- November has come and gone –

What did we learn?What should we do now?

Question of the year: What does MMS/BOEMRE/BSEE want?

Challenges in 2011

Physical compliance and management system compliance are different

Challenges in 2011

Developing documentation that reflected SEMS compliance

Implementation was done irrespective of the ability to absorb change Organizations did not take the opportunity to increase their risk control Perception that SEMS is a “nightmare” was strengthened Several organizations attempted changes that were not commensurate

with their risk profiles

Challenges in 2011

The major challenges from an element perspective were:

Hazard Analysis Written Operating Procedure

Elements that are not fully linked are: Safety and Environmental Information Mechanical Integrity

Challenges in 2011

Hazard Analysis250.1911 What criteria for hazards analyses must my SEMS program meet?Hazards analysis requirements for simple and nearly identical facilities, such as well jackets and single well caissons, may be fulfilled by performing a single hazards analysis which you can apply to all such facilities

Challenges in 2011

Written Operating Procedures

250.1913 What criteria for operating procedures must my SEMS program meet? You must develop and implement written operating procedures that

provide instructions for conducting safe and environmentally sound

activities involved in each operation addressed in your SEMS program.

Challenges in 2011

Safety and Environmental Information

250.1910 What safety and environmental information is required?   Information that provides the basis for implementing all SEMS program

elements, including the requirements of hazard analysis

Challenges in 2011

Mechanical Integrity

250.1916 What criteria for mechanical integrity must my SEMS program meet?Inspections and tests can be performed more frequently if determined to

be necessary by prior operating experience.

Challenges in 2011

Stages of organizational development:a. Individualized

b. Departmentalized

c. Formalized

d. Focused

e. Learning

Challenges going forward

Rules for success:a. Celebrate early successes

b. Identify early adopters

c. Control what is critical

d. Measure, compare, optimize

e. Institutionalize

Challenges going forward

Define what success is:It is no use saying “we are doing our best” You have got to

succeed in doing what is necessary – Winston Churchill

a. Acceptance in the field

b. Suitability for use

c. Impact “at the valve”

Celebrate early successes

Early adopters:a. Try to use the system as intended

b. Provide constructive criticism

c. Convince others

Early adopters

Define what is critical:a. Use hazard analysis to align SEMS

b. Four questions of risk management

c. Precision risk management

Control what is critical

Continuous improvement:Prescription without diagnosis is malpractice, be it in medicine or

management – Karl Albrecht

a. Measure what you are trying to control not what you are trying

to achieve

b. Communicate

c. Safer, better, faster

d. Use technology

Measure, compare, optimize

When SEMS is seamlessly integrated into production, it is REALLY part of my organization

Institutionalize

Be persistent but flexible