Safety and Environmental Management Systems - SEMS
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SEMS Regulatory History - 1990 to 2009 - 2010 to 2019 | Regulatory Interpretations and Oversight | Culture of Safety | Performance and Opportunities to Improve | OCS Performance Measures | Feedback
A Safety and Environmental Management System (SEMS) is a performance-based approach to integrating and managing offshore operations. The purpose of a SEMS is to enhance the safety and environmental performance of operations by reducing the frequency and severity of incidents.
There are four principal SEMS objectives, as highlighted in the Federal Register preamble to the current SEMS rule:
- focus attention on the influences that human error and poor organization have on incidents;
- continuous improvement in the offshore industry's safety and environmental records;
- encourage the use of performance-based operating practices; and
- collaborate with industry in efforts that promote the public interests of offshore worker safety and environmental protection.
SEMS Regulatory History
1990 to 2009
A SEMS framework was proposed in response to the 1990 National Research Council's Marine Board finding that the bureau's prescriptive approach to regulating offshore operations had forced industry into a "compliance mentality." The Marine Board found further that this compliance mentality was not conducive to effectively identifying all the potential operational risks or developing comprehensive incident mitigation. As a result, the Marine Board recommended, and the bureau concurred that a more systematic approach to managing offshore operations was needed.
In response to the Marine Board findings, the American Petroleum Institute (API), in cooperation with the bureau, developed Recommended Practice 75 - Development of a Safety and Environmental Management Program for Outer Continental Shelf (OCS) Operations and Facilities. The API also produced a companion document, RP-14J, for identifying safety hazards on offshore production facilities. The API RP-75 was published in May 1993. In 1994, the bureau published a notice in the Federal Register that recognized implementation of API RP-75 as meeting the spirit and intent of SEMS. The API RP-75 was updated in July 1998 to focus more on contract operations, including operations on mobile offshore drilling units.
Since API RP-75 was first published, the bureau has used public meetings, seminars, letters, research, and Federal Register notices to promote and encourage SEMS implementation. To date, four OCS-wide, SEMS implementation surveys have been conducted by the API. The bureau has co-sponsored many widely attended SEMS performance measures workshops and meets regularly with industry trade associations to promote SEMS.
The SEMS approach for coordinating OCS oil and gas operations recognizes worker safety and pollution control are largely dependent on proper human behavior. The bureau has asked OCS operators to make SEMS an essential business practice component.
On May 22, 2006, the bureau published an Advance Notice of Proposed Rulemaking (ANPR) in the Federal Register (71 FR 29277), to seek comments and information on ways to improve the regulatory approach to safety and environmental management for OCS operations. The purpose of this ANPR was to acquire information necessary to improve the regulatory system and industry safety and environmental performance through a requirement for an integrated management system. Based on incident investigation findings and performance reviews with operators, the bureau and industry identified a need for performance improvement in the following four areas: (1) hazards analysis, (2) operating procedures, (3) mechanical integrity, and (4) management of change. The ANPR then discussed several options for implementing a SEMS; one option was to require that only the four elements listed above be adopted and implemented; a second was for operators adopt a comprehensive safety and environmental management approach comprised of all elements of API RP-75.
On June 17, 2009, the bureau published a Notice of Proposed Rule (NPR) in the Federal Register (74 FR 28639) based on industry and public feedback from the 2006 ANPR. The bureau proposed to publish a rule with a requirement for operators to adopt only the four essential elements: hazards analysis, operating procedures, mechanical integrity, and management of change. Based on the analysis of incident panel investigation reports, incident reports, and incidents of noncompliance, bureau subject matter experts determined that the root cause of most OCS incidents was failure of one or more of these four elements. The bureau believed that requiring operators to implement a SEMS would result in reducing the risk and number of accidents, injuries, and spills during OCS activities. In response to this proposed rule, the bureau received 61 sets of comments, of which 57 were from individual entities (companies, industry organizations, or private citizens). Some of the 61 comments were duplicates, not related to the proposed rule, or the same company submitting multiple comments.
In response to several requests, the bureau issued a National Notice to Lessees and Operators (NTL No. 2009-N05) on August 12, 2009, announcing a public meeting on September 2, 2009, in New Orleans, Louisiana, to discuss the proposed rule.
2010 to 2019
On October 15, 2010, the bureau published the Final Rule for 30 CFR Part 250 Subpart S - Safety and Environmental Management Systems, in the Federal Register (75 FR 63610). This Final Rule incorporated by reference, and made mandatory, all elements in the API RP-75, Third Edition, May 2004, reaffirmed May 2008. This recommended practice, including its appendices, constituted a complete Safety and Environmental Management System. API RP-75 (third edition) consisted of 13 sections, one of which was a ''General'' section. This related to the 12 elements identified in the 2006 ANPR as part of a comprehensive SEMS, adding the overall principles for a SEMS, and establishing management's general responsibilities for SEMS success.
On September 14, 2011, the bureau published a Notice of Proposed Rulemaking in the Federal Register entitled, ‘‘Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Revisions to Safety and Environmental Management Systems’’ (76 FR 56683). These proposed revisions to 30 CFR 250, subpart S, grew out of and strengthened the original SEMS framework by supplementing the requirements in API-RP 75 to ensure that all companies are implementing current best practices and establishing well-functioning SEMS programs. The final rule known as SEMS II was published on April 5, 2013 (78 FR 20423). Specifically, it required operators to integrate six additional requirements over and above the requirements in API RP-75 Third Edition, to enhance the program and facilitate oversight:
- Job Safety Analysis (JSA) signature and approval requirements;
- Auditing by an audit service providers (ASPs), accredited by a BSEE-approved accreditation body (AB);
- Stop Work Authority (SWA);
- Ultimate Work Authority (UWA);
- Employee Participation Plan (EPP); and
- Reporting Unsafe Working Conditions.
At the time of the SEMS II promulgation, BSEE issued a Fact Sheet to summarize how it modified the original SEMS requirements.
In December 2019, the API released the fourth edition of Recommended Practice 75, re-titling it as “Safety and Environmental Management System for Offshore Operations and Assets.” This fourth edition reorganizes the recommended SEMS framework into 14 elements. BSEE has yet to begin a formal evaluation of whether or how to adopt the fourth edition changes into its regulatory structure. In the meantime, BSEE is willing to entertain proposals from operators to adjust their individual approaches to SEMS based on fourth edition recommendations which appear to have an added benefit of ensuring that each of the redefined 14 SEMS elements embed four main principles: (1) Commitment, (2) Risk Management, (3) Human Performance, and (4) Continual Improvement.
SEMS Regulatory Interpretations and BSEE Oversight Practices
Questions regarding BSEE expectations of SEMS implementation and compliance, are published in the Regulatory Interpretations section on bsee.gov. To request an interpretation of a BSEE regulation, submit your request by email to bseeQandA@bsee.gov, and if the question is specific to the SEMS regulation, copy firstname.lastname@example.org.
BSEE has also published its “Safety and Environmental Management Systems (SEMS) Oversight and Enforcement Program (OEP)” chapter in the Bureau Manual. Part 503, Chapter 1, Version 1. This chapter describes the BSEE approach in overseeing operator adaptation of SEMS requirements.
SEMS and a Culture of Safety
On May 9, 2013, one month after issuing the SEMS II Final Rule, BSEE issued a Safety Culture Policy Statement recognizing that a SEMS promotes a culture of safety within operating companies, and that sustainable improvements in safety performance are only possible when leadership and operating culture support and promote its maturation. While BSEE does not regulate safety culture, SEMS requirements should lead to a culture that embraces communication, risk awareness, team management of the risk, and a learning environment to foster continual improvement.
Additional guidance on enhancing the safety culture of offshore operations is available in the following publications:
- National Academies of Sciences, Engineering, and Medicine, “Strengthening the Safety Culture of the Offshore Oil and Gas Industry” Transportation Research Board | Special Report 321, issued 2016.
- Center for Offshore Safety Publication COS-3-04, “Guidelines for a Robust Safety Culture”, First Edition, April 2018
Analysis of SEMS Performance based on Audit Results and OCS Performance Measures
SEMS audits conducted to comply with BSEE regulations provide insights into the successes and challenges of the SEMS regulation. Every three years, BSEE conducts a detailed analysis of the audit results to determine if BSEE’s regulatory requirements and operator culture, are meeting stated SEMS program objectives, namely better awareness and control of risks.
As of June 2020, three cycles of SEMS audits had been completed. An analysis of results from all three audit cycles indicates that offshore operators have mostly established the foundations of a conforming, SEMS but are experiencing challenges in operational consistency. Following each audit, operators are expected to develop and implement a Corrective Action Plan (CAP) that will define the steps, timeline, and responsible parties for addressing gaps and concerns identified during the SEMS audits. Strengthening the CAP process is considered the key to unlocking further improvements in SEMS effectiveness. BSEE’s oversight of this process is designed to ensure operators address system root causes rather than simply treating observable symptoms.
Additional guidance on determining SEMS effectiveness, and on improving SEMS auditing and corrective action processes, are available in the following publications:
- National Academies of Sciences, Engineering, and Medicine, “Evaluating the Effectiveness of Offshore Safety and Environmental Management Systems” Transportation Research Board | Special Report 309, issued 2012.
- Center for Offshore Safety "Good Practice" documents
- COS-3-01, “Guidelines for Leadership Site Engagement”, First Edition, May 2013
- COS-3-02, “Skills and Knowledge Management System Guideline”, First Edition, December 2013
- COS-3-03, “Guidelines for SEMS Maturity Self-Assessment”, First Edition, October 2017
- COS-3-04, "Guidelines for Robust Safety Culture", First Edition, April 2018
- COS-3-06, “Guidance for Developing and Managing Procedures”, First Edition, January 2020
- Center for Offshore Safety Auditing Documents
- COS-1-06, “Guidance for Developing a SEMS Audit Plan”, First Edition, March 2020
- COS-1-07, “Guidance for Developing a SEMS Corrective Action Plan”, First Edition, March 2020
- COS-1-08, “SEMS Audit Report Format and Guidance”, First Edition, March 2020
OCS Performance Measures
BSEE's SEMS regulation requires all operators submit performance measure data to BSEE.
During the first quarter of each year, BSEE's SEMS rule (30 CFR 250.1929) requires all active operators to submit performance measures data outlined on Form BSEE-0131 (Form-0131 instructions). Information about the data survey and how to submit performance data is provided in Notice to Lessees 2018-N05 (issued September 10, 2018), supplemented by Notice to Lessees 2020-N01 (issued December 23, 2019). This latter NTL describes minor modifications to the form, effective January 1, 2020, to eliminate duplicate data requests. The data helps BSEE gauge aspects of the offshore oil and gas development & production industry's safety and environmental performance on the OCS. The bureau uses these formulas to calculate a variety of annual, OCS-wide, performance indices. These indices allow operators to benchmark their performance against aggregate industry data, as well as provide the public with OCS performance trends information.
To make the BSEE OCS Performances Measures data collection program more efficient, BSEE developed a software application that accepts electronic versions of Form BSEE-0131. This application, called Performance Measures Data, resides in BSEE’s Technical Information Management System (TIMS) Web database. TIMS is the bureau’s core mission application for planning, permitting, and reporting functions; it provides the tools to manage the wide array of data and information needed to accomplish the bureau’s day-to-day mission requirements effectively. TIMS is the industry’s portal for electronic submission of documents and data to BSEE.
The Performance Measures Data application enables the user to enter data into an online Form BSEE-0131, save and submit the data, and keep track of previous submissions. The data collected online is the same as that collected with the PDF and paper versions of the form. BSEE continues to accept PDF and paper versions of Form BSEE-0131.
The continued success of the OCS Performance Measures Program depends on participation by OCS lease operators. Completed forms may be sent by any of the following ways, with the new online Performance Measures Data application being the preferred method:
fax: 703-787-1093, Attn: Craig Thomas
mail: BSEE, Attn: Craig Thomas 45600 Woodland Road, MS VAE-ORP, Sterling, VA 20166
The most current OCS Performance Measure Tables can be accessed through the following links:
Similarly, the most current OCS Performance Measures Incident Rate Charts can be accessed through the following links:
These reports show that since BSEE first promulgated SEMS requirements in 2010, there has been a general reduction in reportable injury and incident rates, though challenges still exist. BSEE is conducting additional analysis of systems and root causes of ongoing incidents and adjusting oversight practices to further drive better safety performance.
For questions or comments about the SEMS program in general, the Audit Program, or the OCS Performance Measures Program, please contact Stan Kaczmarek at 703-787-1612 or send an email to email@example.com.