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COMPLIANCEwith regulatory requirements;  environmental enforcement with a focus on compli- ance by operators with all applicable environmental reg- ulations, as well as ensuring that operators adhere to the stipulations of their approved leases, plans and permits;  and funding scienti c research to enhance the infor- mation and technology needed to build and sustain the organizational, technical and intellectual capacity with-in and across BSEE?s key functions that keeps pace with industry technological improvements, innovates regula- tion and enforcement and reduces risk through system- atic assessment and regulatory and enforcement actions in order to better carry out the BSEE mission. SEMS: WHAT IT MEANS & WHYBSEE implemented offshore oil-and-gas SEMS require- ments in 2011, and SEMS II went into effect in mid-June of this year. SEMS II clariÞ ed that offshore personnel, in- cluding contractors, must be trained in safety and emer-gency response. Operators have to make sure that contract employees understand safe-work practices before they set foot on a vessel. Contractors and operators have to docu- ment a safety and environmental plan before the contrac- tor begins work. ÒAs a vessel operator focused mainly in the shallow wa- ters of the GOM, the SEMS approved by BSEE doesnÕt apply to us directly in the way that it does to our clients, the lease holders,Ó Barousse said last month. ÒBut we do have to comply with it indirectly because we need to meet the requirements of our customers.Ó ÒWeÕre a shallow water or Shelf operator; not a deep- water operator,Ó Barousse explained further. ÒDeepwater tends to attract more formally trained and educated per- sonnel because the vessels are larger and more technical and require greater skills. But the regulations for vessel op- erators are pretty much the same across the board, deep or shallow water.Ó Today, Fleet Operators has 80 employees, including its contractors.Under todayÕs regulations, Fleet Operators and its oil- and-gas customers coordinate before FleetÕs offshore work begins. ÒWe have to cooperate with the leaseholderÕs obli- gation to meet BSEEÕs SEMS through a Bridging Agree- ment,Ó Barousse said. ÒThat requires that the client re- view and sign off on our health, safety and environmental programs and practices,Ó he said, adding, ÒI feel that the deepwater sector, because of the nature of its business, had a head start in becoming compliant with SEMS when it became effective in 2011,Ó Barouse said. HURDLES TO COMPLIANCEVessel operators on the Shelf have faced hurdles because of SEMS. In the past, many of FleetÕs applicants for work had a bare minimum of safety training, he said. ÒAppli- cants trying to cross over from commercial Þ shing, for ex-ample, have a ton of vessel experience but have never been formally trained.ÓÒOur class of vessels is sort of at the entry level,Ó Barous- se said. ÒWe have to make investments in people before we even know if theyÕre capable of doing the job because training is required before they can go offshore. WeÕve seen cases where a new employee is fully trained and ready to start work, looked great on paper, but out on a vessel they canÕt perform the job. They might get seasick, not be able to handle the environment or simply not like it. When that happens, we usually lose out.Ó Meeting federal training requirements doesnÕt automati- cally make the person a good seaman the way experience does, Barousse said. ÒItÕs a chicken before the egg problem.Ó The situation is starting to change for the better, however. ÒNow that SEMS rules have been in place for a couple of years, applicants are coming to us with most or all of the required training, often from previous employers,Ó he said. As part of its rules, BSEE requires oil-and-gas operators to do periodic audits of their contractorsÕ SEMS programs. ÒDocumentation to provide an audit trail is required now for things that were just part of doing business before,Ó Barousse said. ÒWeÕve had staff in place to track the docu- mentation and enter it into monitoring systems via the internet. But many companies had to hire people to do that.Ó And, that costs money. Beyond this, said Barousse, ÒWe often hire consultants to make sure that we are on the right track, and we continuously perform self auditsÓ. SEMS: IMPACT & PERCEPTIONS Fleet Operators views SEMS as mostly positive because its employees are getting more training and their safety awareness has increased. ÒA couple of years ago, it meant a big increase in training,Ó Baroussse said. ÒSEMS compli- ance is a cost of doing business. But we havenÕt calculated how much it has cost us overall. Now that the rules have been in place for awhile, our direct expense of getting a per- son ready to work is starting to level out because people are applying with most or all of the required documentation.Ó Fleet Operators uses internal and outside assets to satisfy its training requirements. ÒAll of our employees go through required core training, and then quite a bit of itÕs on the job and refreshers,Ó Barousse said. ÒPeople at all levels, www.marinelink.com MN 33MN November2013 Layout 32-49.indd 33MN November2013 Layout 32-49.indd 3310/28/2013 3:17:54 PM10/28/2013 3:17:54 PM