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Subpart S - SEMS

Subpart S - SEMS. September 11, 2012 Prepared by: BSEE, Office of Safety Management. Author: Jason Mathews. www.bsee.gov. Thanks For The Opportunity. Why was BSEE invited?. Historical  perspective, expectations & compliance Inform the support companies on their SEMS requirements

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Subpart S - SEMS

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  1. Subpart S - SEMS September 11, 2012 Prepared by: BSEE, Office of Safety Management Author: Jason Mathews www.bsee.gov

  2. Thanks For The Opportunity

  3. Why was BSEE invited? Historical perspective, expectations & compliance Inform the support companies on their SEMS requirements Attempt to reduce any confusion/concern with SEMS

  4. SEMS is Good!

  5. Any Questions?

  6. Relevant Dates

  7. 13 Elements

  8. Key Point 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.

  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 Obligations 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.

  11. Are you in the clear? • 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

  12. Performance Dashboard

  13. Other Possibilities • Draft USCG ANPR • Multiagency Stakeholder Meeting (EPA, BSEE, USCG, DOT, PHMSA, BLM, BOEM) • BSEE – USCG MOA • SEMS III

  14. Subpart S – SEMS II Proposed Rule

  15. SEMS II NPR Comments • 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)

  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

  20. Summary 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

  21. Bureau of Safety and Environment Enforcement1201 Elmwood Park Blvd.New Orleans, LA 70123 September 11, 2012 www.bsee.gov

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