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Center for Offshore SafetySEMS and SEMS II: The Latest on Auditing –
Requirements, Learning's, Developments and OpportunitiesOctober 9, 2013
Jeff Ostmeyer, EHS [email protected]
www.centerforoffshoresafety.org
COS Mission
The Center for Offshore Safety is designed to promote the highest level of safety for offshore drilling, completions, and
operations through leadership and effective management systems addressing communication, teamwork, and independent third-party auditing and certification.
COS Vision & Path Forward
• One-stop central source for:
- Information & knowledge- Auditor accreditation- Program certification- Tools and technical assistance
• Promote an industry culture of incident-free operations
- Process safety in addition to personal safety- Emphasis on behavior- No harm to people, no harm to environment
• Elevate the industry’s quality and safety standards
- Create and share good practices- Continuous improvement
Dates and SEMS Auditing
SEMS • Effective Nov. 15, 2010 and required operators to
implement a SEMS program by Nov. 15, 2011.• Also required operators to submit their first complete
SEMS audit to BSEE by Nov. 15, 2013.
SEMS II• Effective on June 4, 2013 but operators have until June 4,
2014 to comply, except for auditing requirements.• All SEMS audits must be in compliance with the SEMS II
Rule by June 4, 2015.
COS Independent 3rd Party SEMS Auditing
Types of audits• Audits of Audit Service Providers (ASP)
• Office and Witness audits• Accreditation vs. Certification
• Types of industry audits• COS SEMS Audits
• Minimum 15% sample of facilities each cycle
Audit Characteristics%
Compliance Focus
% System Focus
Typically Performed
ByTypical
FrequencyKey
DriverInspectionPrescriptive
100 0 Field Daily/weekly/monthly
Compliance/Requirement
AssessmentPrescriptive or Performance
0-100 0-100 Field or SME Ad hoc Perceived need – Risk
Compliance AuditPrescriptive
80-90 10-20 Independent audit team
1-3 years/location
Compliance/ Requirement
Management System Audit *Performance
10-20 80-90 Independent audit team
3-5 years/Business unit or Region
Risk – AssuranceCorporate Responsibility
Characteristics of different types of audits
* SEMS Audit
SEMS Audit Reporting Timeline
SEMS audit Initiated
Contract with ASP to perform a
SEMS audit
COS provided a courtesy
notification
Audit Starts
Auditing Complete – Formal audit
close-out meeting
between ASP and Operator
Draft audit report provided
by ASP
Audit likely includes office and offshore
components.
Audit Plan
prepared
As Agreed to by member and
ASP
6 Months Maximum
3 years
30 Days 30 Days
Minimum 30 Days
Operator decides that
audit will meet BSEE
requirements
Audit Plan provided to
BSEE
ASP issues a COS Standard Audit Report to the
Operator
Report identifies Non-Conformances
NCs (does not include corrective
action plans)
BSEE Audit Complete
Corrective action plans developed to
address NC’s identified in the Audit
Report
Corrective action plans include timing
and responsible parties
If audit to fulfill BSEE requirement – ASP submits the report to BSEE with corrective action plans included
ASP accepts and verifies corrective actions; all NCs must be closed out for ASP to
certify
ASP issues COS SEMS Certificate
ASP provides completed COS Standard Audit
Report with corrective action plans to COS in order to share
good practices.
Audit Closed
COS Member Company maintains
their SEMS program
COS Member Company starts next
COS certification
audit within 3 year period
COS Member implements
corrective action plan
As Agreed to by member and ASP
COS member consults with ASP on a verification process.
SEMS Audit Reporting Timeline
SEMS audit Initiated
Contract with ASP to perform a
SEMS audit
COS provided a courtesy
notification
Audit Starts
Audit Plan
prepared
As agreed by member and
ASP
3 years
Minimum 30 Days
Operator decides audit will
meet BSEE requirements
Audit Plan provided to
BSEE
As agreed by member and ASP
SEMS Audit Reporting Timeline
Audit Starts
Auditing Complete – Formal audit
close-out meeting
between ASP and Operator
Draft audit report provided
by ASP
Audit likely includes office and offshore
components.
6 Months Maximum
3 years
30 Days 30 Days
ASP issues a COS Standard Audit Report to the
Operator
Report identifies NCs (does not
include corrective action plans)
BSEE Audit Complete
SEMS Audit Reporting Timeline
Audit Starts
6 Months Maximum
3 years
30 Days 30 Days
ASP issues a COS Standard Audit Report to the
Operator
Report identifies Non-Conformances
NCs (does not include corrective
action plans)
BSEE Audit Complete
Corrective action plans developed to
address NC’s identified in the Audit
Report
Corrective action plans include timing
and responsible parties
If audit to fulfill BSEE requirement – ASP submits the report to BSEE with corrective action plans included
ASP accepts and verifies corrective actions; all NCs must be closed out for ASP to
certify
ASP issues a COS SEMS Certificate
ASP provides completed COS Standard Audit
Report with corrective action plans to COS in order to share
good practices.
Audit Closed
COS Member implements
corrective action plan
COS member consults with ASP on a verification process.
SEMS Audit Reporting Timeline
Audit Starts
6 Months Maximum
3 years
30 Days 30 Days
Minimum 30 Days
Operator decides that
audit will meet BSEE
requirements
Audit Plan provided to
BSEE
COS Member Company maintains
their SEMS program
COS Member Company starts next
COS certification
audit within 3 year period
SEMS Audit Reporting Timeline
SEMS audit Initiated
Contract with ASP to perform a
SEMS audit
COS provided a courtesy
notification
Audit Starts
Auditing Complete – Formal audit
close-out meeting
between ASP and Operator
Draft audit report provided
by ASP
Audit likely includes office and offshore
components.
Audit Plan
prepared
As agreed by member and
ASP
6 Months Maximum
3 years
30 Days 30 Days
Minimum 30 Days
Operator decides audit will
meet BSEE requirements
Audit Plan provided to
BSEE
ASP issues a COS Standard Audit Report to the
Operator
Report identifies Non-Conformances
NCs (does not include corrective
action plans)
BSEE Audit Complete
Corrective action plans developed to
address NC’s identified in the Audit
Report
Corrective action plans include timing
and responsible parties
If audit to fulfill BSEE requirement – ASP submits the report to BSEE with corrective action plans included
ASP accepts and verifies corrective actions; all NCs must be closed out for ASP to
certify
ASP issues COS SEMS Certificate
ASP provides completed COS Standard Audit
Report with corrective action plans to COS in order to share
good practices.
Audit Closed
COS Member Company maintains
their SEMS program
COS Member Company starts next
COS certification
audit within 3 year period
COS Member implements
corrective action plan
As agreed by member and ASP
COS member consults with ASP on a verification process.
60 Days - SEMS II
Goals of this presentation
What will the auditors look for?• Each element of SEMS
• Is each element in place?• Is each element being implemented?• Is each element effective?
NOTE: The question in the COS protocol is the question the auditor must answer…Not the question the auditor asks!
SEMS Elements
1. General – Principles & Scope2. Safety & Environmental Information3. Hazards Analysis4. Management of Change5. Operating Procedures6. Safe Work Practices7. Training 8. Mechanical Integrity9. Pre-Startup Review10. Emergency Response & Control11. Investigation of Accidents12. Auditing the Program13. Records & Documentation14. Stop Work Authority *15. Ultimate Work Authority *16. Employee Participation Plan *17. Reporting Unsafe Conditions *
* SEMS II - not required in first audit
SEMS Elements
1. General – Principles & Scope• This provides the overall definition of the
Operator’s SEMS compliance program. This section includes requirements for management responsibilities, buy-in and support.
• Format: Written documents.
SEMS Elements
2. Safety & Environmental Information• Deals with process safety information which
requires an employer to compile a complete list of hazards and a plan to deal with those hazards. Operator’s SEMS must include information that provides the basis for implementing all SEMS program elements, process design information, operating procedures and mechanical design information.
• Format: Written Plan & supporting documents. Strongly related to Hazard Analysis (#3), Operating Procedures (#5) and Safe Work Practices (#6).
SEMS Elements
3. Hazards Analysis• The operator must ensure the development and
implementation of a hazards analysis program (facility level) and a job safety analysis (operations/task level) for all facilities.
• Format: Likely includes review of hazard analyses, recommendations, and actions, and JSA’s.
SEMS Elements
4. Management of Change• Operator must develop and implement written
Management of Change procedures (MoC) for modifications associated with the following: (1) Equipment, (2) Operating procedures, (3) Personnel changes (including contractors), (4) Materials and (5) Operating conditions.
• Format: Written Documents
SEMS Elements
5. Operating Procedures• Must develop and implement written operating
procedures which provide instructions for conducting safe and environmentally sound activities involved in each operation addressed in the SEMS program. Some specific minimum requirements for what must be included in operating procedures.
• Format: Written document.
SEMS Elements
6. Safe Work Practices• This is a huge element.• The SEMS program must establish and implement safe work
practices designed to minimize risks associated with operating, maintenance and modification activities as well as the handling of materials and substances which could affect safety or the environment.
• The SEMS program must also document contractor selection criteria, including the contractor's safety and environmental performance.
• Operators must ensure that contractors have their own written safe work practices. Contractors may adopt appropriate sections of the operator's SEMS program. Operator and contractor must document their agreement on appropriate contractor safety and environmental policies and practices before the contractor begins work at the operator's facilities.
• Format: Written documents.
SEMS Elements
7. Training • Not just training, but knowledge and skills!• SEMS program must address: Initial training,
Periodic training, Communication of changes and verification of contractor’s personnel training.
• Must also address operating procedures, safe work practices and emergency response and control measures.
• Must document the qualifications of instructors. • Format: Learning Management System (LMS),
training matrix, e-learning, onsite training.
SEMS Elements
8. Mechanical Integrity• The operator must develop and implement written
procedures which provide instructions to ensure the mechanical integrity and safe operation of equipment through inspection, testing and quality assurance.
• The procedures must address: design, procurement, fabrication, installation, calibration and maintenance of equipment; training; inspections; correction of deficiencies; installation of new equipment; construction; verification of various equipment aspects; maintenance; parts; repairs.
• Format: Written documents; extensive use of SMEs; heavy archival requirements.
SEMS Elements
9. Pre-Startup Review• Final check to make sure everything is complete
and correct.• Involves the Operator’s commissioning process;
includes a pre-startup safety and environmental review for new and significantly modified facilities subject to Subpart S to confirm that specific criteria are met.
• Includes a training component.• Format: Primarily Procedures. Partially LMS and
training matrix.
SEMS Elements
10. Emergency Response & Control • These plans must be validated by drills carried out
in accordance with the SEMS training program. • Program must include: Emergency Action Plan;
Emergency Control Center(s) designated for each facility with access to the Emergency Action Plan, oil spill contingency plan, other safety and environmental information; training and drills.
• Format: Written documents with immediate retrieval and archival requirements. LMS, training matrix.
SEMS Elements
11. Investigation of Accidents • The SEMS program must establish procedures for
investigation of all incidents with serious safety or environmental consequences and require investigation of incidents determined by facility management or BSEE to possess the potential for serious safety or environmental consequences.
• Format: Written documents describing action. Immediate retrieval is important.
SEMS Elements
12. Auditing the Program• The SEMS program must be audited by either an
independent third-party or the Operator’s designated and qualified personnel*
• According to the requirements of this subpart and API RP 75, Section 12 within 2 years of the initial implementation of the SEMS program and at least once every 3 years thereafter. (*As defined by BSEE)
• Format: Action with findings as written documents.
• COS Audit Service Providers meet this criteria.• Only requirement is for a SEMS audit!
SEMS Elements
13. Records & Documentation• Reports must be submitted to BSEE.• Required by 30 CFR 250.1928 (in Subpart S).• Requires significant archiving of up to six years,
though the Legal Department may require a longer time period.
SEMS Elements
14. Stop Work Authority (30 CFR 250.1930)15.Ultimate Work Authority (30 CFR 250.1931)16.Employee Participation Plan (30 CFR
250.1932)17.Reporting Unsafe Conditions (30 CFR
250.1933)• Required by SEMS II.• Although included in SEMS, are usually covered
by the other elements.• Not included in RP 75 as separate elements.
SEMS Audit Protocol
All of the Elements in one place• Designed for auditors and is not an inspection
document.• 187 questions (SEMS I).• Covers both RP75 and SEMS.• RP 75 and SEMS Rule (30 CFR 250) Audit Checklist
with Guidance• Free access as part of COS services.• www.centerforoffshoresafety.org
SEMS Audit Protocol Checklist
All of the Elements in one place
COS SEMS Toolkit
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 for Auditors*• COS-2-03 Certification to API RP 75• COS-2-04 Accreditation of Audit Service Providers*• COS-2-05 Standardized Audit Report Form
* Incorporated by reference in SEMS II
Accreditation & Certification
The future of SEMS Auditing
SEMS II• A stop work authority which creates procedures and authorizes any and
all offshore industry personnel who witness an imminent risk or dangerous activity to stop work.
• An ultimate work authority which requires offshore industry operators to clearly define who has ultimate work authority on a facility for operational safety and decision-making at any given time.
• An employee participation plan which provides an environment that promotes participation by offshore industry employees as well as their management to eliminate or mitigate safety hazards.
• Guidelines for reporting unsafe working conditions which enable offshore industry personnel to report possible violations of safety, environmental regulations requirements and threats of danger directly to BSEE.
• Additional requirements for conducting a job safety analysis.• The team lead for an audit must be independent and represent an
accredited audit service provider.
The future of COS SEMS Auditing
Observing COS Audits – Continuous Improvement
Expand Audit Protocol Guidance• SEMS II• Drilling focus• Projects and Construction• Contractors
Lead Auditor Certification
US Coast Guard
Jeff Ostmeyer, EHS [email protected]
www.centerforoffshoresafety.org
Questions, Comments or Concerns?
1990 Post Oak Blvd, Suite 1370Houston, TX 77056
www.centerforoffshoresafety.org