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contract workers we?re hiring meet SEMS standards.? He adds, ?In that case, we might even train people from the other vessel operator?s company to get them up to speed.? BSEE CAN FINE CONTRACTORS NOWA chance of being  ned looms in the new environment. ?One big change regarding SEMS regulations is that BSEE is now authorized to  ne anyone working on a lease, not just the leaseholder,? Barousse said. ?It?s kind of scary in that they used to only have jurisdiction over the lessee. So far, the only  nes issued to non-lease holders that I?m aware of were assessed to contractors directly involved in the integrity of a well. But they can extend compliance now to anyone working on the lease.? ?Most of BSEE?s inspections are scheduled directly with leaseholders over facility inspections, drilling operations, etc., and don?t affect boat operators much,? he said. ?But again, BSEE has authority to  ne anyone working on the lease.? That means that vessel operators will need to tight- en up and remember that, in this environment, they have to answer to more than one master. U.S. COAST GUARD : YET ANOTHER SET OF RULES While BSEE?s rules hold lease operators accountable for operational safety on Outer Continental Shelf leases, the U.S. Coast Guard wants its own policy for vessels. On Sep- tember 10, the USCG published a Federal Register notice proposing regulations that would require boats involved in exploration, development or production on the OCS to maintain a vessel-speci c Safety and Environmental Management System. The Coast Guard estimates that as many as 2,200 foreign and domestic vessels engaged in OCS activities could be affected, including offshore supply vessels, liftboats, accommodation vessels, mobile offshore drilling units, well stimulation vessels,  oating production and storage of oad units, shuttle tankers and other vessels under its jurisdiction. The comment period on the Guard?s Federal Register notice ends on December 9. The USCG?s proposal would align its regulations with BSEE?s and would incorporate the management program and principles of API RP 75 ? the American Petroleum Institute?s Recommended Practice for Development of a Safety and Environmental Management Program for Out- er Continental Shelf Operations and Facilities. API?s stan- dard was published in July 1998. In its September Federal Register notice, the Coast Guard included Table 1 (page 34), describing the current safety regime for vessels operating in the Outer Continen- tal Shelf. But Barousse feels the table is a bit misleading. He said: ?For offshore supply vessels, it says ?No SEMS directly required, but may or may not be subject to a des- ignated lease operator?s SEMS.? The real-world situation is stricter than that for us, however.? COMPLIANCENovember 201336 MNMN November2013 Layout 32-49.indd 36MN November2013 Layout 32-49.indd 3610/28/2013 3:18:27 PM10/28/2013 3:18:27 PM