gulf coast branch of imarest centre for offshore safety (cos)
TRANSCRIPT
Gulf Coast Branch of IMarEST Centre for Offshore Safety
(COS)
Charlie Williams
Executive Director
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
4
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 [email protected] 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)
6
• 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
7
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
8
SEMS Audit Protocol Checklist
13 sections that corresponds with API RP 75 and 30 CFR 250 – Subpart S (SEMS)
5
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
10
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
11
Bow Tie Approach
12
Operator/Contractor Interfaces
13
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
14
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
17
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
19
COS Annual Forum – April 9 & 10, 2014
COS Safety Management Systems Sessions at OTC – May 8, 2014
• Breakfast
• Morning Technical Session
• Luncheon
20
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 [email protected]
THANK YOU