You should ensure that a facility-level hazards analysis and a task-level Job Safety Analysis (JSA) is developed and implemented for all of the facilities and activities identified or discussed in the SEMS II.
You should document and maintain a current JSA for each identified or discussed operation for the life of the operation at the facility.
You should update the analysis when an internal audit is conducted to ensure that it is consistent with the facility’s current operations.
Excerpt from BSEE Safety Alert No. 22 - February 28, 2014
Hydrogen Sulfide (H2S) Gas Release from Piping Corrosion Failure Near a Weld
A hydrogen sulfide (H2S) gas release occurred from a piping corrosion failure near a weld, on the 8-inch side of an 8-inch by 4-inch reducer on the blowdown line for a third-stage section compression scrubber. Multiple H2S sensors detected the release and initiated a platform shutdown. Platform personnel were directed to muster to the safe briefing areas. Response personnel using breathing apparatus isolated the leak. No injuries to any personnel occurred from the incident. Prior to the platform being restarted, the failed spool was removed and saved for testing, and a new spool was installed. The H2S concentration at the release point was estimated to be 40,000 ppm.
For a facility-level hazards analysis, the analysis should be appropriate for the complexity of the operation and should identify, evaluate, and manage the hazards involved in the operation.
The facility-level hazards analysis should address the following:
The hazards analysis should be performed by a person(s) with experience in the operations being evaluated. These individuals also need to be experienced in the hazards analysis methodologies being employed.
You should assure that the recommendations in the hazards analysis are resolved and that the resolution is documented.
A single facility-level hazards analysis can be performed to fulfill the requirements for simple and nearly identical facilities, such as well jackets and single well caissons. You can apply this single hazards analysis to simple and nearly identical facilities after you verify that any site-specific deviations are addressed in each of the SEMS II program elements.
You should ensure a JSA is prepared, conducted, and approved for OCS activities that are identified or discussed in the SEMS II program.
The JSA is a technique used to identify risks to personnel associated with their job activities. They are also used to determine the appropriate mitigation measures needed to reduce job risks to personnel. The JSA should include all personnel involved with the job activity.
You should keep a copy of the most recent JSA at the job site and it should be readily accessible to employees.
You should ensure that the JSA identifies, analyzes, and records:
The immediate supervisor of the crew performing the job onsite should conduct the JSA, sign the JSA, and ensure that all personnel participating in the job understand and sign the JSA.
The individual designated as being in charge of the facility should approve and sign all JSAs before personnel start the job.
If a particular job is conducted on a recurring basis, and if the parameters of these recurring jobs do not change, then the person in charge of the job may decide that a JSA for each individual job is not required. The parameters you should consider in making this determination include, but are not limited to, changes in personnel, procedures, equipment, and environmental conditions associated with the job.
All personnel, which includes contractors, should be trained in accordance with the requirements of 250.1915.
You should also verify (in writing) that contractors are trained in accordance with 250.1915 prior to performing a job.
Management of Change (MOC) is a best practice used to ensure that safety, health and environmental risks are controlled when a company makes changes in their facilities, documentation, personnel, or operations.
When decisions and changes are made rapidly, safety and health risks can increase resulting in disasters. There are many examples of how even simple changes at a worksite have led to tragedy.
You should develop and implement written management of change procedures for modifications associated with the following:
Management of change procedures do not apply to situations involving replacement in kind (such as, replacement of one component by another component with the same performance capabilities).
You should review all changes prior to their implementation.
The following items should be included in the management of change procedures:
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