page to find the latest schedule and registration information.

Here’s what we have going on right now:

  • SEMSReady™ Skills and Knowledge Classes – SEMS requires operators to evaluate their workers and contractor personnel to make sure they can do their jobs safely and effectively offshore.   Learn how to create a skills and knowledge verification program in your company and how to evaluate workers to meet this challenging requirement.
    • Special note – Want to learn more about skills and knowledge evaluations under SEMS?  Join us for one of two free webinars on Wednesday, January 15th.
  • SEMS Workshops For Contractors – SEMS II kicks in this year and operators will be putting more pressure on contractors to meet their safety requirements.  Will you be ready?  This half-day program looks at the new SEMS II requirements and the results of the 2013 audits to teach contractor management, sales people and  and other customer representatives the ins and outs of the SEMS rule.
  • How To Survive A Contractor Audit – Audits are becoming much more important and the costs of failing an audit have never been higher.  This unique workshop gives real world best practices for using audits to let your company shine.
  • SEMS For Vessels Webinar –  The Coast Guard has plans to require some sort of SEMS plan on vessels that work in the offshore oil and gas industry.  Learn what the Coast Guard is trying to accomplish and what you can do about it

Check  our Classes and Workshops page for new sessions.    You can also schedule any of these classes to be held at your company.  Contact KenWells@LifelineStrategies.com with any questions.

New Safety Management Rules For Landside Oil and Gas?

I have already written on this blog about OSHA’s efforts to extend its Process Safety Management (PSM) rules to oil and gas drilling and production.   It is part of a much larger effort to revise and expand PSM to a number of industries.  In the case of oil and gas, this would be similar to implementing the offshore SEMS rules to landside operations.

Now you have a chance to learn more and have your voice heard.   OSHA and other agencies are holding a “listening session” on a White House initiative called Improving Chemical Facility Safety and Security (Executive Order 13650) in Houston on January 24.

You have the option of attending in person or listening in on a teleconference, but you must register here to participate.

In my experience in dealing with the regulatory and public policy process, when the government proposes something as large as this initiative, two outcomes are real possibilities.  One is that the proposal is too big for the agencies to get their arms around and it doesn’t succeed.

However, the other possibility is that there are so many moving parts to the proposal that it is difficult for any one industry to successfully argue that is shouldn’t be included or that there is a better way to address its concerns.  In that case, the industry tends to get swept up in the proposal without being able to make its case.    The upstream oil and gas industry has successfully argued that PSM is a bad fit for its operations in the past, but if it wants to continue to stay outside the PSM regulations, it will need to make sure its voice is heard above the noise that this proposal is producing.

 

SEMS Plans on Vessels – January 16th Webinar Focuses on Coast Guard Proposals

The Coast Guard says it wants vessels working in the offshore oil and gas industry to have SEMS plans and has given industry and the public until January 23 to comment on the proposal.

Lifeline Strategies and Moxie Media will explore this important issue in a webinar to be held at 2:00 p.m. central time on January 16th.  

Topics include::

  • What the Coast Guard may have in mind on vessel SEMS
  • What it may mean to the industry
  • How to make sure your comments are heard.

To learn more or to register, click here.

At last check there were only 33 comments to the public docket on the Coast Guard proposal, but that is expected to jump as industry groups start to weigh in.   Additionally, the Coast Guard advisory group, the National Offshore Safety Advisory Committee, has formed four different working groups, representing different segments of the offshore vessel industry.   They will be working to develop comments on behalf of their different groups.  Contact us if you want more information on those working groups.

Too Many Audits or Too Few? Take Our Survey on Contractor Audits

When you talk to contractors, you can’t help but conclude that the number of audits has increased, but by how much?  What do audits cost as an industry?  What aspects of a contractor safety program are being looked at?

In researching this issue, I have been surprised by how little we actually know about contractor audits.   Everyone has an opinion, but there has been very little in the way of studies or surveys on the subject.

Let’s answer some of those questions!   If you are a contractor, please take the survey here.   I will be happy to share the results with you when it is finished.

 

More Predictions – Five Trends To Watch In 2014

Yesterday I posted five predictions  that would drive SEMS in 2014.  There was a lot of interest so I am pulling out the crystal ball again to look at five trends for this year.    Note: a trend is a prediction that you are pretty sure might happen, but you don’t want to bet the ranch on.

So here they are:

  1. Operators continue to exit the Gulf of Mexico – Under SEMS a number of small operators  either sold off their assets or P&A’d their properties.  Some of that is the usual churn that always happens on the shelf, but you get the sense that something else is going on.   Some operators have always treated properties like an ATM – take out money when they can and put money in when they have to.    Some operators have held onto projects that are near the end of their life-span, delaying decommissioning until prices  justify wringing out the last few drops of hydrocarbons.   The compliance costs of SEMS add a new layer of risk and disrupt the economic model.   When BSEE started SEMS, it said there were 130 operators offshore.  In November it said there were 84.   A potential reduction in operators of 45% doesn’t make any sense, but clearly there has been a reduction.   And remember operators are taking out around 10 structures on the shelf for every new one they put in.
  2. Operators pare down their contractor lists – We are hearing from some pretty big operators that they want to scale back on the numbers of contractors they are using, maybe dramatically.   We have heard it before, but this time it has two new drivers.
    • Evaluating contractors under SEMS costs money.  The more contractors you evaluate. the more it costs.   The economies of scale mean it costs about as much to evaluate a small contractor as it does a medium contractor.  So, fewer contractors means cheaper SEMS.
    • Don’t forget that the point of evaluating contractors is to weed out the unsafe players.   As operators determine who “gets” SEMS and who doesn’t, it is only natural that they will lean on the ones that do.
  3. Larger contractors manage subcontractors more closely – See above.   Just because operators cut back on the number of contractors on their vendor lists, doesn’t mean they no longer need those services.   Larger contractors will absorb a lot of that internally, but there will also be a push for them to take a firmer hand in evaluating their subs.   Some of it will shift costs from operators to large contractors.   Some of it will shift liability.  Honestly, some of it is just the offshore pecking order.
  4. Safety culture takes hold – OK, is this a trend or just a wish?   A lot of operators and contractors have very healthy safety cultures, but that is by no means universal.   The push from BSEE in 2013 was to extend that safety culture throughout the industry.   We may see operators take up that call with their contractors this year for a key reason.   In several of the industry’s incidents over the last year or so, operators were blamed for not having enough oversight of their facilities and the contractors who work for them.   A contractor with a strong safety culture may still make mistakes, but they don’t have to be under the customer’s thumb all the time.   A company with a weak safety culture has to be watched constantly.   Who would you rather have work for you?
  5. BAST – In 2013, BSEE release a proposal for the use of Best Available and Safest Technology (BAST) in the development and use of offshore equipment.   BAST would require a life-cycle analysis of critical equipment, with a goal to maintain and replace that equipment before it fails.  Sounds good, but that is a very complex and controversial area, like predicting when your car will bite the dust.   The comment period closed last month and you can read the full record here.    What the final rule looks like is anyone’s guess, but the chances are it will mean a lot of equipment will need to be replaced over the next few years and that becomes yet another trend that affects which operators stay in the Gulf and who they use as contractors.

Oh, and one more thing – the Saints surprise the world by going on to the Superbowl!    Too far out on a limb?