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907 Introduction to SEMS II
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Audit Plan and Procedures

The audit plan and procedures for the SEMS program must meet or go beyond all of the recommendations listed in Section 12 of API Recommended Practice (RP) 75. Operators must also explain how each recommendation has been addressed in their audit plan. This ensures that the audit process is thorough, transparent, and aligned with federal safety and environmental standards.

Each of the following items from API RP 75 Section 12 must be specifically addressed in the audit plan:

  • Section 12.1 – General: This section covers the overall purpose and importance of the audit process. Operators must show they understand the role of audits in improving safety and environmental performance.
  • Section 12.2 – Scope: Operators must clearly define what will be reviewed during the audit, including all operations, facilities, and SEMS elements to be evaluated.
  • Section 12.3 – Audit Coverage: This section requires a detailed explanation of how each part of the SEMS program will be audited. Coverage must be complete and include all required program elements.
  • Section 12.4 – Audit Plan: A written audit plan must be submitted to the Bureau of Safety and Environmental Enforcement (BSEE) at least 30 days before the audit begins. BSEE has the authority to change or add to the list of facilities the operator proposes to audit.
  • Section 12.5 – Audit Frequency: After the initial implementation audit is completed, audits must occur at least once every 3 years. The 3-year cycle starts from the first day of each comprehensive audit and ends on the start date of the next one.
  • Section 12.6 – Audit Team: The audit must be carried out by an accredited Audit Service Provider (ASP) as defined in 30 CFR § 250.1921. The audit plan must include the ASP's qualifications to show they are capable of performing a reliable and objective audit.

Once the audit is finished, the operator must submit a complete audit report to BSEE within 60 days. This report must include all findings, observations, any deficiencies identified, and overall conclusions about the SEMS program's effectiveness. This requirement helps ensure that safety and environmental risks are recognized and corrected in a timely manner.

These procedures support compliance with federal regulations under Title 30, Section 250.1920 of the Code of Federal Regulations.

Knowledge Check Choose the best answer for the question.

6-2. When must the operator submit a written audit plan to BSEE?