As a result of the Deepwater Horizon/Macondo incident on April 20, 2010, the Department of the Interior adopted the Safety and Environmental Management Systems (SEMS) regulation (30 CFR 250). This regulatory program, which imposes a process safety management-like program on oil and gas facilities operating on the Outer Continental Shelf (OCS), replaces a voluntary program that had existed since 1993. SEMS includes an audit element that is substantially different from its sister element in PSM-covered facilities onshore. This paper will examine the following aspects of SEMS auditing:
• How process safety on the OCS differs from onshore facilities, where it is well developed and long standing. • Interpretation of the SEMS audit requirements, and the active role of the government in these audits. • Audit guidance published by the new Center for Offshore Safety (COS), which is heavily influenced by the PSM audit guidance published by CCPS in 2011 in Guidelines for Auditing Process Safety Management Systems. The Background for Auditors and Auditor Activities information published in these documents is unique. • Management systems and their effect on SEMS auditing. Several ISO standards will influence SEMS audits even though the SEMS regulations do not refer to them. • Requirements for the training, qualification, and certification of SEMS auditors established by COS. The SEMS regulations do not specify these requirements, however, the offshore industry has adopted them via COS. • The COS concept of independent third party (I3P) auditors and how they will be accredited by COS. • SEMS audits and SEMS metrics. Metrics are not mandatory in the SEMS regulations but audits provide an opportunity to measure the efficacy of SEMS programs. • The business case for SEMS auditing. Beyond the regulatory regulations themselves SEMS audits provide an opportunity to increase the reliability and operability of OCS facilities, which represent an enormous investment for their owners and operators.