SAFETY AND ENVIRONMENTAL MANAGEMENT SYSTEMS

1
SAFETY AND ENVIRONMENTAL MANAGEMENT SYSTEMS

Final Rule
January 14, 2011
David NedorostekBureau of Offshore Energy
Management Regulations and Enforcement 1/20/11
- Revised by M.G. Bell to include EP Operators
SEMS initiatives
2
Todays Discussion.

• Safety and Environmental Management Systems
  (SEMS) FINAL RULE
• HIGHLIGHTS?
• Contractor Selection Criteria
• Auditing Requirements
• 2. Key SEMS Elements
• - 13 elements in API RP 75

3
API RP 75 13 Elements

• 7. Training
• 8. Mechanical Integrity
• 9. Pre-Startup Review
• 10. Emergency Response Control
• 11. Investigation of Accidents
• 12. Auditing the Program
• 13. Records Documentation

1. General Principles Scope
2. Safety Environmental Information
3. Hazards Analysis
4. Management of Change
5. Operating Procedures
6. Safe Work Practices

4
SEMS Current Status

• Mandatory
• Companies are required to develop and implement
  their own SEMS
• Based on API RP 75 (SEMP)
• BOEMRE released ANPR (2006)
• NPR released (2009)
• Partial SEMS (4 Elements)
• Final Rule released (2010)
• Comprehensive (13 elements)
• Effective 11/15/2011

5
SEMS - Points of Interest

• Applications
• All operations
• All structures
• Fixed, floaters, MODU
• Program approval not required
• Lessee needs to have SEMS plan developed,
  implemented and available upon request
• Add on to existing BOEMRE regulations
• Must be model after RP75

6
SEMS Who does what?

• Lessee develops program
• Lessee or I3P audits program
• 2 years from the initial implementation of the
  SEMS program and at least once every 3 years
  thereafter
• Lessee notifies BOEMRE at least 30 days prior to
  conducting audit
• BOEMRE may participate in your audit
• Lessee submits audit report to BOEMRE w/in 30
  days of audit (includes deficiencies
  corrections)
• BOEMRE may conduct its own audit or evaluation of
  your SEMS

7
SEMS Audit Requirements?

• Operator can use either
• I3P or Designated and qualified personnel
• Comprehensive audit (13 elements)
• Audit plan - API RP 75 section 12.1 thru 12.4
• Submit plan to BOEMRE - 30 days before audit
• BOEMRE may modify facility audit list
• Submit audit findings/conclusion- 30 days after
  audit completion date
• Outline the results of audit
• Deficiencies identified
• Correction plan

8
SEMS Audit Requirements?

• Correction plan must identify
• Schedule to correct deficiencies
• BOEMRE notifies lessee w/in 14 days
• Person responsible with job title
• BOEMRE may do a follow-up to verify corrective
  actions have been undertaken

9
BOEMRE Directed Audits

• Lessee must hire I3P to conduct audit
• I3P must meet requirements listed in Subpart S
• I3P submits findings to BOEMRE within 30 days of
  audit
• Lessee responsible for all costs
• If BOEMRE conducts audit in lieu of I3P
• BOEMRE will provide lessee a report w/in 30 days
  of audit
• Lessee must submit corrective action plan within
  30 days of audit completion

10
Contractors

• Applies to contractors performing maintenance or
  repair, turnaround, major renovation, or
  specialty work
• Lessee responsibilities
• ensure contractors have the skills and knowledge
  to perform their assigned duties
• ensure that contractors have their own written
  safe policies and procedures.
• provide upon request the evaluation conducted to
  verify that contractors are skilled

These requirements do not apply to contractors
providing domestic services to the lessee or
other contractors. Domestic services include
janitorial work, food and beverage service,
laundry service, housekeeping, and similar
activities.
11
Contractor Selection

• Lessee SEMS program must have procedures in place
  for selecting and evaluating a contractor
• Lessee must make the following available to
  BOEMRE upon request
• Documentation
• Contract employees evaluation/verifications
• Contractors safety policy and procedures
• Contract employees expertise
• Can use Subpart O requirements for well control
  and production verification
• Contractor is not required to have a SEMS.

12
HAZARD ANALYSIS (HA)

• Facility level HA
• HA to be conducted by qualified personnel
• HA findings and recommendations need to be in a
  written report
• Task level JSA
• JSA to be conducted for each activity and be
  maintained on facility

13
MANAGEMNT OF CHANGE (MOC)

• Facility/MODU is subject to continual and
  temporary changes
• equipment, people, procedures
• Any of these changes can introduce new hazards to
  the operation which can impact safety

14
MOC TRIGGERS

• Equipment and Procedural Changes
• new equipment installation
• use of temporary cranes
• equipment modifications
• well stream changes
• Personnel Changes
• company mergers
• personnel vacancies, crew rotations
• contractor changes
• MOC should be written and include
• link to HA

15
OPERATING PROCEDURES

• Written procedures for each activity in your SEMS
  (lifting, drilling, production.)
• Address activities from start-up to shut down
• Changes in operating procedures need to be
  reviewed in context of your MOC
• Accessible to all affected employees
• Reviewed and updated as needed to keep current

16
MECHANICAL INTEGRITY

• Purpose assure equipment is designed, procured,
  tested, built, inspected, monitored maintained
  in a manner appropriate with service requirements
  and manufacturer recommendations

17
SEMS Rule II

• SEMS Proposed Rule may require operators to
  develop and implement
• stop work authority,
• ultimate work authority,
• employee participation program
• whistleblower protection

18
SEMS Rule II

• Additional requirements for conducting job safety
  analysis (JSA).
• Only I3P will conduct audits (not designated and
  qualified personnel)

19
SEMS Workshop

• 3/15/11 _at_ the Hilton New Orleans Riverside,
  Jefferson Ballroom, 3rd Floor
• Discuss SEMS Final Rule Requirements
• Discuss Frequently Asked Questions
• Will be announced in Federal Register in late
  January

20
What are the Operators doing to address SEMS ?

• Internal Gap analysis of current management
  systems vs SEMS
• API RP75 Audit Task Force (develop standardized
  SEMS audit tool)
• Revision of Standardized Safety Questionnaires
• Explore the following options
• Expand SafeGulf curriculum to include competency
  training
• Create SEMS qualifying programs similar to DOT OQ
  qualifying programs
• Add SEMS related questions to safety
  questionnaires

21
Proposed New SSQ Questions

• Does your company have a program to determine and
  document the competences for personnel?
• If yes, does it include
• a. Job classifications
• b. Required skill sets for each classification
• c. Required training for each classification
• 1. Operating procedures
• 2. Safe work practices
• 3. emergency response
• d. Fit for work requirements
• e. Methodology to determine competency

22
Proposed New SSQ Questions

• Does your company have a fully implemented HSE
  Management System (Safety Environmental
  Management Plan) appropriate for the services
  provided?
• If yes, does it include
• a. Is it certified by a third party
• b. Is it written to conform with an
  international standard
• 1. OSHAS 18,0012007
• 2. ANSI Z10
• 3. API RP 75
• 4. Other _____________

23
DISCUSSION - Open for Questions -
24
Contact Information

• Please Submit questions
• Email David.Nedorostek_at_boemre.gov
• Phone [phone]