Published October 15, 2010
Background
The BOEMRE has issued a final rule that requires operators to develop and implement a Safety and Environmental Management System (SEMS) to address oil
and gas operations in the Outer Continental Shelf.
An Advanced Notice of Proposed Rulemaking (ANPR) was issued on May 22, 2006 because of an “identified need for performance improvement.”
A Notice of Proposed Rulemaking (NPR) was then released on June 17, 2009, based on industry and public feedback from the 2006 ANPR.
The Final Rule is effective on November 15, 2010. It requires full implementation of the thirteen SEMP elements of API RP 75 on or before
November 15, 2011.
The BOEMRE will enforce the SEMS requirements via audits. Therefore it is important to note that a comprehensive audit trail is vital for compliance.
General Considerations
The final rule applies to all OCS oil and gas and sulphur operations and the facilities under BOEMRE jurisdiction including drilling, production, construction,
well workover, well completion, well servicing, and DOI pipeline activities.
- Operators must submit Form MMS-131 on an annual basis beginning March 31, 2011
- Operators must ensure that their SEMS program identifies, addresses, and manages safety,
environmental hazards, and impacts during the design, construction, start-up, operation, inspection,
and maintenance of all new and existing facilities, including mobile offshore drilling units (MODU) while
under BOEMRE jurisdiction and Department of Interior (DOI) regulated pipelines
- All personnel involved with your SEMS program must be trained to have the skills and knowledge to perform their assigned duties
Management’s General Responsibilities for the SEMS Program
- Establish goals, performance measures, demand accountability for implementation, and provide necessary resources for an effective SEMS
- Appoint management representatives who are responsible for the SEMS program
- Designate specific management representatives who are responsible for reporting to management on the performance of the SEMS program
- At least annually, review the SEMS adequacy and effectiveness
- Develop and endorse a written description of your safety and environmental policies and organizational structure that define responsibilities,
authorities, and lines of communication
- Utilize personnel with SEMS expertise to manage your system
- Ensure that facilities are designed, constructed, maintained, monitored, and operated in a manner compatible with industry codes, consensus
standards, and all applicable governmental regulations
- Ensure that the SEMS is maintained and kept up to date via periodic audits
- Ensure that an initial hazards analysis is performed on each facility on or before November 15, 2011
Job Safety Analysis (JSA)
- You must develop and implement a JSA for OCS activities identified or discussed in your SEMS program
- You must keep a copy of the most recent JSA (operations/task level) at the job site and it must be readily accessible to employees
- Your JSA must identify, analyze, and record;
- the steps involved in performing a specific job;
- the existing or potential safety and health hazards associated with each step; and
- the recommended action(s)/procedure(s) that will eliminate or reduce these hazards and the risk of a workplace injury or illness
- The supervisor of the person in charge of the task must approve the JSA prior to the commencement of the work
SEMS Program Audits
- You must have your SEMS program audited by either an independent third-party or your designated and qualified personnel within 2 years of the initial implementation
of the SEMS program and at least once every 3 years thereafter
How will BOEMRE determine if my SEMS program is effective?
- BOEMRE or its authorized representative may evaluate or visit your facility to determine whether your SEMS program is in
place, addresses all required elements, and is effective in protecting the safety and health of workers, the environment, and
preventing incidents. BOEMRE or its authorized representative may evaluate your SEMS program, including documentation of
contractors, independent third parties, your designated and qualified personnel, and audit reports, to assess your SEMS
program. These evaluations or visits may be random or based upon the OCS lease operator’s or contractor’s performance.
- You must notify the BOEMRE at least 30 days prior to conducting your audit, so that BOEMRE may make arrangements to observe or
participate in the audit.
For further information contact
Ken Smith
(kenneth.smith@jccteam.com)
at (281) 578-3388
|