Transcript Document

Subpart S - SEMS
September 11, 2012
Prepared by: BSEE, Office of Safety Management
Author: Jason Mathews
www.bsee.gov
Thanks For The Opportunity
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Why was BSEE invited?
 Historical perspective, expectations & compliance
 Inform the support companies on their SEMS requirements
 Attempt to reduce any confusion/concern with SEMS
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SEMS is Good!
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Any Questions?
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Relevant Dates
DATE
10/15/10
EVENT
SEMS Final Rule Published
9/14/11
SEMS II NPR Published
11/14/11
SEMS II NPR Comment Period Closed
11/15/11
11/22/11
Mandatory Implementation of SEMS
SEMS PINCs are online
9/11/12
Zero BSEE Conducted Audits – 5 Independent
11/15/13
Initial Audits must be completed
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13 Elements
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.
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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 rightof-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.
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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.
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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.:
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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
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Performance Dashboard
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Other Possibilities
• Draft USCG ANPR
• Multiagency Stakeholder Meeting (EPA, BSEE, USCG, DOT,
PHMSA, BLM, BOEM)
• BSEE – USCG MOA
• SEMS III
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Subpart S – SEMS II Proposed Rule
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)
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
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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
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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
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Familiarize Yourself With This
Audit team members shall meet the following
requirements:
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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
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
Bureau of Safety and Environment Enforcement
1201 Elmwood Park Blvd.
New Orleans, LA 70123
September 11, 2012
www.bsee.gov