Six Lessons From A Disaster.

These six lessons were derived from the finding of the investigation of a major disaster. If we do not learn from them, we will repeat them – to the detriment to life, health, profits and the environment.

Failure to stop work after encountering multiple hazards and warnings. A stop-work policy should be written and enforced. Continuing to work while a problem “is being fixed” is an invitation to disaster.

Failure to fully assess the risks associated with operational decisions and to ensure all risks are as low as possible. Conduct at least a minimal risk assessment and management. Read our four-part series that starts here: http://safetyrich.blogspot.com/2011/06/risk-management-part-1-of-4.html

Failure to consider contingencies and mitigation while making cost- or time-saving decisions. Almost all cost- or time-reducing actions also reduce safety. Protecting the health and well-being of workers should always prevail.

Failure to have full supervision and accountability over all activities in a work area. Abdication of control is abdication of commitment to a safe environment.

Failure to document, evaluate, approve and communicate changes associated with personnel, equipment, process and operations. A complete change management program identifies what new hazards could be created with the change.

Failure of have a common integrated approach to safety with contractors and employees. Contractors, supervisors and employees may each have their own idea of what safe means.  A safety program not fully enforced or followed may be more hazardous that not having any program. Employees can be willing to take risks, but they should live and breathe safety.

See our Web site: SafetyRich

SEMS Compliance for Contractors.

UPDATE: 11 November 2011. In a speech to IADC, Michael Bromwich announces that BSEE is moving toward enforcing the SEMS regulations on Contractors which are now only enforced for Operators. Watch here for news on this process. Expect enforcement action to begin late 2012. Contractors should act now to prepare.

Download the paper that condenses the 13 Elements of SEMS: http://goo.gl/R3tkY.

Contact SafetyRich for the full range valuable compliance services.

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Original Post:

On 15 November 2011, US government regulations relating to offshore safety go into effect. Specifically, Operators of offshore facilities (Facility definition: 30 CFR 250.1700c) must be in compliance with 30 CFR 250, Subpart S which applies to Safety Environmental Management Systems (SEMS) administered by the Bureau of Energy Management, Regulation and Enforcement (BOEMRE) of the US Department of Interior. SEMS regulations closely resemble The American Petroleum Institute’s API RP75. See: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title30/30cfr250_main_02.tpl.

Note 1: In 30 CFR 250, readers will note references to MMS. MMS was the Minerals Management Service, which was the predecessor to BOEMRE. A good start is to read the FAQ here: http://www.boemre.gov/ooc/newweb/frequentlyaskedquestions/frequentlyaskedquestions.htm.

Note 2: BOEMRE will, at some time in the future be split into two parts: Bureau of Energy Management (BOEM) and Bureau of Safety & Environmental Enforcement (BSEE). The later will enforce the SEMS regulations. The change was to have taken place in August 2011, but was delayed.

Contractors are not required to comply directly with the regulations. Contractors are, however, required to fully comply with the Operator’s requirements as if they were a part of the Operator. Although a US Government agency will not be enforcing SEMS regulations with the Contractors, the Operators require the compliance.

SEMS consists of 13 elements or areas requiring specific compliance. We provide advisory services in all of the elements, with specific compliance services in 11, particularly:

Safe Work Programs (30 CFR 250.1909 & .1914)

Safety & Environmental Management Programs (SEMPS) (30 CFR 250.1910)

Training Compliance and Tracking (30 CFR 250.1915) ***

Management of Change – Process & Documentation (30 CFR 250.1912)

Hazard Analysis – Development & Authorization (30 CFR 250.1911)

Risk Assessment & Management (30 CFR 250.1909 & .1913)

Investigation of Incidents – Process, Documents, Tracking, Reporting (30 CFR 250.1919)

Compliance Management & Tracking ***

Safety Manuals

*** In partnership with International Human Resources Development Corporation (IHRDC – www.ihrdc.com)

After 15 November 2011 various auditing, reporting and compliance timetables begin.

See our Web site: SafetyRich

Scaffold Safety.

A client asked SafetyRich to design a custom course on scaffolds. He wants us to cover both supported and suspended scaffolds.

A scaffold course includes assembly, moving, dismantling scaffolds in addition to the reason for having a scaffold in the first place: working on the elevated platform. The list of other items that should be covered includes:

Fall Protection: If a scaffold is assembled correctly and includes required barriers, a separate PFAS (Personal Fall Arrest System) is not mandated. If a scaffold is too far from the structure being worked on, a PFAS must be provided. A PFAS is always required for workers on a suspended scaffold.

Working Surface/Housekeeping: The working surface should be keep free of debris to prevent slips and trips. Spills should be cleaned up and any accumulation of material should be minimized.

PPE: Personal Protective Equipment should be used at all times. Depending on the work being done, PPE may include safety glasses, hard hats, gloves and hi-viz vests. Respirators, face masks and hearing protection may be used.

Weather/Wind: Since a scaffold is an elevated platform, workers can be exposed to the elements more than on the ground. If lighting is heard, we recommend getting off of the scaffold until the last thunder has passed by at least 15 minutes. Workers should get down from a scaffold when winds exceed 25 miles per hour (about 40 KPH). In a suspended scaffold, we use 20 MPH (32 KPH) at higher levels or where dismounting time may be extended.

OSHA requires that the installation of a supported or suspended scaffold be inspected daily by a competent person to make sure all equipment is in order. Failure to complete and note a daily inspection can result in dangerous conditions. If a worker is hurt, fines can be higher from enhanced levels of severity.

Installation foundations, rolling scaffolds and dozens of variables can complicate the design, installation and use of a scaffold system. Have a well qualified person in charge of the assembly and use of a supported or suspended scaffold.

See our Web site: SafetyRich