Thursday at the Offshore Technology Conference is traditionally the “safety day,” with sessions and panels bringing together regulators as well as industry professionals to talk about the sometimes uneasy interaction between the two in the offshore oil and gas industry.
This year, much of the talk in the morning revolved around audits of Safety and Efficiency Management Systems (SEMS), as dictated by the Bureau of Safety and Environmental Enforcement, part of the US Department of the Interior. While BSEE officials during an early session stressed a learning curve and need to be honest about shortcomings in audits, industry insiders in a later panel expressed some hesitation about the audits and how the findings could be shared.
Doug Morris, chief of offshore regulatory programs for the Department of the Interior, described the origins of the SEMS program, which came after the Deepwater Horizon oil spill in 2010. Initially a voluntary standard known as the Workplace Safety Rule, in June 2013 the SEMS II rule became effective, enhancing the original rule.
Susan Dwarnick, chief of Interior’s offshore safety improvement branch, said that in 2014, at the end of the first cycle of audits, 96% of operators were in compliance. However, “SEMS is not about compliance; it is performance-based,” she said, and shouldn’t be viewed as much as a checklist of things to have or to meet as much as a tool to identifying risks and improving.
“Nobody is 100% perfect,” Dwarnick said, and as such, the focus for the audits moving forward would be for very thorough documentation, implementation and effectiveness. “After all, we’re focusing on the end result of safe and sustainable work environment,” she said.
Stan Kaczmarek, an engineer with the SEMS section, echoed Dwarnick’s view of the audits as a learning experience.
“We really are expecting that nobody’s going to be great, that everyone’s going to have findings of some sort,” he said.
He noted that any kind of pre-audit prep can fall prey to the strategy of drilling employees with scripted answers about what they’re supposed to say, the audit happens, and then the issue falls away until the next audit cycle. Companies and their people shouldn’t be afraid to show what they really are, as opposed to what they think auditors want to hear, he said.
But he did admit that BSEE would be facing a challenge with SEMS moving forward, because if it is a performance-based regulation, it is more difficult to measure performance.
During a later panel coordinated with the Center for Offshore Safety, various operators spoke about how SEMS fits with their own safety systems, including health, safety and environment systems. Among the operators were Shell, Chevron, Statoil, Cobalt and Anadarko, and all detailed their companies’ various safety plans.
Kevin Renfro, general manager of Gulf of Mexico compliance and regulatory affairs at Anadarko, outlined how their framework fit into six steps, from planning and risk management to implementation in the field. He said his view is that industry focus really needs to be on implementation.
“As an industry, where do we think we historically see more problems with our risk management system?” he said.
After the operators’ panel, the floor was opened to questions, and one man asked whether defining problems in an audit had the potential to come back as a threat to a company in the future.
And that is one of the primary problems with the audit process, said Stephen Thurston, VP of Chevron North America E&P Company, who said his company does internal audits that don’t go to BSEE.
“Taken out of context, some of the improvement items in here could be viewed as problematic,” he said. “… You just have to be careful how you write that because that could be taken out of context in the Wall Street Journal.”
Kathy Kanocz, VP of health, safety and environment at Statoil, who also spoke on the operators’ panel, said her company is having discussions with BSEE about freedom of information concerns.
Dwarnick admitted in the morning to mixed feelings when given the task last year to take SEMS regulation and help implement it. She didn’t see herself as a regulator, she said, and had come from the industry.
It will be interesting to see how the SEMS audits progress and whether there would be repercussions of findings that BSEE may not look upon favorably. Will the industry be willing to totally divulge its weak spots to regulators? And if it does, what sort of consequences could companies face in what is supposedly a process of self-discovery and self-improvement?
The industry already takes safety very, very seriously — as evidenced by all the internal safety plans each operator shared during the panel, the hundreds of booths in the exhibit spaces dedicated to safety-enhancing gear and equipment, and the inclusion of these sessions and panels and others like them. But in a world where fallible humans exist, how do you ever prove you’re safe enough? Maybe, as they say, this is about the journey, and not the destination.