Gulf Coast Branch of IMarEST Centre for Offshore Safety

(COS)

Charlie Williams

Executive Director

williamsc@centerforoffshoresafety.org

22 January 2014 | Houston

2 http://www.bsee.gov/Regulations-and-Guidance/Safety-and-Environmental-Management-Systems---SEMS/Safety-and-Environmental-Management-Systems---SEMS.aspx

COS Membership

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Owners / Operators / Leaseholders

• Anadarko

• Apache

• BHP Billiton

• BP E&P

• Chevron USA

• Cobalt

• ConocoPhillips

• Exxon Mobil

• Hess

• Marathon

• Murphy E&P

• Shell International E&P

• Statoil North America

• TOTAL E&P

Drilling Contractors • Diamond Offshore Drilling

• Ensco

• Noble Corp

• Pacific Drilling

• Seadrill Americas

• Transocean

Service/Equipment Providers • Baker Hughes

• Cameron International

• Halliburton

• Oceaneering

• OCS Group

• Schlumberger

Affiliates • IADC

• NOIA

• PESA

Charlie Williams, Executive Director info@centerforoffshoresafety.org www.centerforoffshoresafety.org

Safety & Environmental Management Systems What are the elements of SEMS in API RP-75

Leadership Mechanical Integrity

Safety and Environmental Information Pre-Start-Up Review

Hazard Analysis Emergency Response and Control

Management of Change Incident Investigation

Operating Procedures Audit

Safe Work Practices Records and Documentation

Training

Safety and Environmental Management

Systems (SEMS)

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• Goal: Safe & Reliable Operations / Operational Integrity

• SEMS is a key mechanism to reduce the likelihood of major incidents

Core Functions

• Find SEMS Gaps - Data Collection,

Analysis & Reporting

• Close Gaps with Good Practices

• Effectiveness Assurance & Measurement

– Auditing, Accreditation & Certification

• Outreach & Communication

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IMPROVE & SUSTAIN INDUSTRY SKILLS & KNOWLEDGE

SEMS Toolkit and Accreditation/Certification

• SEMS Audit Protocol COS-1-01 (Revision 2 complete)

• Compliance Readiness Worksheet COS-1-02

• Operator-Contractor Letter Templates COS-1-03

• Audit Guidance Document (Revisions starting)

• COS-2-01 Qualification & Competence Requirements

Audit Leads & Auditors

• COS-2-02 Training Program Requirements Auditors

• COS-2-03 Certification API RP 75

• COS-2-04 Accreditation Audit Service Providers

• COS-2-05 Audit Report Form

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SEMS Audit Protocol Checklist

13 sections that corresponds with API RP 75 and 30 CFR 250 – Subpart S (SEMS)

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Audit

Question

Has a management representative been appointed

that is responsible for establishing, implementing and

maintaining the SEMS?

§250.1909(b) [Specifically you, through your management, must:]

(b) Appoint management representatives who are

responsible for establishing, implementing and

maintaining an effective SEMS program.

RP 75 1-

1.2.2(c)

[This recommended practice is based on the following

principles:]

c. Management appoints specific representatives

who will be responsible for establishing, implementing

and maintaining the safety and environmental

management program. 9

SEMS II

• “…working with the COS workgroups on developing indicators to gauge industry OCS performance other

stakeholders. …”

• COS-2-01, Qualification & Competence Requirements for

Audit Teams & Auditors

• COS-2-03, Requirements for Third-party Auditing &

Certification

• COS-2-04, Requirements for Accreditation of Audit Service

Providers

• (ASPs) must be accredited by a BSEE-approved

accreditation body (AB) .. Like COS

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COS SEMS Accreditation and Certification

• Accreditation of Audit Service Providers – Four

accredited by COS (ABS, BV, DNV, ERM); two

additional by end of 1Q 2014

• Certification of COS Members – One certified

by COS (Statoil); preparing to issue additional

certificates to Members

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Bow Tie Approach

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Operator/Contractor Interfaces

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Core Functions & Activities

• Effectiveness Assurance and Measurement

– SEMS Auditing, Accreditation and Certification

• Find Gaps - Data Collection, Analysis and Reporting

– Safety Performance Indicators

– Improving Industry Learning Capability

• Close Gaps with Good Practices

– Leadership Site Engagement

– Skills & Knowledge Management System Guideline

– Ultimate & Stop Work Authority FAQ and Answers

• Outreach and Communication

– COS Annual Forum April 9 & 10

– COS Breakfast, Tech. Session & Lunch at OTC May 8

– External Stakeholder Group

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Challenge Identified

Under 30 CFR 250.194(b), the operator is required to document that each contractor working for you is knowledgeable and experienced in the work practices it will be performing. This documentation needs to be available to BSEE should we ask to see it during a BSEE-conducted evaluation of your SEMS program. BSEE has not specified a format for you to use in preparing this documentation. Acceptable verification procedures include but are not limited to the following or combination thereof: In 30 CFR 250.194(e), the operator is required to perform “periodic

evaluations” of the performance of contract employees to verify they are fulfilling their obligations. These periodic evaluations may included the verification techniques listed above in relation to complying with 30 CFR.250.1914(b), or they may include other operator-conducted verification techniques. These periodic evaluations need to be available to BSEE should we ask for them during a BSEE-conducted audit of your SMES program.

Elements of an effective

Skills & Knowledge Management System

(SKMS):

1. Commitment & Objectives

2. Overview & Scope

3. Accountability & Responsibility

4. Roles &/or Tasks

5. Assessment & Remediation

6. Auditing & Quality Assurance

7. Records & Documentation

COS Learning from Incidents

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Definition

• Voluntary collection of information about major safety

events, COS SPI 1 and 2 events, and near misses (“High

Value Learning Events” or HVLE)

Purpose

• Complement information from the COS Safety Performance

Indicators Program

• Improve understanding of circumstances that led to these incidents and events, and of steps that were taken to

reduce the likelihood of recurrence

• Sharing industry knowledge

Stop Work Authority and Ultimate Work Authority

Guidance

• Developed guidance to industry on these closely related topics as a collective of trade associations (COS, API, OOC, IADC, OMSA, and IMCA)

• Developed Frequently Asked Questions (FAQ)

and Answers

• Developed white paper that explains relationship

between BSEE UWA and USCG PIC

The Future of COS - SEMS Work

SEMS Effectiveness Measures, Tools, & Techniques – Continuous Improvement

Expand Audit Protocol Guidance

• Respond to SEMS Regulatory Changes

• Drilling focus

• Projects & Construction

• Contractors

• Marine

Lead Auditor Training & Individual Certification

Coast Guard

Safety Culture

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COS Annual Forum – April 9 & 10, 2014

COS Safety Management Systems Sessions at OTC – May 8, 2014

• Breakfast

• Morning Technical Session

• Luncheon

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COS Upcoming Events

• COS Annual Forum – April 9 & 10, 2014

• COS Safety Management Systems Sessions at OTC – May 8, 2014

• Breakfast

• Morning Technical Session

• Luncheon

Questions Charlie Williams

Center for Offshore Safety

Executive Director williamsc@centerforoffshoresafety.org

THANK YOU