Offshore Operations

SEMS Offshore: The Safety Management System BSEE Requires

SEMS, short for Safety and Environmental Management System, is the formal program BSEE requires offshore operators to run on the Outer Continental Shelf. It turns safety from good intentions into a written, audited, everyday way of working. Here is how SEMS works and who it binds.

What SEMS is

BSEE, the Bureau of Safety and Environmental Enforcement, requires SEMS under 30 CFR Part 250 Subpart S, a rule BSEE calls the Workplace Safety Rule. It is a performance based approach. The rule sets out what a safe operation must cover, and each operator builds its own program to meet that standard.

SEMS is a management system, not a single checklist. It covers how an operator identifies hazards, how crews are trained, how equipment is kept fit for service, and how work is approved and controlled.

The management layer sits on top of the engineered barriers that protect a well. A blowout preventer is one such barrier. SEMS is the system that makes sure the people running the operation understand the risks around it. See how a blowout preventer works.

Who SEMS applies to

The rule binds operators working on the Outer Continental Shelf. That includes the companies that hold operating rights on leases and the companies that operate facilities there.

Operators carry responsibility for the SEMS program even when contractors do much of the physical work. That is why contractor selection is built into the rule as its own element.

The elements of a SEMS program

The regulation organizes a SEMS program around a set of elements. An operator's program has to cover each one:

• Hazard analysis, so risks are identified and assessed before work starts.
• Operating procedures, written down for the tasks crews actually perform.
• Training, so personnel know the procedures and can carry them out.
• Mechanical integrity, so critical equipment stays in safe working order.
• Management of change, so modifications to equipment, procedures or personnel are reviewed before they take effect.
• Contractor selection, so the companies brought on site meet the operator's safety standards.
• Stop work authority, so anyone can halt work they believe is unsafe.
• Audits, so the program is checked against the rule on a set cycle.

How the elements run in practice

In practice, SEMS is a paperwork discipline. Procedures are written before the job, not reconstructed after it. Training is recorded with dates and topics, so an auditor can see who was trained and when. Hazard analyses are done before the job begins, not during it.

The same discipline applies to site specific risks. An operation that may encounter hydrogen sulfide, for example, needs its hazard analysis, procedures and emergency plans to line up before anyone works in that environment. Read more on H2S safety and contingency planning.

Audits

An operator cannot simply declare a SEMS program and move on. The rule requires the program to be audited on a set cycle, by people qualified to judge whether it meets the regulation.

An audit looks at two things: whether the program on paper covers the required elements, and whether the operation actually follows it. Gaps found in an audit have to be corrected, and the operator is responsible for making sure the fixes happen.

Stop work authority

Stop work authority is the element that puts the system in the hands of the crew. Under the rule, any person involved in the operation can stop work they believe is unsafe.

It does not take a supervisor's permission. The point of the authority is to remove the hesitation that comes from rank or cost pressure. A worker who stops a job for a safety reason is doing what the rule requires, not what it tolerates.

Records and documentation

SEMS exists on paper as much as on site. The rule expects operators to keep the records that show the program is real: written procedures, training records, hazard analyses, management of change documentation, and audit reports.

Those records do double duty. They guide the crew during the job, and they give an auditor the evidence needed to check the program. Without the records, there is nothing to show the program was followed.

How work permits and JSAs feed the SEMS record

The daily paperwork of an offshore operation plugs straight into the SEMS record. A job safety analysis (JSA) is hazard analysis at the level of a single task. A permit to work is the approval that the job can start, with the hazards assessed and the controls in place. How JSAs work in the field and how permit to work systems control jobs.

Every permit issued, every JSA signed, and every training record filed becomes part of the evidence that the SEMS program is being followed. That is why the procedures, permits and training records behind SEMS all live in the same document flow as the work tickets, and why software that keeps tickets, dispatch, approvals, timesheets and documents in one place makes the record easier to keep straight. OpsFlo tracks that document flow for oilfield service companies.

Sources and further reading

• BSEE: Safety and Environmental Management Systems (SEMS)
• eCFR 30 CFR 250 Subpart S: SEMS on the Outer Continental Shelf