Safety and Environmental Management System (SEMS) is a performance-based management system that promotes safety and environmental protection during oil and gas operations in the outer continental shelf (OCS). SEMS is a result of the heightened safety requirements following the Deepwater Horizon accident in the Gulf of Mexico in April 2010. The Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE)* published SEMS in October 2010. The safety guidelines became federal law on November 15, 2011.
*BOEMRE was replaced by the Bureau of Ocean Energy Management (BOEM) and Bureau of Safety and Environmental Enforcement (BSEE) in October 2011.
All companies conducting offshore operations in U.S. waters must be SEMS compliant. Compliancy requires safe work practices, training, mechanical integrity, emergency response and control, audits, and more.
Since SEMS is still a relatively new law, many companies still have questions. To help clarify things, we asked Ron White, SEMS Expert at Clover Global Solutions to address a few of the most frequently asked questions about the new guidelines.
Information about SEMS Compliance for Workers
Question: Who is required to have a Safety and Environmental Management System (SEMS)?
Answer: People required to be SEMS compliant include the owner or holder of operating rights, a designated operator or agent, a pipeline right of-way holder, or any lessee(s).
Q. Who is affected by SEMS?
A. Just about anyone doing business with lessees/operators with facilities in the OCS is affected in some way. Contractors providing domestic services – such as food and beverage service; laundry service; and housekeeping — are an exception. Companies’ responsibilities vary depending on whether they are a lessee/operator or contractor, as well as the service or equipment provided.
Q. Are contractors required to have a SEMS program?
A. Legally, no. Contractors are not required by law to have a comprehensive SEMS program. However many contractors have seen the value of SEMS and develop, implement and maintain a SEMS program while satisfying expectations of the operators at the same time.
Q. What if a worker is based onshore, but supports offshore work?
A. It really depends on what kind of work and support are provided. The employer may or may not have some responsibilities regarding SEMS. In this case, check with the employer about the work being supported and the SEMS requirements for that work.
Common SEMS Compliance Questions
Q. If my company acquires a facility; do we need to rewrite the facility’s operating procedures to align with my company’s standards? If so, is there a grace period to complete the task?
A. Yes, current and up-to-date operating procedures need to be in place upon acquisition of a facility. There’s no grace period.
Q. Are resources like ISNetworld or PEC Premier all I need to comply with SEMS?
A. Absolutely NOT. These two companies provide an internet portal for quick and easy access to contractor data as well as additional services. But to comply with SEMS, it’s important to know what you are responsible for. You might need to have the following data on hand (and perhaps more): Safe Work Practices training records; HSE management plans; HSE policies and procedures, and insurance requirements.
Q. What about SEMS II?
A. SEMS II includes modifications to the Job Safety Analysis (JSA). Only an independent third party can conduct an audit.
Q. When do we need to initiate a Management of Change (MOC)?
A. A MOC is not required during regular shift changes in personnel. However, a MOC is required if changing from one contractor to another. Also, it may benefit the operator to conduct a MOC for a change of supervision or person in charge.
Q. What equipment qualifies as “critical equipment”?
A. Critical equipment is used to prevent or mitigate the uncontrolled release of hydrocarbons, toxic substances, or other materials that could cause environmental or safety consequences.
Q. How does an operator determine the level of hazard analysis required for a facility?
A. The hazard analysis should be based on the level of risk associated with the facility. Operators need to be able to justify their selection of risk assessment methodologies and should keep careful records in case of an audit.
Handling a SEMS Audit
Q. What should an operator do if the Bureau of Safety and Environmental Enforcement (BSEE) initiate an audit?
A. The operator should hire an independent third party to conduct the audit, pay for all costs and ensure a report is provided to BSEE with an outline of the results of the audit and a corrective action plan.
Q. What is the protocol for an operator-initiated audit?
A. The operator must notify BSEE at least 30 days in advance with a list of facilities and a nominated independent third party auditor. Programs must be audited within 2 years of initial implementation of a SEMS program and at least once every 3 years thereafter.
Clover specializes in placing professionals in the oil and gas industry. If you are an Operator seeking to augment Project Teams, contact Jeff.W@clovergs.com
If you are an experienced professional looking for opportunities in the Upstream Industry (Alaska, Eagle Ford Shale Play, Bakken Formation, Deepwater Gulf of Mexico), send your resume in complete confidence to Chris.S@clovergs.com