CHAPTER 15 SAFETY AND ENVIRONMENTAL MANAGEMENT SYSTEMS (SEMS) COMPLIANCE: WHAT TO EXPECT AND HOW TO PREPARE FOR A SEMS AUDIT

• Jurisdiction: United States

Federal Offshore Regulatory Enforcement
(Jan 2016)
CHAPTER 15
SAFETY AND ENVIRONMENTAL MANAGEMENT SYSTEMS (SEMS) COMPLIANCE: WHAT TO EXPECT AND HOW TO PREPARE FOR A SEMS AUDIT

Anton Du Preez
Vice President, Business Development
SEMPCheck
Houston, TX

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ANTON DU PREEZ is Vice-President of Business Development at SEMPCheck Services in Houston, Texas. He holds a doctorate in safety management, as well as advanced degrees in business management and electronic engineering. During an EHS career spanning more than 20 years, he has provided consulting and auditing services in Europe, Africa, and North and South America. He has led more than 50 organizations towards ISO 9000, 14000, and OS 9000 certification and has performed more than a hundred audits of HSE systems. In 2013 he facilitated a workshop with BSEE where the BSEE SEMS audit methodology and protocol was developed. During the summer of 2013, he developed an audit report review process for BSEE. In March 2014, he presented a paper on the utilization of Management of Change analysis as an indicator of HSE system effectiveness at SPE International Conference on HSE in California.

SEMS - Auditing - What did we learn and what should we expect?

A. What are the regulatory requirements regarding Auditing?

a. Performance requirements

The 30 CFR 250 Subpart S requires operators to perform a full system audit at least every three years and report the results to BSEE. Previously the audits could be performed by operator personnel or appointed contractors if the operator could provide evidence that the audit team was qualified. As from July 2015, the regulation requires that audit are performed by an independent accredited service provider. This accreditation can currently only be provided by COS (Center for Offshore Safety). COS has issued accreditation for 4 service providers but are reviewing several more service providers.

b. Report requirements

The 30 CFR 250 Subpart S requires a formal written report to BSEE within 30 days of performance. The report should include a list of corrective actions and a timeline for the implementation of such corrective actions. The regulation does not specify that corrective actions are implemented within a defined timeframe but operators should demonstrate that the implementation focus match the degree of risk exposure addressed by the corrective action. BSEE may require that proof of corrective action implementation is communicated to them...