OK, maybe they are not so fearless, but here are my five predictions for what will happen on the SEMS front in 2014:
- 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.
Over the past three months, I have spoken with a number of auditors and attended presentations on SEMS audit results. In particular, I was impressed by excellent presentations from the Center for Offshore Safety, representing the largest oil and gas operators, and M&H, which audited the lion’s share of small to medium operators. I use the information from those conversations and presentations for the workshop class on SEMS for Contractors that I teach. Today I wanted to draw some year-end lessons:
- The stuff we knew would be hard turns out to be hard – When companies were developing SEMS, everyone knew evaluating training/competence of contractor crews, operating procedures and mechanical integrity were industry-wide weaknesses. Based on the audits, it looks like we still have a long way to go.
- Consistency of audit processes and results is a problem – The first auditors had to make up the rules as they went. Is this a compliance audit or a systems audit? When is something a corrective action vs. a notation? What gets reported to BSEE? So it is no surprise that results were all over the map and looking for general trends is like comparing apples to oranges to golf balls.
- What gets looked for gets found – The old saying is, to a guy with a hammer, everything looks like a nail. SEMS is such a broad area, covering everything from the hard science of engineering to the softer science of human factors. That is a lot of territory for an audit team to cover and, especially when it comes to physical visits to facilities, with all of their complexities. As a result, individual auditors tended to focus on what they understood. Anecdotally, I have heard that many auditors had Coast Guard inspection backgrounds and if there is anything a Coastie understands, it is emergency response. So that is an area that some auditors focused attention on, even though it may be the area of SEMS the industry has the most experience with.
- Audits may not be the best way to evaluate the quality of a SEMS plan – The three previous trends will improve as we do more audits, but this last one may be a problem we can’t overcome. It really looks like most of the audit deficiencies were based on compliance with specific SEMS requirements. For example, one potential discrepancy from an audit was whether the operating procedures included “lease or concession stipulations” not whether the SOP is accurate or a review of JSA’s focused on whether the forms were filled out correctly, not whether the JSA accurately described the task the crew had to perform. In other words, audits look at black and white proof of documentation, not the grey areas of whether a process is effective, especially involving highly technical processes.
This is not the auditors fault. It is just the reality of what an audit does best – review documentation in an objective, non-judgemental manner. The failing of this was pinpointed by my friend Ian Sutton when he asked at a conference whether an audit looks qualitatively at safety-by-design alternatives that are considered by the original engineering team for a facility. The answer, of course, is no.
So after the first round of audits, the industry may be faced with a rather unappealing reality. The audits are a tool for assessing the programs, but they are a flawed tool and they cannot be relied on as the only tool. They can tell an operator whether its SEMS plan looks good, but, in some critical ways, they may miss the sort of fundamental problems that can cause a catastrophe. A historical comparison might be the Maginot Line, a system of concrete fortifications meant to protect France from German invasion before World War II. An audit would have shown it to be well-planned, well-built, and well-provisioned. The only problem was it failed in the first week of the German attack. The challenge in 2014 will be to use audits to help win the fight for safety, not just the battle over documentation.
Register now for one of two free webinars to be held on January 15th where we will look at the requirements to evaluate worker skills and knowledge under SEMS and a new tool to help with compliance.
Oil and gas operators are requiring contractors to prove that their personnel know how to do their jobs safely offshore. We will look at what the industry is doing to meet the requirements and introduce SEMSReady, a new one-day class that helps contractors create an evaluation system.
Click here to register or to sign up for one of our SEMSReady classes.
Contact us for more information.
On Christmas Eve, the U.S. Coast Guard published changes to its credentialing rules to meet the new international STCW code. Makes for exciting reading – 216 pages of technical jargon that explains what it takes to train, license and maintain credentials for a mariner.
I won’t go into much on the changes, except to say that:
- This is complex stuff that may take some time to sort through.
- Vessels working in the oil and gas industry have not been a good fit for the STCW code because the jobs they do are so different from their deep-draft colleagues for whom the STCW code was written.
- Over time, this may force OSV companies into more structured and expensive training.
For now, the workboat companies will need to scramble to parse out the new requirements, because they take effect in March of 2014. For example, one change will be that the basic safety training that every seafarer takes under STCW must be renewed every five years, which includes a jump into a pool from heights and working in a smoke room. While that training makes perfect sense, there is a concern for the older mariners who may not be in the best shape.
From a SEMS standpoint, STCW makes it easier to quantify that a given seafarer is qualified to work safely and competently, but it will require a massive Management of Change, to borrow from the SEMS buzzword.
Today’s safety tip – Careful on the roads if you get too full of turkey and holiday cheer.
Guidelines for Hydrogen Sulfide exposure have gone through a major change. Did you know about it? Looks like not many safety professionals in oil and gas did. A survey found that more than half of the professionals contacted did not know that the American Conference of Governmental Industrial Hygienists has recommended a dramatic reduction in the allowable exposure limits. More significantly, three-quarters of the people who did know about the change are not moving very quickly to adopt it.
You can read more about the actual guidelines themselves here, but OH&S Online says the meat of it is that:
(ACGIH) changed its recommended threshold limit values (TLVs) for airborne hydrogen sulfide (H2S) exposure. Previously, the ACGIH recommendation for an eight-hour time weighted average (TWA) exposure limit was a concentration of 10 parts per million and the 15-minute short-term exposure limit (STEL) was 15 ppm. The new recommendations for airborne H2S exposure are a TWA of 1 ppm and an STEL of 5 ppm. While compliance with these recommendations is not mandatory, they were developed from scientific data gathered by ACGIH during several years on the health effects of H2S exposure.
As the article states, the guidelines are not mandatory and the OSHA levels are still higher, but OSHA recently announced an online database of permissible limits, including these new H2S guidelines. This threatens to become a dangerous legal grey area for employers where several limits exist side-by-side with no clear definition of what consitutes “safe” limits.
SEMS requires that all offshore personnel are qualified to work safely and effectively. But how do you prove that?
Ever since the rule went into effect, operators have struggled to validate contractor competency and contractors have struggled to show their workers have the skills and knowledge required under SEMS.
In 2014, the industry will see a renewed push from operators to evaluate workers and industry groups like the Center for Offshore Safety and IADC will release industry guidelines.
SEMSReady™ is a new course that gives companies a step-by-step approach to meet this important SEMS challenge. Please join us for a free webinar where we will discuss industry trends on evaluations and how SEMSReady™ can help your company develop and manage an effective, auditable evaluation program.
The webinar will be held:
Or if you are ready to sign up for a class and get ahead of the curve, our next classes are scheduled for:
- January 8, 2014: Lafayette, LA
- January 14, 2014: Houston, TX
Go to www.semsready.com/events-1.html for registration.
Please contact us with any questions.
To the debate over leading indicators of safety (near misses, etc.) and lagging indicators (injury stats, etc.), here is one more datapoint to consider – clumsiest cell phone users. Square Trade, a company that insures cell phones, publishes an annual list of states with the worst records for damaging cellphones.
Texas and Louisiana, Both oil and gas hubs, made the top 10 list again this year. Wyoming which is seeing big increases in production moved up to number 10 on the list. Other oil and gas-producing states on the list are Utah and California. If our crews can’t hold on to their phones, should we be surprised that dropped tools are such a problem?
And the number one location for slippery fingers and dropped phones? Washington, DC. Hmmmmmmmm.
Here is a link to the announcement.
The article, Proving Skills and Knowledge Under SEMS: One Solution, looks at how our SEMSReady training helps companies meet this important challenge.
The next two SEMSReady classes will be held:
January 8, 2014: Lafayette, LA
January 14, 2014: Houston, TX
We are also holding two free webinars on January 15th to explain the SEMSReady Skills and Knowledge training to offshore operators and contractors.
Go to www.SEMSReady.com/events-1.html for more information.
On Friday, we told you OSHA was looking to revise its Process Safety Management (PSM) rules. As a part of that effort, the agency is asking whether PSM should apply to landside drilling, servicing and production of oil and gas wells. The notice was published in the Federal Register today. You can read what we said about the proposal in our last posting.
As they say in the movies: This is not a drill! Industry will have a limited time to comment on the rule and, while it will take a while for the proposal to work through the regulatory process, this is how the government may impose a safety management requirement similar to SEMS on landside operations.