The SEMS II program procedures should ensure that records and documents are maintained for a period of 6 years, except as provided below. You should document and keep all SEMS II audits for 6 years and make them available to BSEE upon request. You should maintain a copy of all SEMS II program documents at an onshore location.
For JSAs, the person in charge of the job should document the results of the JSA in writing and should ensure that records are kept onsite for 30 days. In the case of a Mobile Offshore Drilling Unit (MODU), records should be kept onsite for 30 days or until you release the MODU, whichever comes first. You should retain these records for 2 years and make them available to BSEE upon request.
You should document and date all management of change provisions as specified in 250.1912. You should retain these records for 2 years and make them available to BSEE upon request.
You should keep the injury/illness log for 2 years and make them available to BSEE upon request.
You should keep all evaluations completed on contractor's safety policies and procedures for 2 years and make them available to BSEE upon request.
For Stop Work Authority (SWA), you should document all training and reviews required by 250.1930(e). You should ensure that these records are kept onsite for 30 days. In the case of a MODU, records should be kept onsite for 30 days or until you release the MODU, whichever comes first. You should retain these records for 2 years and make them available to BSEE upon request.
For Employee Participation Plans (EPP), you should document the employees' participation in the development and implementation of the SEMS II program. You should retain these records for 2 years and make them available to BSEE upon request.
You should submit Form BSEE-0131 on an annual basis by March 31st.
On the BSEE Form 0131, you should indicate the following:
The injury and illness data should be recorded for each of the following categories:
The form should be broken down quarterly, reporting the previous calendar year's data.
Click here to view the operation forms on the BSEE website.
The Stop Work Authority (SWA) procedures should ensure the capability to immediately stop work that is creating imminent risk or danger.
These procedures should grant all personnel the responsibility and authority, without fear of reprisal, to stop work or decline to perform an assigned task when an imminent risk or danger exists.
Imminent risk or danger means any condition, activity, or practice in the workplace that could reasonably be expected to cause:
The person in charge of the conducted work is responsible for ensuring the work is stopped in an orderly and safe manner. Individuals who receive a notification to stop work should comply with that direction immediately.
Work may be resumed when the individual on the facility with Ultimate Work Authority (UWA) determines that the imminent risk or danger does not exist or no longer exists.
The decision to resume activities should be documented in writing as soon as practicable.
You should include SWA procedures and expectations as a standard statement in all JSAs.
You should conduct training on the SWA procedures as part of orientations for all new personnel who perform activities on the Outer Continental Shelf (OCS).
Additionally, the SWA procedures should be reviewed during all meetings focusing on safety on facilities subject to the SEMS II rule.
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.
The SEMS II program should have a process to identify the individual with the UWA on the facility. You should designate this individual taking into account all applicable USCG regulations that deal with designating a person in charge of an OCS facility.
The SEMS II program should clearly define who is in charge at all times.
In the event that multiple facilities, including a MODU, are attached and working together or in close proximity to one another to perform an OCS operation, the SEMS II program should identify the individual with the UWA over the entire operation, including all facilities.
You should ensure that all personnel clearly know who has UWA and who is in charge of a specific operation or activity at all times, including when that responsibility shifts to a different individual.
The SEMS II program should provide that if an emergency occurs that creates an imminent risk or danger to the health or safety of an individual, the public, or to the environment, the individual with the UWA is authorized to pursue the most effective action necessary in that individual’s judgment for mitigating and abating the conditions or practices causing the emergency.
The management should consult with their employees on the development, implementation, and modification of the SEMS II program.
The management should develop a written plan of action regarding how the appropriate employees, in both the offices and hose working on offshore facilities, will participate in the SEMS II program development and implementation.
The management should ensure that employees have access to sections of the SEMS II program that are relevant to their jobs.
The SEMS II program should include procedures for all personnel to report unsafe working conditions in accordance with 250.193. These procedures should take into account applicable USCG reporting requirements for unsafe working conditions.
You should post a notice at the place of employment in a visible location frequently visited by personnel that contains the reporting information in 250.193.
Civil Penalties Highlight BSEE’s Commitment to Personnel Safety
Regulatory violations that pose a threat of serious, irreparable, or immediate harm or damage to life are always reviewed for potential civil penalties by a BSEE Reviewing Officer. One such violation was the subject of a civil penalty case that was closed and paid during the 2nd Quarter. In July 2011 during the course of an inspection, bureau inspectors discovered two open holes or fall hazards which posed a threat to the safety of personnel on the rig. The operator paid civil penalties in the amount of $50,000.
(BSEE Enforcement Newsletter, 2nd Qtr., FY 2012)
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