Introduction

In the United States, the Bureau of Safety and Environmental Enforcement (BSEE) requires an offshore lease operator to implement a Safety and Environmental Management System (SEMS), and to have it audited at least once every 3 years to evaluate its compliance to the regulatory requirements detailed in 30 CFR 250, Subpart S.

The first round of these SEMS audits, which concluded in 2013, was executed using varying audit styles – from system audits through to compliance audits. These varying audit styles, in turn, lead to differing types output, levels of detail, format and presentation.These diverse approaches may have been due, at least in part, to disparities in the expectations of stakeholders, differing interpretations of the use of the Center for Offshore Safety's (COS) SEMS Audit Protocol tools, use of other audit protocols, the experience-level of individual auditors, and the newness of the regulation.

System audits are intended to be a holistic assessment of a system, its elements, and how the elements work together to achieve system objectives. Compliance audits, on the other hand, are intended to assess adherence to specific requirements.

This white paper proposes that both types of audits should be used in tandem to reduce risk and increase confidence that a management system, and its verification programs, is operating as designed and meeting regulatory and company requirements.

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