TRB Special Report 309: Evaluating the Effectiveness of Offshore Safety and Environmental Management Systems recommends that the Bureau of Safety and Environmental Enforcement (BSEE) take a holistic approach to evaluating the effectiveness offshore oil and gas industry operators’ Safety and Environmental Management Systems (SEMS) programs. According to the report, this approach should, at a minimum, include inspections, audits by the operator and BSEE, key performance indicators, and a whistleblower program.

SEMS is a safety management system(SMS) aimed at shifting from a completely prescriptive regulatory approach to one that is proactive, risk based, and goal oriented in an attempt to improve safety and reduce the likelihood that events similar to the April 2010 Macondo incident will reoccur.

According to the committee that produced the report, it is not possible for a regulator to create a culture of safety in an organization by inspection or audit; that culture needs to come from within the organization. To be successful, the tenets of SEMS must be fully acknowledged and accepted by workers, motivated from the top, and supported throughout the organization and must drive workers’ actions.

The report also notes that BSEE can encourage and aid industry in development of a culture of safety by the way it measures and enforces SEMS. The Committee believes BSEE should seize this opportunity to make a step change in safety culture by adopting a goal based holistic approach to evaluating the effectiveness of SEMS programs.

In recommending a holistic approach to evaluating the effectiveness of SEMS programs, the report explores in detail SEMS’ role in helping to develop a culture of safety, highlights the pros and cons of various methods of assessing the effectiveness of a SEMS program, and investigates existing approaches for assessing the SMS programs of various U.S. and international regulatory agencies whose safety mandates are similar to that of BSEE.

The culture of safety cannot be built or sustained through publishing statements from the chief executive officer and human resources department, posting notices in company internal and external communications, punishing individuals for incidents of noncompliance (INCs), rewarding individuals for a lack of INCs, or reading perfunctory safety minutes prior to meetings.