About a year ago, the Minerals Management Services (MMS) proposed a new rule that would require operators of oil and gas operations in the US Outer Continental Shelf to develop and implement Safety and Environmental Management System (SEMS).
It is expected that the rule will be promulgated sometime this year.
Based on the proposed SEMS rule docket, SEMS would consist of four elements:
- Hazard Analysis
- Management of Change (MOC)
- Operating Procedures
- Mechanical Integrity
Why the above elements?
The MMS analyzed incident reports and conculded that the contributing causes for majority of these incidents (80%) is one or more of the proposed four elements.
Between 2001-2007, there were 1,443 incidents in the US Outer Continental Shelf waters that resulted in
- 41 fatalities
- 302 injuries
- 10 losses of well control
- 11 collisions
- 476 fires
- 356 pollution events
- 224 events from heavy lifting (crane, hoists, winches, etc.)
Below is a distribution of contributing causes for 85% of the 1,443 US offshore events between 2001-2007.
| SEMS Element | Number of Incidents | % of total 1443 incidents |
|---|---|---|
| Management of Change | 108 | 7.5 |
| Hazard Analysis | 185 | 12.8 |
| Mechanical Integrity | 475 | 32.9 |
| Operating Procedures | 481 | 33.3 |
5 Responses
Very interesting. Thank you for this valuable information.
Based on the root cause analysis I see the rational for selecting these four elements. The usually accepted process safety management programme comprises 16 elements including the 4 selected items. It would be comforting if all offshore (and on-shore) drilling operations had fully implemented and audited process safety management programmes in place.
Very ‘hands-on’ and without useless complications, simple but not simplistic; if these four only were really implemented and followed-up …
Great Post about SEMS.