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SEMS II Management, Culture and Program Elements


Management's General Responsibilities

Management should ensure that the program elements discussed in API RP 75 and in the SEMS II rule are properly documented and are available at field and office locations, as appropriate for each program element. See BSEE-0131 Performance Measurement Data form.

Management should develop, support, and continually improve the overall success of the SEMS II program by doing the following:

Establish goals, objectives and performance measures, demand accountability for implementation, and provide necessary resources for carrying out an effective SEMS II program. Be sure that the following information is included:

  • a commitment to continuous improvement
  • assigned responsibilities for achieving stated goals and objectives at each level of the company
  • the means and timelines for achieving goals and objectives
  • the means and methods to communicate goals, objectives and performance measures
  • performance measures to evaluate the results

Appoint management representatives who are responsible for establishing, implementing and maintaining an effective SEMS II program.

Designate specific management representatives who are responsible for establishing, implementing, maintaining, and reporting to management on the performance of the SEMS II program.

Management's General Responsibilities (Continued)

Review the SEMS II program at specified intervals and at least annually, to determine if it continues to be suitable, adequate and effective by addressing:

  • the possible need for changes to policy, objectives, and other elements of the program in light of program audit results, changing circumstances
  • the commitment to continual improvement
  • formally document the observations, conclusions and recommendations of that review

Develop and endorse written safety and environmental policies and organizational structure that define responsibilities, authorities, and lines of communication required to implement the SEMS II program.

Use personnel with expertise in:

  • identifying safety hazards
  • environmental impacts
  • optimizing operations
  • developing safe work practices
  • developing training programs, and
  • investigating incidents

Ensure that facilities are designed, constructed, maintained, monitored, and operated in a manner compatible with applicable industry codes, consensus standards, and generally accepted practice as well as in compliance with all applicable governmental regulations.

Ensure that management of safety hazards and environmental impacts is an integral part of the design, construction, maintenance, operation, and monitoring of each facility.

Ensure that suitably trained and qualified personnel are employed to carry out all aspects of the SEMS II program.

Ensure that the SEMS II program is maintained and kept up to date by means of periodic audits to ensure effective performance.

The SEMS II Safety Culture


BSEE director Jim Watson believes an effective SEMS II Safety Culture Policy Statement is at the core of an offshore operations safety culture, at all times, because every offshore operation – no matter when or where it is performed – carries with it some degree of risk.

The following are the nine characteristics of a robust SEMS II safety culture:

  1. Leadership Safety Values and Actions—Leaders demonstrate a commitment to safety in their decisions and behaviors.
  2. Problem Identification and Resolution—Issues potentially impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected commensurate with their significance.
  3. Personal Accountability—All individuals take personal responsibility for safety.
  4. Work Processes—The process of planning and controlling work activities is implemented so that safety is maintained.
  5. Continuous Learning—Opportunities to learn about ways to ensure safety are sought out and implemented.
  6. Environment for Raising Concerns—A safety conscious work environment is maintained where personnel feel free to raise safety concerns without fear of retaliation, intimidation, harassment, or discrimination.
  7. Effective Safety Communication—Communications maintain a focus on safety.
  8. Respectful Work Environment—Trust and respect permeate the organization.
  9. Inquiring Attitude—Individuals avoid complacency and continuously consider and review existing conditions and activities in order to identify discrepancies that might result in error or inappropriate action.

So what do we mean by “safety culture” and how should we measure “safety?” Is it merely the absence of accidents? Is it compliance with regulations? Is it how you approach complex activities? I believe it is how you approach risk. How do you balance risk to the employees and the environment with the need to stay on schedule, to complete the well, or to start production? It goes far beyond management decisions. How do the people approach risk? Are they afraid to speak up when they see something wrong? Will they immediately halt operations if their colleagues are in danger? Or, do they only pay attention to the missing handrail when they see the helicopter with a BSEE inspector approaching their facility? How much risk – to themselves – are they willing to accept? (Brian Salerno, Director, BSEE)

Safety and Environmental Information


You should require that SEMS II program safety and environmental information be developed and maintained for any facility that is subject to the SEMS II program.

SEMS II program safety and environmental information should include:

  • program information that provides the basis for implementing all SEMS II program elements, including the requirements of hazard analysis (§ 250.1911)
  • process design information including, as appropriate, a simplified process flow diagram and acceptable upper and lower limits, where applicable, for items such as temperature, pressure, flow and composition
  • mechanical design information including, as appropriate, piping and instrument diagrams; electrical area classifications; equipment arrangement drawings; design basis of the relief system; description of alarm, shutdown, and interlock systems; description of well control systems; and design basis for passive and active fire protection features and systems and emergency evacuation procedures

SEMS II Program Elements

offshore rig

The SEMS II program should meet the minimum criteria outlined in the SEMS II rule, including the following SEMS II program elements:

  1. General (see 250.1909)
  2. Safety and Environmental Information (see 250.1910)
  3. Hazards Analysis (see 250.1911)
  4. Management of Change (see 250.1912)
  5. Operating Procedures (see 250.1913)
  6. Safe Work Practices (see 250.1914)
  7. Training (see 250.1915)
  8. Mechanical Integrity (Assurance of Quality and Mechanical Integrity of Critical Equipment) (see 250.1916)
  9. Pre-startup Review (see 250.1917)
  10. Emergency Response and Control (see 250.1918)
  11. Investigation of Incidents (see 250.1919)
  12. Auditing (Audit of Safety and Environmental Management Program Elements) (see 250.1920)
  13. Recordkeeping (Records and Documentation) and additional BSEE requirements (see 250.1928)
  14. Stop Work Authority (SWA) (see 250.1930)
  15. Ultimate Work Authority (UWA) (see 250.1931)
  16. Employee Participation Plan (EPP) (see 250.1932)
  17. Reporting Unsafe Working Conditions (see 250.1933)

We will cover each of the above program elements in this course.

Make sure you include a job safety analysis (JSA) for OCS activities identified or discussed in the SEMS II program (see 250.1911).

Finally, the SEMS II program should meet or exceed the standards of safety and environmental protection of API RP 75.

SEMS II Program Flexibility

The overarching mechanism used by an operator to develop and implement its SEMS II program provides avenues of flexibility, including the following:

  1. operator may apply the job safety analysis (JSA) to recurring events
  2. operator has the freedom to select the individual with ultimate work authority (UWA)
  3. operator can determine training frequency, training methodology, and the training vendor, except in specific cases where certain training requirements are specified in Section 7 of API RP 75

BSEE believes there is no need to prescribe each aspect of an operator's SEMS II training program or how frequently an operator must conduct periodic training. The final regulatory text in 30 CFR 250.1915 is sufficient to cover the detailed training requirements for an operator's SEMS II programs. The introductory language establishes that all personnel must be trained to perform work safely. These changes allow operators to take responsibility for implementing their training in accordance with the regulations.

Also, SEMS II maintains performance flexibility as evidenced by the discretion the rule grants to operators to design, develop, and deploy their employee participation plan and stop work authority programs.

Safety is an element that is easier to measure when it is absent. When an accident occurs, it is easy to point to that and say, “they were not safe,” and you can then peel back the contributing factors and identify things that should have been visible before the accident. That is why we must proactively identify, quantify, and mitigate risk based on new, relevant data streams. Brian Salerno, Director, BSEE)


Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!

1. Management can develop, support, and continually improve the overall success of the SEMS program by doing all of the following, except _____.

2. Each of the following are one of the nine characteristics of a robust SEMS II safety culture, except _____.

3. Each of the following are one of the 17 SEMS II program elements, except _____.

4. Make sure you include a _____ for OCS activities identified or discussed in the SEMS II program.

5. BSEE believes there _____ an operator's SEMS training program or how frequently an operator must conduct periodic training.

Have a great day!

Important! You will receive an "error" message unless all questions are answered.