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.
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:
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.
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.
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.
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.
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.
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