Offshore Major Accident Safety: Is SEMS Enough?
Authors: Pitblado Robin , Bjerager Peter 
Published: May 2013

Abstract
Formal Safety Management Systems (SMS) have been required in the USA and elsewhere for the onshore refining and petrochemical industries since the mid 1980's (EU) or early 1990's (USA). While several different versions of SMS exist they are mostly similar in content. Risk based SMS are more modern in thinking than hazard based systems. The O&G and petrochemical industries have reduced occupational accidents by close to a factor of ten over the past 15–20 years. However, major accident performance has hardly improved globally. An exception is the North Sea where major accidents appear to have declined by close to a factor of ten as well as occupational safety. This paper reviews some key additional requirements in the North Sea and why these appear to address major accidents better - by focusing on risks and barrier management and verification focusing on these. The SEMS approach as mandated by BSEE is essential and will be improved by safety culture requirements BSEE is proposing. However, since SEMS is very similar to OSHA 1910, and much less than North Sea requirements, it is likely that achievements will mirror that of 1910 and unlikely that the desired order of magnitude improvement in major accidents will occur. Additional focus on risk and barrier management is still required and this is not part of SEMS. A strong culture for process safety requires a focus on risk assessment and barriers.

Background to Safety Management Systems
The requirement for formal safety management systems (SMS) in the process industry has been common since the 1980's with earlier development of formal SMS by leading companies. Examples of these include the DuPont SMS, Exxon OIMS - Operations Integrity Management System, BP Getting HSE Right, and the DNV International Safety Rating System. A common feature is that most of these systems were developed in response to some major accident. The insight was that accident causes are not simply technical, but have underpinning management system influences (root causes) and major accidents would recur unless improved management systems were implemented.
The major accidents in the 1970's in Europe (i.e. Flixborough UK and Seveso Italy) spurred development of safety case regulations in the Seveso Directive (originally passed in 1984 and coming into force in 1986). This included a requirement for a formal SMS. Major accidents in the 1980's in the USA or affecting USA companies (i.e. Bhopal MIC release, Phillips Pasadena VCE, Marathon HF release Texas City) led OSHA to seek input for new regulations. API issued RP 750 for onshore and RP 75 (1991) for offshore and CCPS issued its Guidelines for Technical Management of Process Safety (1989). These guides were extensively used in the public process leading to development of OSHA 1910.119 - the Process Safety Management regulations (1992). About this time the UK HSE issued HSG 65 - Successful Health and Safety Management (1991). All of these systems used an element based approach to the SMS with 12–20 elements typically. Most had the same content and the differences were primarily textual.
These initial processes were followed by other initiatives that continue to current times. The UK HSE Offshore Safety Case regulations (1992) were an extension of the requirements in the EU Seveso Directive and included more advanced risk thinking from the Cullen Inquiry. The EU Seveso Directive was updated on multiple occasions to address new threats as they occurred (e.g. environmental damage: pollution of the Rhine following a fire at Sandoz, and a major cyanide spill from a mining dam in Eastern Europe). A major revision increased the focus on major accidents and changed the degree of justification in the safety case (e.g. as implemented in the UK) from " describe?? the safety systems to " demonstrate?? the adequacy of safety systems. The US EPA (1996) issued the RMP regulations (Risk Management Plan). These were very similar to OSHA 1910, but required Offsite Consequence Analysis for standardized 10 minute worst case events and optional some alternative release scenarios. An RMP document had to be created describing the SMS and safety systems this had some similarity to the EU safety case document. OSHA 1910 required the SMS elements to be in place but not collected into a single document.