Offshore SEMS May Change With New Audit Rules

lifelinelogoMost 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.

 

Offshore Safety – What is working and what is not

For those who are not familiar with the Center for Offshore Safety (COS), it is the collective “campfire’ where the deepwater oil and gas industry can gather to discuss safety.   One of the more valuable things that COS does is define and track safety performance indicators and lessons learned from incidents in offshore oil and gas.  A recent COS  report digs into industry safety performance.   You can (and should) read the full report here, but here are some of the highlights.

Lifting incidents continue to be the main source of offshore safety incidents, accounting for nearly half of the incidents reported by COS members.   The next three sources were:

  1.  Process safety,
  2. Loss of station resulting in drive off or drift off and
  3. Life boat, life raft, or rescue boat.

Need help getting your safety management program in place or addressing SEMS requirements like procedures or training?  Contact me at KenWells@lifelinestrategies.com.


The high number of lifting incidents shouldn’t surprise anyone; it is the time when forces like gravity and kinetic energy can have the biggest impact on risk.   It is also the place where smart companies focus a lot of pre-planning, pre-slung loads and other safety measure.

The report then goes back and looks at some of the lessons that can be drawn from the incidents.    More than half of the identified areas for improvement were in safe work practices and operating procedures.   This is significant because, while safe work practices were one of the first areas that industry tackled when the SEMS rule went into effect, operating procedures continues to come up as an area for improvement.   About 30 percent of the incidents had roots in weak “Quality of Task Planning and Preparation,” In other words, crews are not planning well enough, either because they are not properly trained or supervised.

There is room improvement in the safety data COS collects.   One of the most significant problems is that it only represents deepwater operators who belong to COS.  But this is a groundbreaking report.  In the past, BSEE has gathered incident data and has publicized it in different forms.   Now industry is taking the lead in identifying weaknesses and addressing them in a very public way.

New SEMS II Audit Protocols and Operator Guidance Are Out

Word comes from the Center for Offshore Safety that the audit protocols for SEMS plans have been updated to include the new requirements for SEMS II.   Additionally, new guidance is coming out on how industry may interpret SEMS II and what operators will require from their contractors.

We will cover all of this at the next SEMS Workshop For Contractors.  The session will be held next week:

June 24: Lafayette, LA

For more information or to register, click here.

Note:  This is the only SEMS workshop scheduled at this time.

This workshop can also be delivered at your office for your staff.   For more information, contact me at

KenWells@LifelineStrategies.com or (985) 789-0577

SEMS II – New Industry Interpretations

SEMS II kicks in in a little more than two months and oil and gas companies are gearing up to implement the changes.    In particular, there will be a number of new training requirements and processes to put in place.  Groups like the Center for Offshore Safety, API and the Offshore Operators Committee have been working to interpret the requirements so that the industry can take a consistent approach.

Those interpretations and the requirements of SEMS II are a major focus for our SEMS for Contractor Workshops.    We have just set up two new workshops for April in Lafayette and Houston.   The sessions will be held:

Tuesday, April 22nd – 8 a.m.  Lafayette

Register Here

 

Wednesday, April 23rd – 8:30 a.m. Houston

Register Here

We can also hold a special workshop at your company and focusing on your scope of work.

For more information contact me at KenWells@LifelineStrategies.com or Phone: 985-789-0577.

New Classes to Help You Meet SEMS II

SEMS II kicks in less than three months from now. Our classes will help you get ready to meet your customer requirements under the safety rules.

Just Added:  SEMS Workshop for Contractors

We have just set up two classes in April. The SEMS Workshop for Contractors takes a commonsense approach to explaining:
New SEMS II requirements
How to meet existing operator SEMS plans
Lessons from the 2013 SEMS Audits

April 18 – Houston
Register Here

April 22 – Lafayette
Register Here

SEMSReady Skills And Knowledge Classes

Under SEMS, many operators require contractors to evaluate their workers every year to make sure they are qualified. Our SEMSReady classes teach you how to create a skills and knowledge evaluation that can pass customer audits and meet industry SEMS guidelines.

Register Here

April 16 – Lafayette

April 17 – Houston

 

Next SEMSReady Class Thursday, March 13, in Houston

If you are an offshore contractor, chances are your customers now require  you to evaluate your workers every year under SEMS.
How is that going?

Our SEMSReady classes train managers and evaluators to perform skills and knowledge evaluations that can be documented and audited.   The next classes are in Houston on Thursday or Houston and Lafayette in April.

The schedule is:

March 13, 2014:   Houston, TX

April 16, 2014:   Lafayette, LA

April 17, 2014:    Houston, TX

To find out more about classes, click here or call 985-789-0577.

SEMS Skills & Knowledge – Why Qualifying Evaluators Is So Important

When you read the offshore industry guidelines on managing skills and knowledge under SEMS, one of the first things that jumps out at you is the need to make sure the evaluators of offshore personnel are qualified.   

As background, SEMS requires that operators verify that their contractors have the skills and knowledge to do their jobs safely and effectively.  Earlier this year, the Center for Offshore Safety came out with guidelines to help companies develop a Skills and Knowledge Management System (SKMS) and some operators will make having an SKMS a require for their contractors.  Section 8.1.2 of the guidelines says companies need a way to determine assessor (evaluator) qualifications.

Why is that so important?   It is because experience has shown that in any assessment system evaluators, administrators, instructors and proctors are the weak link.   Sometimes the people who are being evaluated or tested do cheat, but the hardest fraud to control is caused by the people who control the evaluation process.   Here are some recent headlines highlighting fraud by the people who were supposed to be safeguarding the system:

Navy sidelines 30 nuclear instructors suspected of cheating – The  Navy says it caught 30 staff members at an elite school fudging the test that allows people to train students to work on nuclear submarines.

Facing fraud investigation, Palo Alto Utilities changes tests for gas workers – An office worker told authorities his boss told him to fill out 30 test forms for workers to help them pass their pipeline operator qualification evaluations.

School Proctor and Admissions Officer Plead Guilty in Student Financial Aid Fraud Scheme – The FBI says school officials falsified test results to help students who had not finished high school qualify for aid at a trade school.

The message is that the people who perform evaluations, observe testing or administer programs have a unique opportunity to commit fraud.   That is why the COS recommends that companies make sure their assessors are qualified and that the program is audited.    It is also why you can expect operators to pay close attention to whether contractors are meeting those requirements.

Those are features of our SEMSReady™ skills and knowledge classes and follow up program.  In our classes, we focus on teaching companies how to develop objective evaluations that measure and document quantifiable skills.  We teach administrators and evaluators the importance of accurate, measurable skills and knowledge assessments.   Finally, we are able to audit results to make sure the process is being followed.

Center For Offshore Safety Issues New Guidelines For SEMS Skills Verifications

The Center for Offshore Safety just made public new guidelines to help the oil and gas industry prove that offshore workers know how to do their jobs safely.   The Safety and Environmental Management System (SEMS) rules are very clear in saying oil and gas operators need to verify that all offshore personnel (theirs and contractors) have the skills, knowledge and experience to work safely and effectively.   What has not been clear is how the industry is supposed to accomplish that:

  • Does it mean collecting class certificates?  That doesn’t prove a worker actually learned the material.
  • Does it mean sending a resume?   That shows experience, but doesn’t show how well an individual can do the job.
  • Does it mean sending a letter from the company that says, T-Joe has the skills, knowledge and experience to work safely?”   Seriously?

It is a real problem and many operators are trying to address it by requiring annual worker evaluations from contractors.  But that leaves contractors wondering what kinds of evaluations will be acceptable and leaves operators without a good way to figure out if the evaluations have real meaning.

For the last year the Center for Offshore Safety has been working on industry guidelines to help both operators and contractors.  Those guidelines have now been approved and made public.  They can be found here.    It is important for every contractor to read and understand these guidelines because these could very quickly become customer requirements.

I served as a member of the COS group that worked on the guidelines.  As a participant, I can say that the group members felt these were necessary and within the abilities of every company that works offshore.

But that doesn’t mean it is easy.  Companies will need to commit some time to making sure they are evaluating the right skills and doing it in a way that will survive an audit.

Lifeline Strategies and OQSG, a leader in the pipeline evaluation field,  have developed a program to help contractors.  We call it SEMSReady™.   It involves the options of classes, hands on assistance in developing programs and database management to track employee training and evaluations.    You can read an article that Rigzone ran on our program here.  If you would like more information click www.SEMSReady.com or email me at KenWells@LifelineStrategies.com.

Come To Our Next SEMS Workshop and Get a Free Pass To Underwater Intervention

SEMS II kicks in  just five months from now and it includes five new training requirements.  As a contractor, are you ready?   The next SEMS workshop for contractors will be held on February 12th in New Orleans and a large part of our focus will be on SEMS II.  As an added bonus, participants will receive a free floor pass to Underwater Intervention, the premier event for the commercial diving and ROV industry.

This half-day workshop is the simplest, most easily-understood way to get your arms around the regulations that drive so much of the safety rules offshore.  For more information or to register contact the Association of Dive Contractors International at (281) 893-8388.

 

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.