Spurred partly by the human and environmental cost of that explosion and subsequent spill, the US authorities have stepped up safety requirements for operators on every level, including decommissioning.

On 15 November 2011, the Work Place Safety Rule required all operators to implement a Safety and Environmental Management program, but how much does this really affect the market?

The impact will be more keenly felt by the smaller independents, rather than the super majors. The primary reason being that super majors and a number of contractors were already following API RP 75, which has now become mandatory. Despite, this analysis provided by DecomWorld’s Offshore Decommissioning Report 2012-13, Gulf of Mexico has demonstrated how SEMS will affect practically all offshore operations from drilling activities to lifting point certification.

The authorities, notably the recently created Bureau of Safety and Environmental Enforcement (BSEE), are taking SEMS very seriously. They have pledged scheduled and unscheduled inspections of all offshore facilities to ensure that a suitable and fully functioning SEMS is always in place.

As well as these random inspections, operators will have to report key performance indicators annually and there will be periodic third party audits of their SEMS programs.

Mechanical integrity of equipment is one vital element covered by SEMS. A process must be in place for specification, inspection, monitoring, maintenance and repair/replacement of critical equipment.

Procedures for safe operating and Management of Change (MOC), i.e changes in facilities and personnel, are now mandatory too.

Operators also have to conduct two types of hazard analysis at facility and operations levels.

One operator interviewed for the Decomworld 2012 report said: “The SEMS regulations have placed the onus on the operators, and consequently on the contractors, to better qualify and verify that the contractor personnel are properly trained and qualified to do the work they are being asked to do.”

This will undoubtedly mean an extra financial burden in many instances, though it is one the industry will scarcely begrudge if it is serious about improving its tarnished image.

As Michael R. Bromwich, regulation and enforcement director of the now defunct BOEMRE, said last year: “The Deepwater Horizon tragedy has shaken government, and I hope industry, out of a complacency and overconfidence that had developed over the past several decades.”

The DecomWorld 2012 report shows how operators and contractors would do well to view SEMS as a continuing commitment to safety and best practice rather than a one-off effort.

To learn more on how the latest regulatory trends are impacting decommissioning activities in the Gulf of Mexico, visit: http://www.decomworld.com/gomreport/index.php

By Sam Phillips