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SEMS II Auditing Requirements


Auditing Requirements

The SEMS II program should be audited by an accredited Audit Service Provider (ASP) according to the requirements of the SEMS II rule and API RP 75, Section 12.

The audit process should also meet or exceed the criteria in Sections 9.1 through 9.8 of Requirements for Third-party SEMS Auditing and Certification of Deepwater Operations COS–2–03 or its equivalent.

The audit team leader should be an employee, representative, or agent of the ASP, and should not have any affiliation with the operator. The remaining team members may be chosen from the personnel and those of the ASP.

The audit should be comprehensive and include all elements of the SEMS II program. It should also identify safety and environmental performance deficiencies.

Audit Plan and Procedures

The audit plan and procedures should meet or exceed all of the recommendations included in API RP 75 section 12 and include information on how you addressed those recommendations.

You should specifically address the following items:

  1. Section 12.1 General
  2. Section 12.2 Scope
  3. Section 12.3 Audit Coverage
  4. Section 12.4 Audit Plan: You should submit the written Audit Plan to BSEE at least 30 days before the audit. BSEE reserves the right to modify the list of facilities that you propose to audit.
  5. Section 12.5 Audit Frequency, except the audit interval, should not exceed 3 years after the 2-year time period for the first audit. The 3-year auditing cycle begins on the start date of each comprehensive audit (including the initial implementation audit) and ends on the start date of the next comprehensive audit.
  6. Section 12.6 Audit Team. The audits should be performed by an ASP as described in 250.1921. You should include the ASP’s qualifications in the audit plan.

You should submit an audit report of the audit findings, observations, deficiencies identified, and conclusions to BSEE within 60 days of the audit completion date.

Corrective Action Plan (CAP)

You should provide BSEE with a copy of the Corrective Action Plan (CAP) for addressing the deficiencies identified in the audit within 60 days of the audit completion date.

The CAP should include the name and job title of the personnel responsible for correcting the identified deficiency(ies).

The BSEE will notify you as soon as practicable after receipt of the CAP if the proposed schedule is not acceptable or if the CAP does not effectively address the audit findings.

Audit Service Provider (ASP) Qualifications

The ASP should meet or exceed the qualifications, competency, and training criteria contained in Section 3 and Sections 6 through 10 of Qualification and Competence Requirements for Audit Teams and Auditors Performing Third-party SEMS II Audits of Deepwater Operations, COS–2–01, or its equivalent.

  • The ASP should be accredited by a BSEE-approved AB (See COS information below)
  • The ASP should perform an audit in accordance with 250.1920(a).

More information on becoming an ASP

Accreditation Body (AB) Qualifications


In order for BSEE to approve an Accreditation Body (AB), the organization should satisfy the requirements of the International Organization for Standardization’s (ISO/ IEC 17011) Conformity assessment— General requirements for accreditation bodies accrediting conformity assessment bodies, or equivalent.

The AB should have an accreditation process that meets or exceeds the requirements contained in Section 6 of the Requirements for Accreditation of Audit Service Providers Performing SEMS II Audits and Certification of Deepwater Operations, COS–2–04 or its equivalent, and other requirements specified in the SEMS II rule.

  • Organizations requesting approval should submit documentation to BSEE describing the process for assessing an ASP for accreditation and approving, maintaining, and withdrawing the accreditation of an ASP.
  • An AB may be subject to BSEE audits and other requirements deemed necessary to verify compliance with the accreditation requirements.

An AB should have procedures in place to avoid conflicts of interest with the ASP and make such information available to BSEE upon request.

The Center for Offshore Safety (COS) is an AB. The COS is an industry sponsored organization focused exclusively on offshore safety in the deepwater (water depths>1000 ft.) Gulf of Mexico. The Center serves the US offshore oil & gas industry with the purpose of adopting standards of excellence to ensure continuous improvement in safety and offshore operational integrity.

More information on the COS.



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. The SEMS II program should be audited by _____.

2. The audit should be comprehensive and include _____ the SEMS II program.

3. The SEMS II audit plan should be submitted to BSEE at least _____ days before the audit.

4. The SEMS II audit report sent to BSEE should include each of the following components, except _____.

5. Which of the following is an accreditation body which is an industry sponsored organization focused exclusively on offshore safety in the deepwater (water depths>1000 ft.) Gulf of Mexico?

Have a great day!

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