SEMS Final Rule - Greater Houston STEPS Network
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Transcript SEMS Final Rule - Greater Houston STEPS Network
GOM Contractor Expectations
Julia Swindle - IADC
Our focus is on the operator/contractor
relationship and meeting the associated SEMS
requirements. Our subcommittees are:
Contractor Guidance – Troy Nugent – Baker Hughes
Competence/Knowledge and Skills – Brenda Kelly -IADC
Training and Certifications – Milton Bell – Exxon ,
and Achebe Hope - Chevron
Documents and Data – Bill Walker - Cobalt
SEMS Final Rule
Published Oct. 15, 2010
Effective Nov 15, 2010
Fully Implemented by
Nov. 15, 2011
API RP 75 – Third
Addition
30 CFR Part 250 Sub “S”
SEMS
Implemented in 1994 as a
voluntary program
Developed by the API at
the request of the MMS
and response to OSHA
1910.119
Developed in conjunction
with the OOC, IADC,
NOIA and the MMS
Per §250.1900( c ) "If there are conflicts
between the requirements of this subpart
and API RP 75 (incorporated by reference
as specified in §250.198), you must follow
the requirements of this subpart."
“[The regulation] does not
require contractors to develop
a [SEMS]. However,
contractors should be familiar
with the operator’s [SEMS]
and should have safety and
environmental policies and
practices that are consistent
with the Operator’s [SEMS].”
Safety & Environmental
Information
Hazard Analysis
Management of Change
Operating Procedures
Safe Work Practices
Training
Assurance of Quality
and Mechanical
Integrity of Critical
Equipment
Pre-Start Up Review
Emergency Response
Investigation of
Incidents
Audits
Recordkeeping
“When selecting a contractor [the operator] must obtain
and evaluate information regarding the contractor’s
safety and environmental performance.”
Contractor personnel must know and understand the
operator’s SEMS
The operator and contractor must document their
agreement on …[HSE]
The operator must document that contractors have the
“skills and knowledge” to perform their assigned duties.
Brenda Kelly, Chair
Reviewed regulation for training and
competency requirements
Determined personnel “competency” not
stated as requirement
REQUIRES:
Training
Verification of knowledge and skills
Documentation of training, instructor
qualifications, assessor qualifications, and
individual assessments
Part 250 - Oil & Gas & Sulphur Operations
in OCS - Subpart S (SEMS)
SEMS and API RP 75 Audit Checklist
Owner
Citation Ref #
Must I have a SEMS program? (§250.1900 / API RP 75
section 1)
§250.1900
RP 75 1
Has a safety and environmental management system (SEMS)
been developed, implemented and maintained?
O*
Operator – implied for all program elements.
C = Contractor
Per §250.1914(a), a Contractor is defined as “anyone
performing work for the Lessee.”
Contractors may be expected to supply evidence of
compliance.
Written policy/procedure, design information, records,
etc.
FO = Facility/Rig Owner
Owners of facility/rig may carry larger burden for
evidence for some requirements.
Documentation
Document Type
Examples
Where
Retained
Retention Period
Train Personnel
Personnel to be
Trained
What Training
Type/Level of
Training Req'd
Evidence of
Knowledge
Retained
Prepare cover page & instructions for documents
Review Tools by SEMS Committee members
Prepare reference materials for Skills Assessment and
Assessor Qualifications
Revise IADC KSAs
Expand KSAs to all rig positions
Anticipate available by end of July
Obtain copy from operator or IADC website
http://www.iadc.org