Bridging documents

This degree of overlap has been recognised by a Commission decision (97/265/ EC), which will allow a company with ISO 14001 to proceed to EMAS registration fairly smoothly, provided a policy statement is issued and certain other minor details of the EMAS are complied with. This move has stimulated renewed interest in ISO 14001. The European standards body CEN has also given internal approval to a bridging document. 

Contract companies do not work in isolation—they have organizational and physical interfaces with the operator of the offshore facility and with other contractors. Since each company will have its own SMS, bridging documents are needed. A bridging document is a map that links the relevant sections of the different standards. So, if the operator s plan calls for start-up procedures, then the bridging document would show where the same information is located in the contractors documents. Any gaps would be identified, and the contractor s program would be modified to ensure that it fits with the operator s requirements. 

Figure 19.2 is an example of a bridging document between an operating and contracting company. 

Contractors with significant operations and/or contractor-owned facilities (MODU, derrick barge, lift boat, etc.) may consider developing a complete SEMP. A Bridging Document may be utilized to manage operations. Such a document will specify which SEMP s requirements are relevant for specific operations. This may avoid confusion as to operational control and work practices. 

Given that there will often be differences between the operator s and contractor s programs, it will be necessary to write bridging documents to ensure that the differences do not cause violation of the SEMS rule. 

The operator will have to show explicitly how his SEMS program, the bridging documents and the contractor s Safety Management System address the requirements of SEMS and RP 75. This is not a trivial task. 

Bridging documents are also used to create facility-specific versions of generic Safety Cases. For example, it has already been noted that the International Association of Drilling Contractors (lADC) has prepared a Safety Case template for a wide-range of drilling operations (both onshore and offshore). A bridging document can be prepared to match the needs of a particular facility to the general template strucmre. 

RP 75 does not require contractors to develop their own SEMP—although most of the larger contract companies will probably have done so. However, contractors should be familiar with the SEMP of the owner/operator with whom they are working. If the contractor company does have its own SEMP, then a bridging document wiU be needed... 

Given that there are about 130 operators in the Gulf of Mexico alone and over 10,000 contractors (of aU types), the number of potential bridging documents over a million—obviously a totally unmanageable workload. One way of getting around this is for each company to map its program to the elements of SEMS, as shown in... 

This section also makes it clear that the primary responsibility for the development and application of a SEMP lies with the owner/operator. (The phrase owner/operator is often used in RP 75, suggesting that the two entities are the same. However, this is not always the case. Other terms that are used are lessee and duty holder.) This section also discusses the role of large contractors, their need for a safety program and the value of them developing a SEMP. The standard states, This recommended practice does not require contractors to develop a SEMP. However, contractors should be familiar with the operator s SEMP... . Reference is made to the need for bridging documents. 

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