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SEMS: Expanding the Rules for Marine Operations The rapidly changing offshore regulatory landscape is amply refl ected by the BSEE’s implementation of the fi rst mandatory SEMS rule for oil and gas opera- tors in the OCS. The Bureau Veritas SEMS Audit team explains how. By Lucas Lopez-Videla and Ronald White REGULATORY REVIEW S erious offshore incidents in recent years have com- pelled both the federal government and the oil and gas industry to make mandatory commitments to envi- ronmentally sustainable practices and worker safety. The US Bureau of Safety and Environmental Enforcement (BSEE), for instance, has established Safety and Environmental Management Systems (SEMS) regulations, which com- panies operating oil and gas and sulfur leases in the Outer Continental Shelf (OCS) are legally obligated to meet with regularly audited safety and environmental programs. Early Origins The concept of SEMS was born in response to a 1990 fi nding by the National Research Council’s Marine Board that the standard prescriptive approach to regulating off- shore operations had forced the industry into a compliance mentality. Further, the Marine Board found that this men- tality was not conducive to effectively identifying potential operational risks or developing comprehensive accident mitigation. The Marine Board therefore recommended, and the BSEE concurred, that a more systematic approach was required for managing offshore operations. The fi rst major industry effort to standardize SEMS came from the American Petroleum Institute (API), who devel- oped Recommended Practice (RP) 75 - Development of a Safety and Environmental Management Program for Outer Continen- tal Shelf Operations and Facilities. The API also produced a companion document, RP-14J, for identifying safety hazards on offshore production facilities. The API RP-75 was pub- lished in May 1993 and, in 1994, the BSEE published a No- tice in the Federal Register that recognized implementation of RP-75 as meeting the spirit and intent of SEMS. This rec- ommended practice was updated several times in the follow- ing decade to give greater focus to contract operations such as those on mobile offshore drilling units (a third edition was published in May 2004 and was reaffi rmed in May 2008). May 2014 26 MN MN May14 Layout 18-31.indd 26 4/21/2014 10:36:10 AM
