TRB Special Report 309: Evaluating the Effectiveness of Offshore Safety and Environmental Management Systems (2012) / Chapter Skim
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5 Role of the Bureau of Safety and Environmental Enforcement in Evaluating Safety and Environmental Management Systems Programs
5 Role of the Bureau of Safety and Environmental Enforcement in Evaluating Safety and Environmental Management Systems Programs
Pages 92-108
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From page 92... ...
Outer Continental Shelf (OCS) ."1 In fulfilling this function, the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE, now BSEE)
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From page 93... ...
The regulations articulate the minimum standards necessary for compliance and, in doing so, limit inspectors to being able to require only these minimums. Among its many provisions, the Outer Continental Shelf Lands Act contains several safety-related directives, including one that requires that each facility on the OCS be subject to annual scheduled inspections of all safety equipment designed to prevent or ameliorate blowouts, fires, spillages, or other major accidents.
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From page 94... ...
The executive summary of the Marine Board report states, A final point made by the committee -- and it is a crucial one -- relates to attitudes. In enterprises that are subject to inspection by government or other authorities, the operators of the enterprise often gradually drift to the point of view that the responsibility for safety lies with the government and the inspectors.
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From page 95... ...
The audit that you submit to BSEE must be conducted by either an independent third party or your designated and qualified personnel. The independent third party or your designated and qualified personnel must meet the requirements in § 250.1926.
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From page 96... ...
Operators with multiple installations need only audit a representative sample of 15 percent of the installations. BSEE also reserves the right to conduct audits of its own or to require an operator to have a third party conduct an audit, as specified in 30 CFR 250.1925:
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From page 97... ...
Consideration will need to be given to the various tasks associated with the audit function as well as to the qualifications of the individuals authorized to perform those tasks. Section 250.1926 of the initial SEMS rule describes the required minimum qualifications of the individual or organization conducting the audit and requires BSEE to approve the qualifications of each auditor: § 250.1926 What qualifications must an independent third party or my designated and qualified personnel meet?
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From page 98... ...
These qualifications, which are under consideration for modification in the SEMS II notice of proposed rulemaking (BOEMRE 2011a) , reflect the basic high-level qualifications needed of auditors: • Education and previous experience with SEMS or similar management related programs; • Previous experience with BSEE regulatory requirements and proce dures; and • Educational background and previous experience relevant to under standing and evaluating how the operator's offshore activities, raw materials, production methods and equipment, products, by-products, and business management systems may affect health and safety perfor mance in the workplace.
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From page 99... ...
Numerous existing auditing protocols and qualification requirements are available as examples for BSEE's SEMS auditors. A majority of the organizations with programs similar to SEMS that are discussed in Chapter 4, such as Petroleum Safety Authority Norway, the United Kingdom Health and Safety Executive, and the Occupational Safety and Health Administration, have similar auditing protocols and qualifications, and details can be found in the associated references for each.
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From page 100... ...
Knowledge and skills specific to the safety and environmental aspects of offshore operations include knowledge of the BSEE SEMS standard, including the related science, technology, processes, and terminology, as well as the interface between systems and human activities. education, Work experience, Auditor training, and Audit experience Auditor education, experience, and training should complement each other.
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From page 101... ...
3 is granted by BSI. British Standards can be obtained in PDF or hard copy formats from the BSI online shop: www.bsigroup.com/Shop or by contacting BSI Customer Services for hardcopies only: tel: +44 (0)
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From page 102... ...
25–26) 4 recommends that Auditors should exhibit professional behaviour during the performance of audit activities, including being: – ethical, i.e., fair, truthful, sincere, honest and discreet; – open-minded, i.e., willing to consider alternative ideas or points of view; – diplomatic, i.e., tactful in dealing with people; – observant, i.e., actively observing physical surroundings and activities; – perceptive, i.e., aware of and able to understand situations; – versatile, i.e., able to readily adapt to different situations; – tenacious, i.e., persistent and focused on achieving objectives; – decisive, i.e., able to reach timely conclusions based on logical reasoning and analysis; – self-reliant, i.e., able to act and function independently whilst interacting effectively with others; – [able to act]
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From page 103... ...
5 is granted by BSI. British Standards can be obtained in PDF or hard copy formats from the BSI online shop: www.bsigroup.com/Shop or by contacting BSI Customer Services for hardcopies only: tel: +44 (0)
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From page 104... ...
f) evidence-based approach: the rational method for reaching reliable and reproducible audit conclusions in a systematic audit process Audit evidence should be verifiable.
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From page 105... ...
The COS plan is to certify audit service providers to conduct SEMS audits using a protocol developed by COS that satisfies both BSEE and industry requirements. Because COS may be involved in many SEMS audits, it plans to collect what it learns about best practices associated with the audit process and then share this information with the industry.
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From page 106... ...
Thus, the current role of the operator is to establish a SEMS program and conduct specified internal or third-party audits according to a plan approved by BSEE. BSEE's current role is to either visit facilities themselves or arrange for third parties to do so on behalf of BSEE to inspect for compliance, approve all operator audit plans and individual auditors, review the results of all audits, and issue incident of noncompliance (INC)
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From page 107... ...
A plan of action that shows how operator employees are involved in the implementation of the API's Recommended Practice for Devel opment of a Safety [and] Environmental Management Program for Offshore Operations and Facilities (API RP 75)
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From page 108... ...
. The revisions would prohibit operators from using their own qualified staff to conduct required SEMS audits.
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