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November 2011

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Service Spotlight

Deadline: November 15, 2011
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Remember that phrase - ready or not, here I come? It always seemed as though time accelerated whenever the Seeker would shout those words and the Hiders would scramble. Seconds before, it felt like there was plenty of time to find a safe hiding place. Now it's happened with SEMS implementation and compliance.

As the voluntary compliance era of API RP75 gives way to the mandatory compliance era of the new 30CFR250 Safety and Environmental Management System (SEMS) rule on November 15, companies are finding themselves in various states of readiness. For many OCS operators, SEMS will be a continuation of their current management system practices adopted under API RP75 that may only require a few enhancements to align with the new rule. For others - those who are only now starting to know what SEMS stands for, and those who have begun developing but have not completed their programs - understanding the best path forward can be a much more challenging and even daunting task.

First Things First.

Whoever said that even a journey of a thousand miles begins with the first step must have faced a similar challenge to that of implementing a SEMS compliant management system. Of course, knowing where you stand in relation to the new rule can bring clarity to help prioritize actions and efforts. Many organizations are sending representatives to the range of SEMS implementation training courses being offered in Houston and around the country by a range of consultants and professional services firms. This is an excellent way to be sure your team is on the same page in terms of their knowledge and understanding of what's required.

From there, determining your status on API RP75 elements will make sure that your program meets the foundational requirement of SEMS—that is, all RP75 elements are now a "must," not just a "should." Then you can begin to prioritize the additional requirements contained in SEMS, but not included in RP75 including:


Have a Plan.

While this might seem obvious, a well thought out and executed plan is a critical element for achieving, not just compliance, but more importantly, ongoing SEMS performance. Here is a general implementation plan outline to get you started.

  1. Outline SEMS-covered situations
  2. Determine current SEMS-related activities
  3. Determine contractor SEMS status
  4. Conduct a gap analysis against SEMS/RP 75
  5. Develop an implementation plan
  6. Execute and monitor the plan
  7. Stay in touch with industry activities
  8. Stay in touch with regulatory activities
  9. Monitor SEMS performance and make improvements


Do It.

At the end of the day, many of the SEMS requirements are now considered standard industry practices for most operators. The new rule will however require a sharpening of the pencil for an increased emphasis on monitoring program performance and incorporating lessons to maintain continuous improvement.

Pay Attention to SEMS 2.

BOEMRE (currently BOEM and BSSE as of October 1, 2011) published a proposed revision to the SEMS regulation (SEMS 2) on Wednesday September 14, 2011.


Even though it will take some months for the comment period to expire before these changes become final, a prudent operator will keep these new requirements in mind it completes its SEMS implementation and compliance activities.

Tips and Advice.

As we approach the November 15 deadline and move into the requirements for plan submission and audits, keep the following in mind.

  1. Make sure you understand the SEMS and SEMS 2 requirements
  2. Monitor BOEMRE developments - on October 1, BOEMRE splits into two parts - BOEM will manage and BSSE will enforce.
  3. Participate in industry activities - download all Center for Offshore Safety, OOC and IADC tools and use them.
  4. What you do in the next few months is determined by: (1) who you are—leasee/operator, contractor, or service provider and (2) the condition of your RP 75-like programs/activities.
  5. If you are nearly complete with SEMS implementation, consider doing a "GAP-check" review. If you still have a lot of work to do, prioritize those tasks to:
    • Execute the "easy to get done work" first to minimize noncompliance issues if BSSE were to inspect or audit your facility soon after November 15
    • Start evaluating your contractors for their part in SEMS compliance
    • Continue to work on the longer lead items (mechanical integrity); establish a plan and work the plan so you can show progress if BSSE were to visit you
  6. Think about when you want to have your third-party audit completed. Prepare a draft audit plan, even if you are not yet ready to submit it to BSSE. Use this plan and timeline to help drive completion of SEMS compliance activities.
  7. Update your 2012 budget to reflect additional/ongoing headcount/outside services needed to complete SEMS initial compliance and maintain ongoing compliance.


And... Be Safe.

Contact ABS Consulting for all your SEMS training and implementation needs. Register today for our courses.

SEMS Compliance (30 CFR 250)
November 15, 2011 | New Orleans, LA
January 23, 2012 | Kenner, LA

SEMS Compliance and Implementation (30 CFR 250)
November 15-17, 2011 | New Orleans, LA
January 23, 2012 | Kenner, LA

SEMS Compliance and Auditing
December 7-8, 2011 | Houston, TX
January 26-27, 2012 | Kenner, LA

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Project Profile

Integrated Management of Marine Engineering Activities for the Petrobras Floating Units (GIEN)

Since June 2002, ABS Consulting has been providing support for activities related to 19 Petrobras floating offshore units (FPSOs, semi-submersibles and jackups); 13 of which are production units and the remaining six are drilling units. ABS Consulting continues to provide the following services for this project: updating of drawings and technical files, development of numerical models (for structure, stability, hydro-dynamics and mooring), emergency rapid response, class maintenance support, management of technical aspects of platform modifications, engineering services, the production of new manuals and drawings and training.

Industry News

Anticipated SEMS 2 Proposed Changes Published

BOEMRE published a proposed revision to the SEMS regulation (SEMS 2) on Wednesday September 14, 2011. Comments are due back to them within 60 days.



On October 1, 2011, the Bureau of Ocean Energy Management, Regulation, and Enforcement will subdivide into the Bureau for Ocean Energy Management and the Bureau for Safety and Environmental Enforcement. Secretary of the Interior Ken Salazar named current Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) Director Michael R. Bromwich to lead the newly formed Bureau of Safety and Environmental Enforcement (BSEE) and current BOEMRE Senior Advisor Tommy P. Beaudreau to lead the newly formed Bureau of Ocean Energy Management (BOEM). BSEE will be responsible for inspections, enforcement, and safety of offshore oil and gas operations. Its functions will include the development and enforcement of safety and environmental regulations, research, inspections, offshore regulatory programs, oil spill response and newly formed training and environmental compliance programs.

More information on BOEMRE's reorganization can be found on the BOEMRE Web site.

Bureau of Safety and Environmental Enforcement (BSEE) Conducts SEMS Auditor Training

After reviewing 11 bidders, BSEE has selected ABS Consulting to provide an initial five-day training course to 30 of its offshore inspection workforce on how to evaluate and conduct audits under its Safety and Environmental Management System (SEMS) regulation (30 CFR 250). This past October, three ABS Consulting instructors provided a workshop-oriented course in New Orleans on how to use industry best auditing practices to evaluate compliance of offshore leaseholders, operators, drillers and support contractors with its SEMS regulation, which has a November 15, 2011 compliance deadline. This course, customized from ABS Consulting's industry-available SEMS auditing course, will make heavy use of mock audit exercises to give BSEE inspectors experience on how to collect, evaluate and judge compliance evidence involving records, work and physical equipment observations and interviews.

Center for Offshore Safety Gears to Achieve Operational Excellence

In March of this year, the Board of Directors of the American Petroleum Institute (API) approved the formation of the Center for Offshore Safety. Based in Houston, the Center is open to all companies that operate in deep water exploration and production with membership mandatory for API members. The focus of the center will be based on API's Recommended Practice 75, covering safety and environmental management systems, which was recently incorporated into federal regulations by BSEE.




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