Safety management systems nonprescriptive

Safety management systems are largely nonprescriptive that is, the regulations and standards in this field generally provide very little specific detail as to what has to be done. This lack of detail explains why the technical section of the SEMS rule is so short. The regulation merely requires that programs be in place, that they be adhered to, and that they work. 

In spite of these differences, the reaUty is that there is a good deal of overlap between the safety case and SEMP/SEMS approaches. Both result in the development of a Safety Management System, and both are basically goal-based and nonprescriptive, although SEMP and SEMS do reference a large number of prescriptive standards, mostly from the American Petroleum Institute (API). 

SEMP is very similar to the Process Safety Management standard (OSHA 1992) issued for onshore facilities in 1992 and which was widely hailed as being a good example of a performance-based, nonprescriptive standard. SEMP provided the basis of the SEMS rule, which was then supplemented by SEMS II. Therefore the combination of SEMS and SEMS II does create a performance-based system, although different in detail and application from the Safety Case approach. 

The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) does not provide detailed guidance as to how a Safety and Environmental Management System (SEMS) program is to be implemented because the standard is fundamentally nonprescriptive. Each company and facility will need to develop a SEMS compliance plan that addresses their own needs and circumstances. Some thoughts as to how this can be done are presented in this chapter. 

At the heart of the safety case approach lies an understanding that is the operator of a facility—not the regulator—who decides how to ensure safe operations. This nonprescriptive approach to the management of safety is similar to the manner in which most PSM programs are prepared and administered. The operator of the facility, known as the duty holder, develops a safety system that is pertinent to that particular facility. The duty holder s performance is then assessed against his or her own standard. 

Two of the key standards to do with safety instrumentation are EC 61511 and lEC 61508. They are performance-based, nonprescriptive standards that provide a detailed framework and a lifecycle approach for the design, implementation, and management of safety systems applicable to a variety of sectors with different levels of risk definition. 

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