The SEMS II is a tool for integrating and managing operations. By developing a management system based on API RP 75, owners and operators are required to formulate policy and objectives concerning significant safety hazards and environmental impacts over which they had control and could be expected to have an influence.
Ultimately, a SEMS II program is intended to:
SEMS II regulations are the basic ground rules – the minimum standards which BSEE expect to be exceeded.
SEMS II builds on and enhances the original SEMS II rule by calling for:
The final rule expands, revises, and adds several new requirements to the existing 30 CFR part 250, 1900-1933, subpart S, regulations for SEMS. The additional safety requirements contained in SEMS II that were not covered in previous regulations include:
The SEMS II Rule becomes effective on June 4, 2013. Operators have until June 4, 2014 to comply with the provisions of the SEMS II Rule, except for the auditing requirements. All SEMS II audits should be in compliance with the SEMS II Rule by June 4, 2015.
“Operators must apply these tools to their management processes.” BSEE will not dictate how that is accomplished – it is up to the operators to determine how to best apply the tools to their management systems and processes.” (Brian Salerno, Director, BSEE)
Yes! If the SEMS II rule applies to the company, you should develop, implement, and maintain a safety and environmental management system (SEMS) program.
The SEMS II program should address the 17 elements of an effective SEMS II (see below), American Petroleum Institute's Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities (API RP 75), and other requirements as identified in the rule.
The SEMS II Rule became effective on June 4, 2013. Operators have until June 4, 2014 to comply with the provisions of the SEMS II Rule, except for the auditing requirements. All SEMS II audits should be in compliance with the SEMS II Rule by June 4, 2015. .
The goal of the SEMS II program is to promote safety and environmental protection by ensuring all personnel aboard an offshore facility on the Outer Continental Shelf (OCS) are complying with the policies and procedures identified in the SEMS II..
To accomplish this goal, management should ensure that the SEMS II program identifies, addresses, and manages safety, environmental hazards, and impacts during:
You should have a written and properly documented SEMS II program in place.
The SEMS II regulation should be applied in a risk-based, fit-for-purpose manner that differentiates between facilities. The operator currently has the ability to adjust the content of the program based on the hazard analysis of specific facilities.
You should also make it available to the BSEE upon request.
AB: Accreditation Body
ASP: Audit Service Provider
BAST: best available and safest technologies
CAP: Corrective Action Plan
COS: Center for Offshore Safety
EPP: Employee Participation Plan
ISO: International Organization for Standardization
JSA:Job Safety Analysis, (Also called a Job Hazard Analysis)
MODU: Mobile Offshore Drilling Unit
OCS: Outer Continental Shelf
SEMS: Safety and Environmental Management Systems
SWA: Stop Work Authority
USCG: United States Coast Guard
UWA: Ultimate Work Authority
Terms used in the SEMS II rule are listed alphabetically as follows:
Accreditation body(AB): a BSEE-approved independent third-party organization that assesses and accredits ASPs
Audit service provider (ASP): an independent third-party organization that demonstrates competence to conduct SEMS II audits in accordance with the requirements of the SEMS II rule
Corrective action plan(CAP): a scheduled plan to correct deficiencies identified during an audit and that is developed by an operator following the issuance of an audit report Personnel: direct employee(s) of the operator and contracted workers
Ultimate Work Authority (UWA): the authority assigned to an individual or position to make final decisions relating to activities and operations on the facility
Bureau of Ocean Energy Management (BOEM): responsible for managing environmentally and economically responsible development of the nation’s offshore resources. BOEM functions include leasing, plan administration, environmental studies, National Environmental Policy Act (NEPA) analysis, resource evaluation, economic analysis and the renewable energy program. (For more information see www.boem.gov)
BOEMRE means the Bureau of Ocean Energy Management, Regulation and Enforcement. Note: On October 1, 2011, the Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE), formerly the Minerals Management Service (MMS), was replaced by the Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE) as part of a major reorganization.
BSEE means Bureau of Safety and Environmental Enforcement and is responsible for safety and environmental oversight of offshore oil and gas operations, including permitting and inspections, of offshore oil and gas operations.
BSEE is involved in the approval of oil and gas plans, facilities, and operations. The process includes reviews where there is much emphasis on design, operations, and maintenance.
While BSEE monitors compliance with the regulations throughout the permitting process and operations, nothing compares to having BSEE personnel in the field to ensure operators are complying with the regulations.
Throughout the drilling and production phases, the BSEE inspects the operations to ensure compliance with regulations, lease terms and statutes. This further ensures operational safety and pollution prevention. It also requires that drilling personnel be trained in well control.
On average in recent years on the Federal OCS, the BSEE has conducted between 20,000 and 25,000 inspections annually. For more information see www.bsee.gov.
COS means Center for Offshore Safety. The Center for Offshore Safety (COS) is an industry sponsored organization focused exclusively on offshore safety in the deep water (water depths>1000 ft.) Gulf of Mexico. The Center serves the US offshore oil & gas industry with the purpose of adopting standards of excellence to ensure continuous improvement in safety and offshore operational integrity. For more information see http://www.centerforoffshoresafety.org/.
Imminent risk or danger means any condition, activity, or practice in the workplace that could reasonably be expected to cause, death or serious physical harm; or significant environmental harm to land, air, mineral deposits, marine or coastal environment, or human environment.
Incident of Noncompliance (INC) – If an inspector finds a violation of BSEE regulations as they are outlined in the PINC checklists, the Bureau Inspector issues an Incident of Noncompliance (INC) citation to the operator. Depending on the severity of the violation, the inspector can declare either a Warning or Shut-In INC.
Potential Incident of Noncompliance (PINC) – Checklist items which BSEE inspects to pursue safe operations on the Outer Continental Shelf. This list of inspection items is derived from all regulations for safety and environmental standards.
Stop Work Authority (SWA) means the authority given to all workers to immediately stop work that is creating imminent risk or danger to worker safety or the environment.
Ultimate Work Authority (UWA) means the authority assigned to an individual on the facility to make the final or ultimate decision to stop work or take action taking into account all applicable regulations.
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