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September 23, 2013
Coast Guard would expand SEMS coverage

In an advanced notice of proposed rulemaking (ANPR), the U.S. Coast Guard announced its intention to require the development and implementation of “vessel-specific” safety and environmental management systems (SEMS) for all domestic and foreign-flagged vessels engaged in Outer Continental Shelf (OCS) activities.  An OCS activity is any offshore activity associated with the exploration for or development of production of OCS minerals. 

The requirement would be compatible to the SEMS regulations currently implemented by the Bureau of Safety and Environmental Enforcement (BSEE), but will expand the number of OCS vessels that must have SEMS that address safety and environmental issues specific to those vessels.  The Coast Guard estimates that approximately 2,200 foreign and domestic vessels engaged in OCS activities could be affected by this action, including 1,800 offshore supply vessels, 150 lifeboats, 125 mobile offshore drilling units, and 125 other vessels. 

API recommended practice

The contemplated SEMS requirement would incorporate the management program and principles of the American Petroleum Institute’s (API) Recommended Practice for Development of a Safety and Environmental Program for Offshore Operations and Facilities (API RP 75).  API RP 75 provides an example of a systematic and proactive management approach intended to assist vessel owners and operators to safely plan, design, manage, and conduct offshore oil, gas, and sulfur operations.  Existing BSEE regulations require that designated lease operators develop, implement, and maintain a SEMS program based on API RP 75.

The Coast Guard notes that the BSEE SEMS requirement is directed toward lease operators.  But the majority of vessels engaged in OCS activities are contracted out by the lease operators.  While BSEE’s regulations also require lease operators to ensure that contractors have their own written safe work practices, the Coast Guard says it believes that vessel owners and operators should be responsible for developing a vessel-specific SEMS because they manage vessel-based personnel, operations maintenance, equipment, emergency response, and alterations. 

SEMS components

According to the Coast Guard, implementing a vessel-specific SEMS that incorporates the management program and principles of API RP 75 would start with an assessment of operating and design requirements as well as a hazards analysis. Under the contemplated regulations, the SEMS would establish vessel-specific safe operating procedures, work practices, management-of-change procedures, and associated training. The SEMS would also incorporate procedures to ensure that the design, fabrication, installation, testing, inspection, monitoring, and maintenance of equipment comply with all applicable safety regulations (e.g., 33 CFR Subchapter N). 

Additionally, the SEMS would be subject to periodic safety audits and would include procedures for emergency response and vessel owner and operator internal incident investigations to help mitigate risk and prevent future mistakes.

Other standards

The Coast Guard says it recognizes that there are vessels operating under other SEMS standards published by the International Maritime Organization, the Association of Drilling Contractors, and the International Standards Organization.  The Coast Guard says it is currently researching whether compliance with these management programs would be an appropriate alternative to API RP 75.

The ANPR was published in the September 10, 2013, FR

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