The Bureau of Safety and Environmental Enforcement (BSEE) last week issued revised regulations for Safety and Environmental Management Systems (SEMS II) governing exploration, development, and production operations on the Outer Continental Shelf. SEMS II requires operators to (1) create procedures giving all personnel stop work authority, (2) establish who has the ultimate work authority on the facility for operational safety and decision-making, (3) promote the participation by employees and management in the mitigation or elimination of hazards, and (4) empower all personnel to report safety or environmental violations to BSEE. But the requirements in SEMS II most significant to the business of many operators are the new rules governing third-party audits and job safety analyses.
Third-Party Audit
Under the previous version of the regulations, audits could be conducted by designated and qualified personnel of the operator. But SEMS II now requires all audits to be conducted by "an accredited [Audit Service Provider (ASP)]," with an audit team lead who is wholly unaffiliated with the operator (although other team members can be employees of the operator). The ASP must be "accredited by a BSEE-approved Accreditation Body (AB)." Operators must comply with the new third-party audit requirements by June 5, 2015. Preparations for these audits will have to be performed much earlier.
Job Safety Analysis (JSA)
SEMS II adds new requirements to the job safety analysis that must be completed prior to work actually commencing. The new regulations specify that the immediate supervisor of the crew performing the job onsite must conduct and sign the JSA, and "ensure that all personnel participating in the job understand and sign the JSA." How the supervisor is to ensure understanding is not prescribed in the regulation. Further, the individual in charge of the facility must approve and sign all JSAs. And all personnel (including contractors) must be trained in implementing the JSA. SEMS II requires that "environmental hazards" and "environmental impacts" be included in the JSA's analysis. Operators must comply with the new JSA requirements by June 4, 2014.
Summary
The SEMS II requirements are not unexpected, but operators and contractors need to review their management systems to prepare for the third-party audits and to ensure that their operating procedures and pre-job JSA's and training are being properly implemented. How to accomplish those goals is generally undefined by SEMS II, but they nevertheless remain the duty of those working on the Outer Continental Shelf.
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