Moving Toward Safety Inspections: Enhancing SEMS Implementation
Shifting focus from compliance to safety, the presentation discusses SEMS audits from 2011-2015, highlighting challenges, successes, and the push towards effective safety inspections. It covers audit results, operator responses, and measures to improve SEMS implementation, emphasizing the importance of consistent reporting formats and continuous evaluation for better safety outcomes.
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Presentation Transcript
2015: Moving our goals from Inspecting for Compliance to Inspecting for Safety John Cushing Chief, Safety Inspection & Renewable Energy Section NOSAC fall meeting November 19, 2015
Outline SEMS update Recap 2011-2013 (1stround of audits) Shifting from compliance to effectiveness YTD 2014-2015 (2ndround of audits) Initiatives, challenges, and successes SEMS moving forward National Inspection Program Risk Based Inspection Program Regulatory Interpretations/FAQ webpage 2
BSEEs SEMS Focus 2011-2013 First Round Audit Results (through 2013) Confirmed existence of SEMS for >95% of operators at that time INC s and shut-in orders issued when evidence of SEMS implementation was not available Inconsistent report formats and approaches Most findings concerned quality of documentation or supporting evidence of implementation 3
BSEEs SEMS Focus 2014-2015 Examine Audit Approach and Auditor Quality Contract with Accreditation Body Improve Reporting Formats Consider SEMS Maturity Initiate review & updates to API RP 75 Outreach OESI, IMCA, OOC, etc. In-reach What can BSEE do better? 4
2014-2015SEMS Audit Results 17 Audit Reports received 12/14 8/15 7 used accredited Audit Service Providers (i.e. ~59% did not) Examines SEMS implementation at 204 facilities Inconsistencies are fewer, but they still exist in report formats More details on findings, gaps in some, but not all reports 5
SEMS Going Forward Improve BSEE Ability to Evaluate SEMS Implementation Observing the Audit Process Dialog with an operator on its approach to its Corrective Actions and to Opportunities for Improvement Possible BSEE conducted audits of CAP implementation Listen to feedback from the BSEE inspectors Clarify SEMS expectations for: Start-ups Mergers and Acquisitions Bankruptcies 9
National Inspection Program (Proposed) Annual Inspections Safety Performance RBI SEMS Audits (focused inspections)
Risk Based Inspection Program Annual inspections of offshore production facilities required. Industry/BSEE data supports the observation that 80% of reportable incidents on OCS platforms occur at ~20% of those facilities. By focusing on higher-risk facilities and operations, BSEE will: Focus limited inspection resources on higher risk activities Systematically monitor and manage facility and operational risk profiles. 11
Risk Based Inspection Program Augments existing annual Inspection Program Utilizes extensive data and experience gathered from BSEE s Annual Inspections, plus SEMS audits, Incident Investigations, Permitting activities, Industry knowledge from other Agencies, Research and Emerging Technologies. 12
Building off the Model Quantitative assessment based on a BSEE developed model (A) the foundation; Behavioral components and performance data (B) inspection and SEMS findings; and Subjective insights and background info (C) other sources of risk info. Facility Prioritization Company Performance Other Risk Related Intelligence (C) Inherent Risk (A) (B)
Methodology Objectives Flexible: allows for quantitative assessment of historical performance data as well as subjective and institutional learnings of BSEE. Integrated: managed as part of the National Inspection Program which includes the annual inspections and SEMS audits. Proactive: allows for proactive or learning opportunities for BSEE. Performance Based: success defined in terms of program objectives not INC s or % of facilities inspected.
Other Initiatives Website for FAQ http://www.bsee.gov/Regulations-and- Guidance/Regulatory-Interpretations/Regulation- Interpretations/ PINC List update/revise/redesign? 15
BSEE Website: www.bsee.gov @BSEEgov BSEEgov Bureau of Safety and Environmental Enforcement
