It Is Called Safety Management For A Reason

From time to time, I would like to use this blog look at the different elements of the Safety and Environmental Management System (SEMS) rule and to focus on how they are being put into practice.   The first section, named General Provisions, is more commonly referred to as the Management Section.  It is where the company commits the people, time and other resources to put the plan into place, but it serves a more important function – When management cares, things get done and if management doesn’t care, nobody cares.

Looking at the oil and gas companies, which have to develop the SEMS plans, management involvement is what tells company employees and contractors that they need to follow the plan and not take shortcuts.   This was driven home the other day in a conversation with Greg Gordillo of Bureau Veritas, one of the approved third-party SEMS auditing bodies.   He said that there was a direct relationship between management’s involvement in pre- and post-audit meetings and the number of areas for improvement found by the audit team.   Reading between the lines, management’s commitment to making the plan work and to safety in general shouldn’t start the day it receives the final audit report.  It needs to be ongoing and visible.


How does that impact contractors?   I recently had the chance to sit in with Chris Kuiper, President at Environmental Health & Safety, as he audited an offshore contractor for a major oil company.   I was surprised at how many of his questions focused on upper management buy-in.   As we walked through the different pieces of the company’s safety program, time and time again, Chris wanted to know how involved management (in fact the owner) had been in making changes or reviewing policies.   At one point, he asked if the owner attended safety meeting and how actively he participated.   As it happened, the owner of this company had been the safety manager early in his career and was very hands-on.

It was very clear that, as operators come to understand how much management commitment SEMS requires, they are looking for the same commitment from the owners and upper management of contractors before they put them to work offshore.   If some contractors are not already seeing this when their customers come to audit, they will as this sea change takes hold.

And that makes sense.   Many believe that SEMS won’t be fully effective until there is a shift in the safety culture offshore.   They are right. Safety culture begins at the top.

Next SEMS Workshop For Contractors: Friday, December 6 in Lafayette

We held a very successful workshop last week in Houston to help contractors understand SEMS.   The next one is scheduled for Friday, December 6th in Lafayette, LA.   You can learn more and register here.

This workshop lasts four hours and we cover:

  1. Each of the 13 SEMS elements from a contractor’s point of view
  2. The early lessons learned from the first round of SEMS audits
  3. What you need to know to prepare for the new requirements in SEMS II.

What makes these workshops unique is that they are focused on the contractor’s perspective.  Now that the first round of audits are behind them, operators will be taking a hard look at some specific areas of SEMS.  Knowing those areas and what the operators are looking for will help keep you in compliance.   BSEE’s new push to INC contractors just adds to the importance of staying on top of SEMS.

These workshops are a very simple way to make sure your operations and sales staff understand the new requirements.

Coast Guard Extends Deadline to Comment on Vessel SEMS Plans


A quick update on the Coast Guard’s proposal to require SEMS plans for vessels that work in the offshore oil and gas industry.    The deadline to comment was originally set for December 9, but at the request of industry, the Coast Guard has now extended that deadline to January 23, 2014.   However, there is still no plan to hold any kind of public hearing on the proposal.   You can read the original Advanced Notice of Proposed Rulemaking here.    The notice of the extension can be found here.

Are You Ready For The Public To See Your OSHA Incident Reports?

On November 8, OSHA published a proposed rule that would require many, if not most, employers to submit their injury and illness reports electronically.  The agency intends to post that information online.

The proposal has three elements:

  1. Companies with 250 or more employees would be required to submit their data for injuries, illnesses and fatalities every quarter.
  2. Companies with 20 or more employees need to submit the information from their OSHA 300A form every year if they are part of an industry that is identified in the rulemaking as having incidents above a certain threshold.
  3. OSHA may also tell individual companies to submit specific information to OSHA.

Talk about a game changer!    Even though employers are already required to post this information where employees can see it, putting incident information online where the whole world can see it is opens up a lot of new issues.   Suddenly a company’s safety record becomes part of the public debate over siting facilities, the relative safety of the industry and the image of the company itself.  Every company must be prepared to publicly defend its record in an environment where any incident is too many incidents.

Of course, whether the government says it or not, that is part of the objective here.  There is a famous quote from Supreme Court Justice Brandeis: “Publicity is justly commended as a remedy for social and industrial diseases. Sunlight is said to be the best of disinfectants.”   OSHA clearly believes that public disclosure will be an incentive to reduce incidents.

For some companies this could be helpful.   If perspective employees start looking at incident rates when deciding where to work or customers gravitate to suppliers and contractors based on their public records, it could be a positive for companies that invest in their safety records and a stigma for those that don’t.

One interesting note – The proposed regulation lists the small employers (by NAICS code) that are required to file their annual OSHA 300A form electronically.  Oil and gas companies and oil and gas service companies are not included on the list.   However, that does not mean small companies in the energy sector are off the hook.    Many are listed under the NAICS code as being part of other industries, such as construction.  Also, OSHA has given itself the ability to target specific companies or sectors to report electronically.

This is still a proposed rule, so the public has a chance to comment. Comments are due by February 6, 2014.   OSHA held public hearings on an earlier version of the proposal and it doesn’t look like it will hold others.

What do you think of this proposal – positive or negative?

Honoring Veterans – Those We Know And Those We Don’t



The focus of this blog has been safety, but with Veterans Day coming up, I want to use this one to talk about my father-in-law.   Roscoe flew 33 missions as a B-17 navigator in World War II.  On Tuesday he took one more flight, this time as one of 70 veterans who flew to Washington, DC, as part of the Honor Flight program.  Over the last three years, the group that organizes the flights that leave from Mississippi has taken nearly 600 vets to DC where they tour WWII memorial, the tomb of the unknowns and the Iwo Jima memorial, among other sites.  There are other Honor Flight groups that have taken vets from other parts of the country

It is a moving and fitting honor for these men and women.    Roscoe called it one of the best moments of his life.

We should also honor the people who make these flights happen, including the volunteers who organize what amounts to a very old and a little bit creaky army on the move and the donors who have stepped up to fund the flights.   And we should  recognize the hundreds of people who show up in Washington to greet the vets and who line the corridors of the Gulfport-Biloxi airport to welcome them home again.   Most of these people don’t know any of the vets on the trip.  They just come to show respect.

And then there is my wife, who was so determined to make sure that Roscoe was healthy and ready to make the flight, I think she would have flown the plane if she needed to.

OCS Vessel Industry Has One Month To Comment On Vessel SEMS Proposal

The deadline is December 9th for industry and the public to comment on a Coast Guard proposal to create a SEMS rule for vessels that work in the oil and gas industry.   At last check, there were only five comments on the public docket, almost all of them against the proposal (and at least one of them not for polite company).

Coast Guard inspectors on the job

This is an Advanced Notice of Public Rulemaking, meaning the Coast Guard will still need to go through more steps if it really wants to require  SEMS on offshore vessels like MODUs, OSVs, liftboats, crewboats  and construction vessels.   However, many in industry believe there will eventually be some kind of SEMS regulation for vessels.   For boats that already have  International Safety Management (ISM) plans, the simplest solution would be an appendix that adds the parts that are in SEMS but not ISM.   For them the worst case scenario would be if they had to adopt ISM and SEMS as two separate plans.

Domestic service vessels that do not have ISM have much more to worry about.  Without any safety management system, they would have a hard time bridging to SEMS.   We are advising clients and working with them to develop a safety management system internally so they are prepared if the Coast Guard moves forward with a SEMS approach.   

You can (and should) read the Coast Guard proposal here.  The Coast Guard says it may affect 2200 vessels.

In the meantime, there is another Coast Guard proposal out that is a bit of a mystery.   On October 25th, the Coast Guard sent a proposal to the White House for review titled  Training of Personnel and Manning on Mobile Offshore Units and Offshore Supply Vessels Engaged in U.S. Outer Continental Shelf Activities.    However, there was no explanation of what that might cover or when the Coast Guard hopes to have it out.

If your company needs help creating a safety management system, contact us.

Special SEMS Workshop For Contractors Just Around The Corner

Only a few more chances to register for a special SEMS workshop aimed just at Contractors.


Now that the first round of Operator audits are ending and SEMS II is coming up, your customers will be expecting you to comply with new requirements.  Are you ready?

On Thursday, November 7th, Lifeline Strategies and the Association of Diving Contractors International will be holding a workshop that focuses on giving Contractors the tools they need to meet their customer expectations.    The session will offer commonsense explanations of

  1. How the existing rules impact Contractors;
  2. Lessons learned from audits and;
  3. What the SEMS II changes mean to you.

This half-day workshop will be held at Houston’s Hilton Garden Westchase from 9 a.m. to 1 p.m.

Click here for details.

To register, call ADCI at (281) 893-8388.

BSEE’s New Boss Weighs In

The Director of  the Bureau of Safety and Environmental Enforcement (BSEE), Brian Salerno, took over the job in late August, but with the government shutdown, he hasn’t had much of a chance to outline his priorities.   In the last week, he did give a speech at an international regulator’s forum, where he talked about BSEE’s approach under his watch.

His approach seems to be very much in line with his predecessor, Jim Watson.   That should be no surprise.  Both were admirals in the Coast Guard and both cut their teeth in the maritime safety space.   So it should also be no surprise that Director Salerno’s approach to industry looks a lot  like the Coast Guard’s approach.   Just as BSEE was shaped by the aftermath of the Macondo disaster, the modern Coast Guard was shaped by the Exxon Valdez spill.   The Coast Guard’s approach of working with (rather than against) industry to address spill prevention and response has produced exceptional results.   Salarno’s speech reflects that:

We will continue our outreach efforts, and I am personally committed to four key principles in our interactions: clarity, consistency, predictability, and accountability. We will continue to work closely with the industry to reduce risks, while never forgetting that we work for, and are accountable to, the American people.

He talked a lot about safety culture, saying the regulations are just the “basic ground rules” and industry needs to go beyond the regulations:

So what do we mean by “safety culture” and how should we measure “safe?” Is it merely the absence of accidents? Is it compliance with regulations? Is it how you approach complex activities? I believe it is how you approach risk. How do you balance risk to your employees and the environment with the need to stay on schedule, to complete the well, or to start production? It goes far beyond management decisions. How do your people approach risk? Are they afraid to speak up when they see something wrong? Will they immediately halt operations if their colleagues are in danger? Or, do they only pay attention to the missing handrail when they see the helicopter with a BSEE inspector approaching their facility? How much risk – to themselves – are they willing to accept?

One clear message of the speech was that BSEE is searching for reliable leading indicators.  As Salerno put it: “Past incidents or accidents are a consideration, but this also may not be the best indicator of risk mitigation when you are dealing with low probability – high risk events.”

Click here to read the full test of Director Salerno’s speech.

Work/Life Balance: 100 Percent Tie-Off



I saw this sign at the exit to one company’s parking garage today.   Now, I know there was construction going on at the site and that “100% Tie Off Required Beyond This Point” refers to the need for workers  to tie of fall protection to an anchor.   But I couldn’t help but think, talk about a perfect message to send employees at the end of a long day at work:    “No ties past this point! 100% required.”     Its all about life balance and its a rule worth following.

Seats Still Available For SEMS Workshop for Contractors

Big changes are coming to SEMS.  If you are a Contractor, are you ready to meet your customer’s requriements?

Please join us for a special workshop focused on helping Contractors sort through the offshore SEMS requirements and prepare for the SEMS II changes that are on the way.   We are partnering with the Association of Diving Contractors International to present this half-day workshop on Thursday, November 7th at Houston’s Hilton Garden Westchase from 9 a.m. to 1 p.m.

In addition to helping you understand this important safety regulation and how to meet your customer’s SEMS requirements, we will look at how the first round of audits have turned out and what it means to you, as well as what will change as the SEMS II requirements kick in.

You can find more information on the session here.   To register, call ADCI at (281) 893-8388.