One of the most valuable tools for oil and gas companies that want to make sure they are meeting the new SEMS requirements is now available for review. I am talking about the Bureau of Safety and Environmental Enforcement’s (BSEE) Potential Incident of Noncompliance List for SEMS. In the industry, that is known as the PINC list and the agency issues PINC lists to help its field units interpret and enforce regulations. As a result it is an inside look at what the BSEE enforcers are looking for when they visit an offshore facility or an oil and gas company office.
The industry has been waiting with bated breath for the SEMS PINC list because it clarifies what the agency will focus on when enforcing SEMS. At the very least, it helps lease-holders fine-tune their SEMS plans. This particular PINC list is extensive – more than 20 pages long. The list goes through each of the 13 elements of SEMS and highlights the specific parts that BSEE personnel should ask to see. To no one’s surprise, the PINC list focuses on documenting and verifying procedures. For example, under the section covering contractor safety, the list says personnel should:
Verify that when selecting contractors, operators should obtain and evaluate information regarding a
contractor’s safety and environmental management policies, practices, and past performance along with their
procedures for selecting sub-contractors.
In other words, the agency is saying to operators, “Show us the process you use to decide if a contractor is safe.” Other parts require the operators to share their SEMS expectations with contractors and that the two sides agree on the safety approach to be used on the facility.
As if anyone needed reminding, the PINC list shows how much is riding on SEMS compliance. Incidents of Noncompliance carry a potential fine of $35,000 per day. The list also helps clarify when an infraction could result in a shutdown of the facility. For most items on the list, failure to comply results in a warning INC. However, failure to have a SEMS plan or allowing an unsafe condition to exist that could threaten the facility and everyone on board could result in an order to shut down the entire facility until the problem is fixed. In cases where a particular piece of equipment presents a hazard or personnel working on that equipment are not properly trained, that problem could result in an order to shut down that specific piece of equipment.