6 DATEEVENT 10/15/10SEMS Final Rule Published 9/14/11SEMS II NPR Published 11/14/11SEMS II NPR Comment Period Closed 11/15/11Mandatory Implementation of SEMS 11/22/11SEMS PINCs are online 9/11/12Zero BSEE Conducted Audits – 5 Independent 11/15/13Initial Audits must be completed Relevant Dates
8 The Subpart S rule does not require a MODU owner or contractor of any kind to develop a SEMS. The OCS operators are the only parties that must develop and implement a SEMS program within the context of the requirements set forth in Subpart S. Key Point
9 NTL No. 2011 – N09 “You” as used in Subpart S, includes a lessee, the owner or holder of operating rights, a designated operator or agent of the lessee(s), a pipeline right-of-way holder, or a State lessee granted a right- of-use and easement. Subpart S does not require a contractor or subcontractor performing work for you on a facility as described in 30 CFR 250.1911 to have a SEMS.
10 Operator’s SEMS program must document contractor selection criteria. When selecting a contractor, Operator’s 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 Operator’s SEMS program. Operators and their contractor(s) must document an agreement on appropriate contractor safety and environmental policies and practices before the contractor begins work at their facilities. This does not include contractors providing domestic services, e.g., janitorial, food and beverage, laundry, housekeeping, etc. Operator’s SEMS Obligations
11 BSEE has the authority in Subpart S to direct OCS operators to conduct comprehensive SEMS audits based on operator or contractor performance, e.g.: INC to Component Ratio INC to Inspection Ratio Incidents Increased Oversight List Leading Indicators – Shut-in PINCs, P-103, etc Civil Penalties SEMS awareness / participation Are you in the clear?
34 sets of comments submitted to BSEE on the SEMS II NPR Themes: Jurisdiction Independent Third Party (I3P) Holistic Regulatory System Process Safety Job Safety Analysis (JSA) Ultimate Work Authority (UWA) Stop Work Authority (SWA) SEMS II NPR Comments
16 Proposed - JSA Personnel performing job must be aware of hazards and sign the JSA Immediate supervisor of crew – conducts the JSA, sign it, and make sure all personnel participating sign Individual in charge of the facility must approve and sign all JSAs Electronic signature allowed – if allowed in Operator’s SEMS plan If operation occurs often and parameters (personnel, weather, procedures, equipment, etc) don’t change, person in charge may decide an individual JSA is not required Operators must ensure all personnel are trained in accordance with 250.1915 prior to a contractor starting a job
17 Proposed - SWA Operator must have procedures that ensure the capability to immediately stop work that causes imminent risk SWA covered in JSA Person in charge of operation responsible for shutting down work in a safe manner SWA procedures / training for orientations
18 Proposed - UWA The authority assigned to an individual to make final decisions relating to activities and operations on the facility Personnel must know who has UWA – especially if responsibility shifts under certain scenarios
19 Familiarize Yourself With This Audit team members shall meet the following requirements: At least 5 years of working experience in implementation, maintenance, or auditing of safety and environmental management systems At least 5 years of working experience in offshore or related oil and gas operations in each of the following areas: MOC, HAZID, Operating procedures, and process safety Technical expertise in mechanical integrity (5 years experience) Knowledge and understanding of the SEMS audit protocol developed by COS Education/experience to comprehend and evaluate how offshore activities, materials, methods, etc may impact health, safety, and environmental performance on offshore facilities
Sub S does not require Contractors to have a SEMS SEMS II NPR expected completion October 2012 BSEE has started observing operator conducted audits and overseeing directed audits Expect varying degrees of compliance Don’t sit back and watch – try to get involved If you have questions, ask them! My number is (504) 731-1496 Summary
September 11, 2012 www.bsee.gov Bureau of Safety and Environment Enforcement 1201 Elmwood Park Blvd. New Orleans, LA 70123