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Photo Credit BSEE Alaska Region

“Safety at all levels, at all times”. BSEE Update John Cushing Senior Technical Advisor Office of Offshore Regulatory Programs NOSAC Fall Meeting Houston, TX November 8, 2012. Photo Credit BSEE Alaska Region. BSEE Update. Regulatory Goals Regulatory Update SEMS Highlights Conclusion.

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Photo Credit BSEE Alaska Region

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  1. “Safety at all levels, at all times” BSEE Update John Cushing Senior Technical Advisor Office of Offshore Regulatory Programs NOSAC Fall Meeting Houston, TX November 8, 2012 Photo Credit BSEE Alaska Region

  2. BSEE Update • Regulatory Goals • Regulatory Update • SEMS Highlights • Conclusion

  3. Beyond Compliance to Offshore Excellence Strategies: Blend prescriptive and performance-based approaches. Compel safety, emergency preparedness, environmental responsibility, and appropriate development and conservation. Build a safety culture throughout the offshore industry. BSEE – Regulatory Goals “Safety at all levels, at all times”

  4. BSEE - Regulatory Update Regulatory Priorities: • Drilling Safety Rule:Final Rule published 8/11/12,effective date is 10/22/12 • SEMS II:Currently in BSEE final clearance • Production Safety Systems:Currently in BSEE final clearance • Blowout Preventer Rule:Currently under development in Regs & Stds Branch Photo Credit BSEE Alaska Region

  5. Notice to Lessees (NTLs) NTL website… www.bsee.gov/Regulations-and-Guidance/Notices-to-Lessees-and-Operators.aspx

  6. SEMS - Overview SEMS is a comprehensive, performance-based system • Designed to reduce human error and organizational failure • Based on the framework of API RP 75 • Required under 30 CFR 250.1900 (Subpart S) • Emphasizes Hazards Analysis, Mechanical Integrity, Operating Procedures, and Management of Change • Operator/Contractor interface is crucial

  7. SEMS - Highlights • Operators must implement their SEMS program by 15 Nov 2011, and complete 1st audit by 15 Nov 2013. • Applies to: • All operations - drilling, production, workover, completions, DOI regulated pipelines • All structures - fixed, floaters, MODUs • Program approval notrequired • 13 elements, plus other provisions, per 30 CFR 250 Subpart S • Job Safety Analysis • Independent 3rd Party audits (optional) • Submission of audit plans • Contractor interface

  8. SEMS – Important Dates Photo Credit BSEE Alaska Region

  9. SEMS - Obligations • Operators must • Document contractor selection criteria – performance evaluations • Ensure that contractors have their own written safe work practices. • Contractors may adopt appropriate sections of Operator’s SEMS program. • Operators and their contractor(s) must document an agreement on appropriate contractor safety and environmental policies and practices before the contractor begins work at their facilities.

  10. SEMS II - Highlights

  11. SEMS - Conclusions • First round of audits underway • BSEE is observing operator conducted audits • Anticipating varying degrees of SEMS implementation • Actively monitoring corrective actions • Interface between contractor and operator is key • Goals - continuous improvement of management systems, empowering employees, and fostering a culture of excellence Don’t delay, audit deadline is November 15, 2013

  12. THANK YOU John Cushing Senior Technical Advisor Office of Offshore Regulatory Programs John.Cushing@bsee.gov (703) 787-1737

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