Safety & Environmental Management System Auditing. M.J. Hazzan AcuTech Consulting Group Philadelphia, PA

Transcription

1 Safety & Environmental Management System Auditing M.J. Hazzan AcuTech Consulting Group Philadelphia, PA

2 Background Process Safety Portion: On April 20, 2010 Deepwater Horizon, approx 50 mi south off Louisiana coast experienced an uncontrolled release of hydrocarbons that sparked an explosion resulting in a fire that destroyed the MODU and resulted in 11 fatalities. Environmental portion: This event also triggered a release of crude oil from the Macondo well serviced by Deepwater Horizon that could not be isolated for several months, resulting in a Spill of National Significance (SONS) into the Gulf of Mexico. SEMS deals primarily with the process safety aspects of this event.

3 Prior to Deepwater Horizon, process safety was a voluntary activity on the OCS. SEMP had been published by API (API RP-75) in May 1993, was affirmed by MMS, but not adopted as a regulation.

4 Background Although the phrases safety and environmental management system or safety and environmental program do not include process safety they contain elements that are intended to prevent large scale events such as fires, explosions, and spills/releases that can have an effect on the safety of the facility and on the environment of the OCS. SEMS introduces process safety management to facilities on the OCS via federal regulation. PSM has been a regulation onshore since May 1992.

5 SEMS Regulation 30 CFR 250 General (The requirement that the SEMS policies, practices, and procedures be written.) Safety and Environmental Information Hazards Analysis Management of Change Operating Procedures Safe Work Practices Training Assurance of Quality and Mechanical Integrity (MI) of Critical Equipment Pre-startup Review Emergency Response and Control Investigation of Incidents Audit of Safety and Environmental Management Program Elements Records and Documentation This program introduces process safety management concepts and elements to offshore oil and gas operations in the U.S.

6 SEMS Audit Requirements Operator can use either independent 3 rd party (I3P) or designated and qualified personnel (Note: SEMS II would require all I3P). Comprehensive audit all 13 elements. Audit plan required (API RP 75 section 12.1 thru 12.4). Submit plan to BSEE 30 days before audit. BSEE may attend SEMS audits. Submit audit findings/conclusions 30 days after audit completion date: Outline the results of audit Deficiencies identified Correction plan

7 SEMS Audit Requirements Correction plan must identify: Schedule to correct deficiencies - BSEE notifies lessee w/in 14 days. Person responsible with job title. BSEE may do a follow-up to verify corrective actions have been undertaken.

8 BSEE Directed Audits Lessee must hire I3P to conduct audit: I3P must meet requirements listed in Subpart S. I3P submits findings to BSEE within 30 days of audit. Lessee responsible for all costs. If BSEE conducts audit in lieu of I3P: BSEE will provide lessee a report w/in 30 days of audit. Lessee must submit corrective action plan within 30 days of audit completion.

9 Plan-Do-Check-Act Model A PDCA management system is founded upon the notion that continuous improvement is a cardinal principle.

10 Management Systems & Audits Auditing is the Check part of P-D-C-A model. The check portion is the evaluation of what occurs during the do step. Auditing is often a governance activity within an organization or they are regulatory requirements, e.g., SEMS. Which means they are mandatory. Which means there will be some findings. Which means people don t particularly like them.

11 Management Systems & Audits But audits are also a chance to learn something about the program being audited. If the audit team does a good job. If the audited facility is culturally prepared to learn as much as they can. Don t let SEMS audits evolve into check-thebox activities.

12 SEMS Auditing SEMS auditing is the systematic review of these management systems to verify the suitability of these systems and their effective, consistent implementation. SEMS audits are intended to determine whether management systems are in place and functioning properly to ensure that: the safety and health of employees, communities, customers, are being properly protected. and the environment is being protected. These audits are an important control mechanism within the overall management of SEMS. In addition, these audits can provide other benefits such as improved operability and increased safety awareness.

13 What SEMS is not: SEMS Auditing Focus on the programmatic aspects of PSM programs, not on identifying the equipment/process hazards. Verify or replicate the engineering activities that took place to design the equipment and processes.

14 In 2011 CCPS published the 2 nd edition of the PSM Auditing Guidelines book Significant changes: Greatly expanded guidance on establishing audit PSM programs. Greatly expanded guidance on planning and executing PSM audits. Guidance on PSM documentation. Specific compliance and non-mandatory auditor guidance for each RBPS element. PSM audit dilemmas appendix. PSM audits in M&As appendix. International PSM audit appendix. Other electronic appendices with audit report, audit plan, and other work product templates.

15 SEMS Auditing Guidance Center for Offshore Safety (COS) is about to publish the SEMS version of the CCPS PSM auditing book. Started with 187 question COS SEMS audit checklist. Incorporates Background Information for most questions. Incorporates the same type of guidance as CCPS book used the CCPS as a source for much of the guidance. Will be on COS website for download.

16 Date COS SEMS RP 75 Audit Protocol-Checklist 23 January 2012 Organization Facility Auditors RP 75 1 General Doc. ID: COS-1-01 Revision: 1.0 Effective Date: Q ID Question Reference 1 Has a safety and environmental management system (SEMS) been (a) implemented? Y N N/A (b) maintained? Y N N/A RP Finding (C/N/NA) Observations Auditor Guidance: Note that this question may not be able to be answered in its entirety until the following questions in Section 1 are completed. Also note that Section 1 in its entirety may not be able to be answered until the other sections are completed. Check if there is a policy, plan, or procedure in place that describes the operator s SEMS program. Interview a spectrum of personnel, not just the safety/sems Manager or Coordinator, to check if the policy, plan, or procedure has actually been implemented as written. This is a high level inquiry for the program overall the details of implementation of each element of the SEMS program will be examined in other audit questions. 2 Has Form MMS 131 been submitted to BOEMRE on an annual basis beginning March 31, 2011? (b) Auditor Guidance: Check if Form MMS 131 has been submitted on an annual basis beginning March 31, The Safety Manager, Regulatory Manager, SEMS Coordinator, or other person with assigned responsibilities for the SEMS program should have custody of this record or know where it is stored. 3 Has management ensured that goals and performance measures are established for the SEMS? Auditor Guidance: Check if the SEMS program policy, plan, or procedure, or a referenced or support document defines the goals of the SEMS program. Check if the SEMS program policy, plan, or procedure, or a referenced or support document defines SEMS metrics or other measures of program effectiveness. 4 Do the safety and environmental objectives, goals and performance measures address the following: (a) a commitment to continuous improvement? Y N N/A (b) responsibilities for achieving objectives and goals at each relevant function and level of the organization? Y N N/A (c) specific means and timeframe by which the goals and objectives are to be achieved? Y N N/A (d) performance measures established to gauge safety and environmental performance? Y N N/A RP (b) (a) RP

17 SEMS Auditing The Background Information explains and interprets the questions. The Auditor Guidance for each questions directs the auditor to: What persons to interview and what the topic of the interviews should be/what information is sought during the interviews. What records and documents to review and what to look for in them. What field observations to make and what to observe.

18 Performance Indicators (Leading & lagging) Maintenance Checks/test Calibration Loop Checks Simulation Audits MOC/ECR Swiss Cheese Model Initiating Events Training, procedures, design IGNITION CONTROL BLOWDOWN & RELIEF SYSTEM FIRE & GAS DETECTION EMERGENCY SHUTDOWN ACTIVE FIRE PROTECTION HAC Static Electric Audits PASSIVE FIRE PROTECTION EXPLOSION Prevention barriers Loop checks for BD Audits/Inspection CFIs on Relief Valves Loop Checks Detector Calibrations Audits MOC/ECR CFT on ESDV Loop Checks Audits/Inspection Mitigation barriers Auditing is one of these procedures

19 SEMS Audits & Metrics SEMS regulation does not formally require metrics. To accomplish the Check and Act parts of P-D-C-A model need measurement systems and then mgmt reviews of what has been measured. Key SEMS metrics would be an effective way to periodically measure program effectiveness: Leading Metrics Lagging Metrics

20 SEMS Audits & Metrics Examples of possible SEMS leading metrics: # ITPM tasks overdue/#itpm tasks planned # deficiencies open and their aging # SEMS action items open and overdue/#sems actions open Examples of possible SEMS lagging metrics: # SEMS incidents # rate of SEMS incidents

21 SEMS Audits & Metrics Audits are also an effective measurement system & are one of the ways to collect metrics data. Typical metrics collection frequencies: weekly, monthly, quarterly Typical audit frequencies: annual or greater Need mgmt reviews of metrics and audit results to complete the P-D-C-A model loop.

22 Swiss Cheese Model - Metrics Audits are one on these barriers

23 Business Case for PSM/SEMS Corporate Responsibility: Protects reputation and shareholder value Creates lower risk perception by investors Increases value of corporate image and brand Reduces concerns within the local community Engages employees - morale, loyalty, retention Helps assure insurance coverage at attractive rates Enhances lenders confidence Helps regulators understand your facility Source: CCPS 23

24 Business Case for PSM/SEMS Business Flexibility: Proves your worthiness to hold a license to operate Strengthens and maintains good relationships with the local community Helps investors feel confident in your ability to grow and earn profits Helps you attract and retain high performance staff Helps you obtain approval for expansion permits or new facilities more quickly Strengthens and maintains good relationships with regulators Source: CCPS

25 Business Case for PSM/SEMS Risk Reduction: Save lives and reduce injuries Reduce property damage costs Reduce business interruptions Protect market share Reduce litigation costs Reduce regulatory penalties from accidents Reduce regulatory attention Source: CCPS

26 Business Case for PSM/SEMS Balance the cost of a program like SEMS with a Spill of National Significant (SONS).

27 ISO Guidelines for Quality and/or Environmental Management Systems Auditing 27

28 ISO Best Practices Audit Principles Ethical Conduct Trust, integrity, confidentiality and discretion Fair Representation The obligation to report truthfully and accurately Due Professional Care The application of diligence and judgment Independence Impartial and objective Evidence Based Approach 28

29 Illustration of the Process Flow for Management of an Audit Program Follows Plan, Do, Act, Check methodology Figure 1 from ISO 19001:

30 Overview of Typical Audit Activities Figure 2 from ISO 19001:2002 Confidential Business Information 30

31 Concept of Competency Figure 4 from ISO 19001:

32 SEMS Audit Guidance Both the CCPS Auditing book and the SEMS follow the broad guidance in ISO Auditor competence: Not defined in SEMS regulation explicitly but BSEE will review them and can reject auditor s qualifications. COS currently working on SEMS auditor qualification certification.

33 Questions?