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