3rd Party or not to 3rd Party, that is the question..

We know SEMS requires an audit to be conducted within 2 yrs. of your SEMS implementation date of 15 Nov. 2011 as per 30CFR 250.1920(b)(6). That means you must have your 1^st audit completed by 15 Nov. 2013.

§ 250.1920 What are the auditing requirements for my SEMS program?

(b) Your audit plan and procedures must meet or exceed all of the recommendations included in API RP 75 section 12 (as specified in § 250.198) and include information on how you addressed those recommendations. You must specifically address the following items:

(6) Section 12.6 Audit Team. The audit that you submit to BSEE must be conducted by either an independent third party or your designated and qualified personnel. The independent third party or your designated and qualified personnel must meet the requirements in § 250.1926.

We also know that current SEMS requirements allow you to conduct these audits with independent 3^rd party auditors or your designated and qualified personnel as per 30CFR 250.1926(a).

§ 250.1926 What qualifications must an independent third party or my designated and qualified personnel meet?

(a) You must either choose an independent third-party or your designated and qualified personnel to audit your SEMS program. You must take into account the following qualifications when selecting the third-party or your designated and qualified personnel:

Many companies are using their own personnel to accomplish this audit. As required in 30CFR 250.1924(d), you must submit your audit plan to BSEE at least 30 days prior to beginning your audit. It is at this point that they will review your audit team and their qualifications. If they see that you are utilizing company personnel to conduct your audit, then they very well could exercise the same CFR reference which states that BSEE may observe or even participate in your audit.

§ 250.1924 How will BSEE determine if my SEMS program is effective?

(d) Representatives from BSEE may observe or participate in your SEMS audit. You must notify the BSEE at least 30 days prior to conducting your audit as required in § 250.1920, so that BSEE may make arrangements to observe or participate in the audit.

The SEMS II rule, sent to the Office of Management and Budget on 31 Jan. 2013, states on page 14 under the section titled “Independent Third Party Audit” that the BSEE will require third party auditors for the following reasons:

• Provide greater assurance
• Ensure objectivity
• Avoid even the perception of bias

The SEMS II rule recommendation does also list a small paragraph offering  a less stringent requirement to leave this requirement the way it currently exist. It is immediately followed by a more stringent longer paragraph offering the Federal Government conduct all audits. It goes on to say that BSEE strongly believes third party audits, along with government oversight, will be sufficient.

The current charge for government inspectors to come offshore and conduct an inspection is around $30,000. I believe when I speak for everyone involved, that we don’t want the government to take on the role as sole auditor.

The above reasoning supports my recommendation for third party auditor utilization.