TRB Special Report 309: Evaluating the Effectiveness of Offshore Safety and Environmental Management Systems (2012) / Chapter Skim
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4 Existing Approaches for Assessing Safety Management Systems
4 Existing Approaches for Assessing Safety Management Systems
Pages 63-91
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From page 63... ...
offshore oil and gas industry is discussed. The Committee on the Effectiveness of Safety and Environmental Management Systems for Outer Continental Shelf Oil and Gas Operations (the committee)
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From page 64... ...
Because of this, USCG marine inspectors will, in the course of routine material and human element inspections, provide a means of measuring compliance with the ISM Code. Confirmation of compliance can take several forms, the most basic of which is simply to verify that the vessel has a valid ISM Code Safety Management Certificate and a copy of the company's Document of Compliance Certificate.
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From page 65... ...
Failure to submit corrective action reports is noted and, depending on the severity and number of instances, is reported to the organization that issued the Safety Management Cer tificate. When these failures are found, the representative of the autho rized organization acting on behalf of the United States must provide a report, orally or in writing, to the cognizant local officer in charge, marine inspection.
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From page 66... ...
U.S. occupational Safety and Health administration Process safety management (PSM)
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From page 67... ...
Because PSM is a performance manage ment standard, it requires employers to identify the codes and standards they use with respect to equipment and to document that they have complied with recognized and generally accepted good engineering practices for the design, inspection, and testing of their equipment. For offshore oil and gas operations, SEMS likewise references API RP 75, Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities (API 2004)
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From page 68... ...
. There are TABLE 4-1 Comparison of SEMS Elements with OSHA PSM Elements Similar OSHA PSM Element SEMS Element (CFR reference)
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From page 69... ...
Program quality verification was resource intensive, although relatively few cita tions were issued, and was too broadly focused. It did not focus the compliance safety and health officers on specific issues for the many types of facilities and processes covered by PSM (in contrast, SEMS is generally limited to offshore oil, gas, and sulfur operations)
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From page 70... ...
This is partly because of the large-scale refining and chemical facilities and operations to which PSM applies, as it is easier to identify deficiencies when there is a focus on specific items to evaluate. OSHA has also increased PSM training for compliance safety and health officers in order to provide a more effective workforce.
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Mine Safety and Health administration MSHA was created in the U.S. Department of Labor in 1977 with the passage of the Federal Mine Health and Safety Act of 1977 (the 1977 Mine Act)
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-- so that NIOSH and other interested parties (including consultants, universities, and the National Safety Council) can access and analyze MSHA data in the course of researching and advancing health and safety experiences in the mining industry.
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From page 73... ...
MSHA is still gathering data to determine what actions the agency might take, including implementation of specific regulations governing safety and health management programs. For example, to gather information on existing model programs for best practices for safety and health management programs, MSHA held a public meeting on November 10, 2011, in Birmingham, Alabama, in conjunction with the Sixth Annual Southeastern Mining Safety and Health Conference.
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From page 74... ...
CSLC believes that a hardwareoriented inspection or audit program does not address the SMS, human factors, or safety culture, and the commission saw the need for these new types of audits more than a decade ago. CSLC has observed steady improvement in safety management performance and culture using the SAMS process and attributes these improvements to working with operators to increase their compliance rather than punishing them with fines and shut-ins for areas that may need improvement.
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From page 75... ...
As a safer culture develops, CSLC inspectors have noted that operator staff who have participated in CSLC's behavioral safety observation programs appear to take more pride in their work and are willing to describe how their programs have evolved and improved.5 In CSLC's view, these are some of the elements that have helped them be successful where other regulatory, corporate, and even third-party paperwork audits have failed.6 Verified documentation does not equate to a true implementation of a positive safety culture, but working closely with operator staff appears to do so.7 inteRnational RegUlatoRy oRganizationS UK Health and Safety executive The current UK offshore regulatory goal-setting regime was born out of a public inquiry into the Piper Alpha explosion in 1988. The goal-setting legislation replaced older prescriptive legislation, and HSE replaced the UK Department of Energy as regulator.
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From page 76... ...
-- both referred to as "duty holders" -- to submit a safety case to HSE for assessment and acceptance prior to operation of an installation. The Safety Case Regulations 2007 require several specific items to demonstrate that the management system is adequate: • Compliance with the relevant statutory provisions with respect to matters within the management system's control; • Satisfactory management arrangements with contractors and subcon tractors; • Established adequate arrangements for audits and for making reports thereof; • Identification of all hazards with the potential to cause a major acci dent; and • Evaluation of all major risks and implementation, or plans for imple mentation, of measures to control those risks to ensure compliance with the relevant statutory provisions.
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From page 77... ...
; and speaking to onshore and offshore duty holder managers and members of the offshore workforce to seek evidence of their understanding of the management system and its application to specific work activities or operations and practices. On occasion, HSE inspectors formally record interviews as formal statements when HSE is undertaking an investigation or anticipating a formal enforcement action.
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From page 78... ...
Failure of a duty holder to comply with a notice is a prosecutable offense. The Offshore Division serves about 35 to 50 improvement notices and two to three prohibition notices each year.
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From page 79... ...
PSA takes a holistic approach to the meaning of safe operations and extends the concept of safety to include protection of human life, health, and welfare; the natural environment; financial investment; and operational regularity. PSA currently regulates more than 40 operating companies with 70 offshore production facilities, two onshore facilities, 14,000 km of pipelines, and about 30 floating and 12 platform drilling rigs on the Norwegian Continental Shelf (Norwegian Petroleum Directorate 2011, p.
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From page 80... ...
At one point, regulations required quantitative calculation of the maximum acceptable risk that an accident would occur and specified that it should not be greater than a statistical probability of 1 in 10,000; however, experience with this approach, including several blowouts and several high-profile tragedies -- most notably the loss of 123 lives on the Alexander L Kielland -- was not as desired.12 With quantitative risk calculation, it was found that discussions on the risk requirements for approving new developments on the Norwegian Continental Shelf quickly became pure number-crunching exercises.
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From page 81... ...
In the context of PSA, supervision is directed at the operator's administrative management system, which the companies actually use to ensure acceptable operation. PSA works with individual operators with the intention of helping to make them more successful, but also works with the industry by chairing an industry board that consists of representatives from employers' representatives (operators, manufacturers, and shipping associations)
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From page 82... ...
Detailed audit guidelines are designed for each audit, and each audit team is led by a certified audit team leader. Audit team membership is driven by the competencies needed to perform the task.
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From page 83... ...
. The RNNP process was initiated in 1999–2000 to develop and apply a tool for measur ing trends in risk level in Norwegian petroleum activity.
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. Since 1984, companies have been required to provide information via the DDRS database on all drilling on the Norwegian Continental Shelf.
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It is PSA's responsibility to define the terms for responsible operation of the petroleum industry and to check that companies are working on prevention and on continuous improvement of safety levels. Because PSA views criminal law as the province of the police (PSA Norway 2010)
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" and to what changes should be made in how PSA manages safety. The formal conclusion was that there was no reason to revise the system and no need for major overhaul, but that there were issues that the industry needed to address in light of the Macondo accident, including lack of understanding of risks, lack of supervision, and failure to follow procedures.
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From page 87... ...
recommended that a self-policing safety institute be set up by and for the companies working offshore. This proposal recognizes that although government regulators are not likely to achieve the technical safety expertise of private industry, the nation must have a high level of assurance that operations on the Outer Continental Shelf (OCS)
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From page 88... ...
The process will encompass audit protocols with metrics for the new SEMS regulation, third-party audits, and accreditation and certification of audit service providers. A major objective of COS is to have BSEE embrace the center's accredited third-party audits as an effective means of complying with regulations and improving industry performance.
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From page 89... ...
Nevertheless, it was probably inevitable that the initial offshore safety organization would be set up by API. API's standards and certification unit, which is the nonadvocacy part of the organization, does so much technical work that it would probably have been difficult to get support to create a parallel and completely independent institute with enough leadership commitment in time and money.
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From page 90... ...
Even before the Macondo well blowout, MMS had undertaken efforts to change regulations for the offshore oil and gas industry, but the blow For example, "Have written operating procedures been developed and implemented which include 27 the job title and reporting relationship of the person(s) responsible for each of the facility's operat ing areas?
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From page 91... ...
71 Existing Approaches for Assessing Safety Management Systems out was the catalyst for swift and sweeping regulatory changes, including the restructuring of MMS.28 In response to the Macondo accident and these regulatory changes, the offshore oil and gas industry established COS, whose mission is to promote the highest level of safety through effective leadership, communication, teamwork, use of SMSs, and process auditing and certification. Although still in the process of being established, COS has the potential to be of great value to the industry.
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