TRB Special Report 309: Evaluating the Effectiveness of Offshore Safety and Environmental Management Systems (2012) / Chapter Skim
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6 Conclusions and Recommended Approach
6 Conclusions and Recommended Approach
Pages 109-125
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From page 109... ...
To assist the agency in this endeavor, the Committee on the Effectiveness of Safety and Environmental Management Systems for Outer Continental Shelf Oil and Gas Operations (the committee) drew on the information obtained from presentations it received, site visits, published regulations, notices of proposed rulemaking, recommended practices, and previously published reports to develop the conclusions and recommended approach presented in this chapter.
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From page 110... ...
If it does not actually drive the actions that people take, then it is only theoretical. Merely following a strict interpretation of a minimal SEMS program will not guarantee safe operations offshore.
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From page 111... ...
Because of the diversity, complexity, and evolving nature of offshore oil and gas operations and the comprehensive nature of a fully implemented SEMS program, no single approach to inspections and audits will be sufficient to ensure a successful SEMS program. Both occupational safety and process, or system, safety need to be verified.
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From page 112... ...
a. A properly conducted, truly independent internal audit is potentially more effective than an independent third-party audit, as it reinforces ownership of the safety culture.
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From page 113... ...
Almost by definition, a properly motivated and conducted internal safety audit requires buy-in from management; however, BSEE is responsible for ensuring that these internal audits are properly motivated and conducted. When resources do not permit an organization to conduct effective internal audits, third parties will need to be used.
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From page 114... ...
RECoMMEndEd AppRoACh BsEE should establish a holistic combination of methods necessary to ensure the effectiveness and continuous improvement of sEMs programs. BsEE should establish a system that employs a combination of compliance inspections, audits, key performance indicators (Kpis)
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From page 115... ...
BSEE inspectors have been trained to measure compliance with a standard or prescriptive checklist and without further training are not equipped to measure the effectiveness of individual SEMS programs. It may not be practical to expect the current BSEE inspection force to make subjective decisions as to whether a SEMS program is working correctly so that it meets the intent of the SEMS regulation and helps create a culture of safety.
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From page 116... ...
Although it may be difficult for BSEE inspectors to identify operators in marginal compliance when it comes to assessing the adequacy of a SEMS program, it is not unreasonable to expect them to make overall observations, which, in turn, could help focus BSEE-initiated SEMS audits. During presentations and site visits1 the committee was told that, in some cases, BSEE inspectors visiting an offshore installation might be able to spot problems inherent in an operator's safety culture by noticing obvious safety issues such as loose handrails, corroded walkways, or staff not wearing the appropriate personal protective gear.
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From page 117... ...
The agency should plan its budget recognizing that per dollar spent, the safety value of ensuring that high-quality inspectors and auditors are recruited and appropriately compensated and that critical data are collected, stored, and analyzed is greater than maintaining a completely independent transportation capability. Allowing overnight stays would increase the time BSEE staff would be able to spend interacting with the operating crew.
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From page 118... ...
The audit scheme adopted by BsEE should have the following characteristics: operator ownership, audit team independence, training and accreditation of auditors, access to top levels of management and audit reports, a definition of required audit frequency, and a scheme for quality assurance of audits. BSEE will also need to audit operator audit reports and have personnel capable of carrying out these tasks effectively.
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From page 119... ...
These operators should be able to use third-party auditors. if an independent third party must be used, at least one member of the audit team should be from the operator's organization, and that person should not be directly involved in the day-to-day operation being audited.
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From page 120... ...
In no instance should the audit team include as a member someone who was recently assigned to the offshore facility being audited. Training and Accreditation of Auditors Audit team members should be trained to conduct audits and should be accredited by a method prescribed by BSEE.3 General qualifications for SEMS auditors are described in more detail in Chapter 5.
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From page 121... ...
Doing so would bring in an element of the peer-review–peerassist method for assessing effectiveness that is described in Chapter 3 and would further involve the industry as a whole in taking ownership of the development of a culture of safety. Such a charge from BSEE to COS would be consistent with the following elements of the COS operating basis as presented to the committee:4 • Compiling and analyzing key industry metrics, • Sponsoring functions to facilitate sharing and learning, • Identifying and promoting opportunities for the industry to continu ously improve, • Interfacing with industry leaders to ensure leadership and system deficiencies are recognized and addressed promptly, and • Communicating with government and external stakeholders.
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From page 122... ...
Under 30 CFR 250, Subpart S, as it currently stands, BSEE accomplishes this task by requiring that operators submit their audit plans before conducting audits, submit the qualifications of audit team members and third-party audit companies, and submit the results of the audits once they have been completed. The assumption is
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From page 123... ...
Personnel for Auditing BsEE should hire or train a sufficient number of auditors, including qualified audit team leaders and an adequate number of staff for analyzing audit reports effectively and auditing the accreditation system that the agency puts in place. Key performance indicators Specific KPIs associated with SEMS effectiveness are difficult to define and need further study and evaluation by both the industry and BSEE.
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From page 124... ...
Whistleblower program PSA Norway, the Occupational Safety and Health Administration, and other organizations have found that programs that allow personnel to anonymously report possible violations directly to the regulator are helpful in identifying possible issues that may not be found by other means. The SEMS II notice of proposed rulemaking (BOEMRE 2011a)
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From page 125... ...
Savings from any increased use of operator transportation and more efficient time offshore derived from operator-furnished accommodations could potentially be reprogrammed for the agency's enhanced inspection and SEMS audit programs and other related activities required by these recommendations.
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