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Abstract
In October 2011 the United States Bureau of Ocean Energy Management, Regulation
and Enforcement (BOEMRE) introduced its Safety and Environmental Management
System (SEMS) rule. It became effective November 15th 2010; companies operating
on the Outer Continental Shelf (OCS) under the jurisdiction of BOEMRE must be
in compliance with its requirements by November 15th 2011. The rule is based on
the Safety and Environmental Program (SEMP), which is part of the API (American
Petroleum Institute) Recommended Practice (RP) 75 (API 2004). RP 75 was first
published in 1994; the most recent edition is from the year 2004.
The SEMS rule is lengthy and its requirements are demanding. Not only has
BOEMRE incorporated SEMP into law, the agency has added many additional
requirements, some of which are quite substantial. (Hence, the statement “SEMS
is SEMP” is somewhat misleading — there is a lot more in SEMS than there is in
SEMP.) The timing of the rule is particularly demanding — particularly for
those companies and facilities that do not currently have an up to date SEMP in
place.
The manner in which the new rule will be enforced is also important. It is
likely that BOEMRE will be considerably more assertive in enforcing rules and
standards than was its predecessor, the Minerals Management Service (MMS). For
example, although the moratorium over new deepwater drilling that was put in
place following the Deepwater Horizon event has been lifted, the agency has
continued to make it very difficult for companies to actually obtain
permits.
This paper provides a brief historical background as to how SEMS came to be. It
goes on to discuss the requirements of the rule, and then provides some
guidance as to how its requirements can be addressed in an expedient and
defensible manner, particularly by those companies who do not already have a
complete SEMP in place.
Finally, it should be noted that, when the original Abstract for this paper was
being written, the SEMS rule had not been promulgated. Some of the assumptions
made at that time — such as a requirement for Production Safety Cases — did not
materialize. It is likely that the SEMS rule, along with some of its associated
standards, will change some more over the course of 2011 and 2012. Therefore,
it is very important that anyone who is implementing or running a SEMS program
check to see if the rule has been updated, or if any material changes have been
made to the pertinent API standards.
Historical Background
The development of Formal Safety Management systems for offshore facilities can
be said to have started with the Piper Alpha catastrophe that occurred in 1988.
Of course, companies working offshore had had safety programs before that time,
but Piper Alpha is often viewed as being the starting point for the development
of formal Safety Management Systems for offshore operations — world wide. This
development is illustrated in Figure 1.
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