Safety White Paper.

Download the recent White Paper on Safety Planning and Training we developed in partnership with David Argy at SAFETYTRAINING. Follow SafetyOnlineNetwork on Twitter:

@OSHAnetwork.

See our Web site: SafetyRich

SEMS Elements Condensed.

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