Module 3 – Safety Environmental Management Systems (SEMS) (Refer to Moodle for due dates)
Background Information:
The Safety Environmental Management Systems (SEMS) rule applicable to offshore operations was issued as a final rule on October 15, 2010 and became effective on November 15, 2010. The rulemaking incorporated by reference the American Petroleum Institute’s Recommended Practice 75, Development of a Safety and Environmental Management Program for Offshore Operations and Facilities. Then the federal government amended the SEMS rule. SEMS II rule was issued as a final rule on April 5, 2013 with an effective date of June 4, 2013 except for revised auditing requirements under § 250.1920 were in compliance was delayed until June 5, 2015.
The SEMS rule is a management systems approach that contains 17 major elements as follows:
1. General
2. Safety and Environmental Information
3. Hazards Analysis
4. Management of Change
5. Operating Procedures
6. Safe Work Practices
7. Training
8. Mechanical Integrity
9. Pre-startup Review
10. Emergency Response and Control
11. Investigation of Incidents
12. Auditing
13. Recordkeeping & Documentation
14. Stop Work Authority
15. Ultimate Work Authority
16. Employee Participation
17. Reporting Unsafe Conditions
Assignment Instructions:
Located in the course folder within module 3, you will find final rules as published in the Federal Register that were issued for SEMS and SEMS II. Skim through these two documents. An additional two power point presentations can be viewed that summarizing both rules.
Starting on page # 63,637 of the Final Rule issued on Oct 15, 2010, read about the how BSEE conducted a study that analyzed accident panel investigations and used the Incidents of Noncompliance (INCs) as part of the justification for why SEMS was necessary. In this study BSEE reviewed 4,284 INCs issued between 2003 and 2009 for drilling and production activities and found that approximately 96 percent were related to 1 or more of the following SEMS elements contained in the final rule:
• Hazards Analysis,
• Management of Change,
• Operating Procedures, and
• Mechanical Integrity
In this assignment you will replicate the study but include current INC’s data issued for calendar years 2014 – 2016. Use the following reference to locate information.
There are 120 total INCs issued during the three-year period with paid penalties totaling $11,610,766 USD.
Analyze the INC’s (all 120) and determine in your opinion which of the 13 elements each incident would be applicable to the violation based on your understanding of how each INC relates to more of the 13 SEMS elements. For example, you will find numerous instances of violations where a safety control device was placed in bypass. This incident of non-compliance would relate well to the operating procedures element of the SEMS regulation. You will need to be familiar with the scope of each element of SEMS and you will have to make some informed judgments about matching up an INC an element of SEMS.
The final product should include the following content organized within the framework of a technical report:
1. A listing of the 13 SEMS elements and number of INC’s you identified related to each element. Note you can only pick one element even though it may apply to more than one.
2. Include a “Not Applicable” item to account for any INC’s you were not able to relate to one of the 13 elements.
3. Include a percentage (number of related INC’s per element divided by 103 incidents for the three year period being analyzed). Rank the elements from highest to lowest in terms of percentage.
4. Compare your top four elements based on percentage ranking to the study conducted by BSEE as was outlined starting on page # 63,637 of the Final Rule issued on Oct 15, 2010 . How does your top four compare to the 96% conclusion reported in the SEMS final rule published on October 15, 2010.
You should prepare a well-developed technical report of your analysis using MS word. The technical report sections must include: 1. Introduction, 2. Methods (describing your procedures of what you performed), 3. Data, 4. Discussion and 5. Conclusion. The use of tables, charts and/or graphs in your technical report is required.