Management should ensure that the program elements discussed in API RP 75 and in the SEMS II rule are properly documented and are available at field and office locations, as appropriate for each program element. See BSEE-0131 Performance Measurement Data form.
Management should develop, support, and continually improve the overall success of the SEMS II program by doing the following:
Establish goals, objectives and performance measures, demand accountability for implementation, and provide necessary resources for carrying out an effective SEMS II program. Be sure that the following information is included:
Appoint management representatives who are responsible for establishing, implementing and maintaining an effective SEMS II program.
Designate specific management representatives who are responsible for establishing, implementing, maintaining, and reporting to management on the performance of the SEMS II program.
Review the SEMS II program at specified intervals and at least annually, to determine if it continues to be suitable, adequate and effective by addressing:
Develop and endorse written safety and environmental policies and organizational structure that define responsibilities, authorities, and lines of communication required to implement the SEMS II program.
Use personnel with expertise in:
Ensure that facilities are designed, constructed, maintained, monitored, and operated in a manner compatible with applicable industry codes, consensus standards, and generally accepted practice as well as in compliance with all applicable governmental regulations.
Ensure that management of safety hazards and environmental impacts is an integral part of the design, construction, maintenance, operation, and monitoring of each facility.
Ensure that suitably trained and qualified personnel are employed to carry out all aspects of the SEMS II program.
Ensure that the SEMS II program is maintained and kept up to date by means of periodic audits to ensure effective performance.
BSEE director Jim Watson believes an effective SEMS II Safety Culture Policy Statement is at the core of an offshore operations safety culture, at all times, because every offshore operation – no matter when or where it is performed – carries with it some degree of risk.
The following are the nine characteristics of a robust SEMS II safety culture:
So what do we mean by “safety culture” and how should we measure “safety?” Is it merely the absence of accidents? Is it compliance with regulations? Is it how you approach complex activities? I believe it is how you approach risk. How do you balance risk to the employees and the environment with the need to stay on schedule, to complete the well, or to start production? It goes far beyond management decisions. How do the people approach risk? Are they afraid to speak up when they see something wrong? Will they immediately halt operations if their colleagues are in danger? Or, do they only pay attention to the missing handrail when they see the helicopter with a BSEE inspector approaching their facility? How much risk – to themselves – are they willing to accept? (Brian Salerno, Director, BSEE)
You should require that SEMS II program safety and environmental information be developed and maintained for any facility that is subject to the SEMS II program.
SEMS II program safety and environmental information should include:
The SEMS II program should meet the minimum criteria outlined in the SEMS II rule, including the following SEMS II program elements:
We will cover each of the above program elements in this course.
Make sure you include a job safety analysis (JSA) for OCS activities identified or discussed in the SEMS II program (see 250.1911).
Finally, the SEMS II program should meet or exceed the standards of safety and environmental protection of API RP 75.
The overarching mechanism used by an operator to develop and implement its SEMS II program provides avenues of flexibility, including the following:
BSEE believes there is no need to prescribe each aspect of an operator's SEMS II training program or how frequently an operator must conduct periodic training. The final regulatory text in 30 CFR 250.1915 is sufficient to cover the detailed training requirements for an operator's SEMS II programs. The introductory language establishes that all personnel must be trained to perform work safely. These changes allow operators to take responsibility for implementing their training in accordance with the regulations.
Also, SEMS II maintains performance flexibility as evidenced by the discretion the rule grants to operators to design, develop, and deploy their employee participation plan and stop work authority programs.
Safety is an element that is easier to measure when it is absent. When an accident occurs, it is easy to point to that and say, “they were not safe,” and you can then peel back the contributing factors and identify things that should have been visible before the accident. That is why we must proactively identify, quantify, and mitigate risk based on new, relevant data streams. Brian Salerno, Director, BSEE)
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