13 SEMS elements
1. General – Principles & Scope
General: This is the overall definition of the Operator’s
SEMS compliance program. This section includes requirements for management
responsibilities, buy-in and support.
Format: Written documents.
2. Safety & Environmental Information
General: Deals with process safety information which
requires an employer to compile a complete list of all hazards and the plan to
deal with those hazards. Employer must cause a SEMS program to be developed
including: Information that provides the basis for implementing all SEMS
program elements; process design information; and mechanical design
information.
Format: Written Plan & supporting documents. Basis for
writing this is Hazard Analysis (#3) Can be included in Safety Manual, Safe
Work Practices (#6)
3. Hazards
Analysis
General: Employer
must ensure the development and implementation of a hazards analysis (facility
level) and a job safety analysis (operations/task level) for all of your
facilities. Note: The Hazard Analysis
must be completed by Operators before 15 November 2011.
Format: Inspections
with findings included in a written plan. Job Safety Analysis (JSA) has an
archival requirement of two to three years depending on the circumstance. JSA
must be produced on demand.
4. Management of
Change
General: Employer must develop and implement written
management of change procedures (MoC) for modifications associated with the
following: (1) Equipment, (2) Operating procedures, (3) Personnel changes
(including contractors), (4) Materials, and (5) Operating conditions.
Format: Written Document. Note: This is the most complex of all of the written documents. It is
commonly believed that failure to manage changes was the root cause for the
Macondo incident. See blog post on related failures – based on the final
report on the Macondo incident: http://safetyrich.blogspot.com/2011/09/six-lessons-from-disaster.html
5. Operating
Procedures
General: Employer must
develop and implement written operating procedures that provide instructions
for conducting safe and environmentally sound activities involved in each
operation addressed in the SEMS program.
Format: Written
document.
6. Safe Work Practices
General: Employer’s SEMS program must establish and implement safe
work practices designed to minimize the risks associated with operating,
maintenance, and modification activities and the handling of materials and
substances that could affect safety or the environment. The SEMS program must also document contractor selection criteria. When
selecting a contractor, you must obtain and evaluate information regarding the
contractor's safety and environmental performance. Operators must ensure
that contractors have their own written safe work practices. Contractors may
adopt appropriate sections of the operator's SEMS program. Operator and
contractor must document their agreement on appropriate contractor safety and
environmental policies and practices before the contractor begins work at the
operator's facilities.
Format: Written document.
7. Training
General: Employer’s SEMS program must establish and
implement a training program so that all personnel are trained to work safely
and are aware of environmental considerations offshore, in accordance with
their duties and responsibilities. Training must address the operating
procedures, the safe work practices, and the emergency response and control
measures. You must document the qualifications of your instructors. Your SEMS
program must address: Initial training, Periodic training, Communication of
changes, verification of contractor’s personnel training.
Format: Learning Management System (LMS), training matrix, elearning, onsite training.
8. Mechanical
Integrity
General: Employer must
develop and implement written procedures that provide instructions to ensure
the mechanical integrity and safe operation of equipment through inspection,
testing, and quality assurance. The procedures must address: design,
procurement, fabrication, installation, calibration, and maintenance of
equipment; training; inspections; correction of deficiencies; installation of
new equipment; construction; verification of various equipment aspects;
maintenance; parts; repairs. Note: This
is the most Involved of all of the requirements. The Operators will take care
of this and tell Contractors what they need to do to meet these requirements.
Format: Written
documents. Extensive use of SMEs. Heavy archival requirements.
9. Pre-Startup Review
General: This element of the SEMS program deals with the
Operator’s commissioning process and includes a pre-startup safety and
environmental review for new and significantly modified facilities that are
subject to Subpart S to confirm that the specific criteria are met. This
requirement has a significant training component.
Format: Primary: Procedures. Partial: LMS, training matrix
10. Emergency
Response & Control
General: The SEMS program requires that emergency response
and control plans are in place and are ready for immediate implementation.
These plans must be validated by drills carried out in accordance with a
schedule defined by the SEMS training program. The SEMS emergency response and
control plans must include: An Emergency Action Plan; Emergency Control
Center(s) designated for each facility with access to the Emergency Action
Plans, oil spill contingency plan, and other safety and environmental
information; training and drills.
Format: Written documents with archival and immediate
retrieval options. LMS, training matrix.
11. Investigation of
Accidents
General: The Operator’s SEMS program must establish
procedures for investigation of all incidents with serious safety or
environmental consequences and require investigation of incidents that are
determined by facility management or BSEE to have possessed the potential for
serious safety or environmental consequences.
Format: Written documents describing action. Immediate
retrieval is important.
12. Auditing the
Program
General: The SEMS program must be audited by either an
independent third-party or the Operator’s designated
and qualified personnel* according to the requirements of this subpart and
API RP 75, Section 12 within 2 years of the initial implementation of the SEMS
program and at least once every 3 years thereafter. (*As defined by BSEE)
Format: Action with findings as written documents. Heavy
archival requirements.
13. Records & Documentation
General: As required by 30CFR250.1928 (in Subpart S).
Requires significant archiving of up to six years.
Shameless marketing note: SafetyRich specializes in written documents, training and Job Hazard Analyses as required in Elements (green). SafetyRich, our team of professionals and business partners provide expertise and Project Management to meet Elements (dark red).
Not sure if you are compliant? Take the short survey here.
Questions? Email me richard@jcgsafety.com
