O&G offshore regulations.

Update 18 November 2011: According to Oil &  Gas Journal, In mid-November 2011, BSEE anounced it would begin proposed rulemaking procedures to enforce SEMS regulations on offshore Contractors in addition to Operators. Enforcement can begin when rulemaking is complete - expected in late 2012. Read the article.

On 15 November 2011, new regulations go into effect requiring safety and environmental systems for oil and gas exploration and production companies. See 30CFR250.

In September, the Bureau of Energy Management, Regulation and Enforcement (BOEMRE) splits into two entities: the Bureau of Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE) to enforce SEMS and API RP75 standards.

We focus our services on the later - BSEE - providing:

• Compliance tracking
• Safe Work programs (SWPs)
• Job Safety Analysis (JSA, JHA HA) - development & authorizations
• Bridging documents to comply with Operator SEMS programs
• Risk Assessment and Management
• Plans: Safety, Process, Operating
• Competency Models
• Training: General and Specialized
• Confined Space
• Fall Protection
• Hazardous Communications
• Walking & Working Surfaces
• Personal Protection Equipment (PPE)

SafetyRich partners with IHRDC to provide expert consulting, e-learning and tracking services. We provide a number of subject matter experts to offer a wide variety of services to O&G companies.

Write us at SafetyRich@gmail.com for no-obligation intial consultation and answers to critical questions.

See our Web site: SafetyRich

Spotted! #5

As we described in our two-part series on Training published in June, OSHA requires training on initial assignment – before workers set out to their assignments.  If their employer had trained them and made it clear that safety rules are to be followed, it is likely this case would have not occurred.

In the picture, a couple of violations are obvious:

1. A ladder used to reach a higher level of work should extend at least three feet above the level the worker is reaching. Using the rung spacing to estimate, we can say the ladder extends above the roof by about a foot.

2. The workers are not wearing gloves (or any other PPE, for that matter). So they expose their hands to several hazards when dealing with the metal Air Conditioner units.

3. Although the picture was taken while standing at ground level, it is easy to see the debris around the feet of the worker on the roof.  This debris presents tripping and slipping hazards.

4. Since the work is taking place close to an edge more than six feet above the lower level (the ground), Fall Protection for the worker on the roof is mandatory.

Some unseen concerns.

5. The base of the ladder is too close to the wall, so the ladder is too vertical. Regulations call for a ladder to be placed at  1:4 ratio – 1 foot out for every 4’ in elevation to the support point. The wall is approximately 13’ high, so the ladder should be around 3’ out from the wall for maximum stability.

6. Training: The workers are willing to work in unsafe conditions, so it is likely their training is deficient. Had the workers been trained in the requirements of federal laws, they would understand the hazards and how to avoid them.

A gentleman told me the other day: “You know, safety rules are pretty much common sense.” He is right, they are not difficult to remember or to follow.  Workers need to know the hazards and how to prevent injuries. Employers must want to protect their workers.

See our Web site: SafetyRich

Risk Management – Part 4 of 4

In previous articles - http://safetyrich.blogspot.com/2011/05/four-levels-of-protection-from-hazards.html and http://safetyrich.blogspot.com/2011/05/making-workers-want-to-be-safe.html - we have mentioned the fourth level of Risk Management. Although we consider it to be the most important, this fourth level is seldom acknowledged in Risk Management discussions or training.

All training sessions offered by our company emphasize the importance of worker involvement in the safety process right from the very first. We encourage workers to pause just a moment to ask themselves: “What can happen to cause me harm here, today?”

United States Steel has a video story about a maintenance worker – Robert – who worked at a USS mill for 35 years without a single injury! Robert did not even have a First Aid level injury his entire career. The key to Robert’s success was primarily in his willingness to pause at the very start of any project to assess the hazards. Did it slow down his production just a bit? Of course, but not near as much as a serious injury would have taken him away from work and cost the company money. See http://safetyrich.blogspot.com/2011/05/cost-of-injuries.html for an idea of how much he very likely saved his employer.

We will cover Robert’s story and what kept him safe in a future post.

When we show workers how to be safe, we tell them about the earlier levels of Risk Management – mostly out of their control. Then we explain the fourth level, the one where the worker has total control: YOU!  Everyone is able to see the hazards, understand what can hurt them and then avoid those dangers.

In our two parts on Training posted in this blog on the 7^th and the 14^th of June, we explain that the main purpose of training is to show workers the hazards and how to avoid them. No worker should have to be sick, hurt or die for a paycheck!

The worker’s brain is the most powerful tool in their kit. They should use their awareness and knowledge to avoid hazards with the full support of management. They want to be safe – let them.

See our Web site: SafetyRich

Spotted! #4

Often, an employer has things set up right at first, but simply does not keep it up. We were completing a safety inspection and investigation after an incident where a powered pallet jack had caught fire. In the picture below, the results of the fire can still be seen on a nearby box. What cannot be seen is just how close this came to being a major incident causing a lot of damage.

Behind the box, a sign marking the presence of a fire extinguisher can be seen.  In the second picture, looking behind the box, we can see the fire extinguisher is missing. This is potentially a very dangerous hazard because precious time could be lost looking for the missing extinguisher.  Fortunately, another worker ran over with another extinguisher for the pallet jack operator to use.  Fire put out, minimal damage, no injuries.

Let’s look at what else happened.

The pallet jack caught on fire because the battery overheated.  The company contracted to do maintenance on the equipment was not doing their job, so the battery was dry. In the course of the investigation we were looking into whether a fire could start while the jack was plugged in to the charger overnight. We found the charger was sitting on a stack of wooden pallets near an area where flammables were stored.

We also found that the manufacturer recommended that the battery cover be opened during charging. The operator, not properly trained, had no idea of the manufacturer’s requirements.

We also discovered that the operator had never been trained to operate a fire extinguisher. Fortunately, he figured it out quickly. The training we scheduled for key personnel was cancelled because it was too expensive. The company figured risking burning their facility to the ground was cheaper than training the workers.

Compliance with safety regulations is not free, but it is far cheaper than the damage that can result from neglect. And, in compliance, no workers are harmed.

See our Web site: SafetyRich