5/8/2014 SEMS Fact Sheet | BSEE

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SEMS FACT SHEET

Safety and Environmental Management Systems (SEMS) Fact Sheet

Revisions to SEMS Final Rule (SEMS II)

The SEMS II final rule enhances the original SEMS rule, also known as the Workplace Safety Rule, that was issued in October 2010, providing greater protection by

supplementing operators' SEMS programs with employee training, empowering field level personnel with safety management decisions and strengthening auditing

procedures by requiring them to be completed by independent third parties.

The original Workplace Safety Rule covered all offshore oil and gas operations in federal waters and made mandatory the previously voluntary practices in the

American Petroleum Institute's (API) Recommended Practice 75 (RP 75). Having a mandatory oil and gas SEMS program enhances the safety and environmental

protection of offshore oil and gas drilling operations.

The SEMS II final rule expands, revises, and adds several new requirements to the existing 30 CFR part 250, subpart S, regulations for SEMS. These revisions were

based on the comments received from the Notice of Proposed Rulemaking which published in the Federal Register on September 14, 2011. Operators will integrate

these new requirements into their existing SEMS program, providing several key ways for personnel to help ensure safe performance of offshore oil and gas activities.

The additional safety requirements contained in this final rule that were not covered in previous regulations include:

Developing and implementing a stop workauthority that createsproceduresand authorizesany and all offshore industry personnel who witnessan imminent riskor dangerousactivity to stop work.

Developing and implementing an ultimate workauthority that requiresoffshore industry operators to clearly define who has the ultimate workauthority on a facility for operational safety and decisionmaking at any given time.

Requiring an employee participation plan that providesan environment that promotesparticipation by offshore industry employeesas well as their management to eliminate or mitigate safety hazards.

Establishing guidelines for reporting unsafe working conditions that enable offshore industry personnel to report possible violationsof safety, environmental regulations requirements, and threatsof danger

directly to BSEE.

Establishing additional requirements for conducting a job safety analysis.

Requiring that the team lead for an audit be independent and represent an accredited audit service provider.

The elements of RP 75 that the Workplace Safety Rule originally made mandatory were as follows:

General provisions: for implementation, planning and management review and approval of the SEMS program.

Safety and environmental information: safety and environmental information needed for any facility, e.g. design data; facility process such as flow diagrams; mechanical components such aspiping and

instrument diagrams; etc.

Hazardsanalysis: a facility-level riskassessment.

Management of change: program for addressing any facility or operational changes including management changes, shift changes, contractor changes, etc.

Operating procedures: evaluation of operationsand written procedures.

Safe workpractices: manuals, standards, rulesof conduct, etc.

Training: safe workpractices, technical training - includes contractors.

Mechanical integrity: preventive maintenance programs, quality control.

Pre-startup review: review of all systems.

Emergency response and control: emergency evacuation plans, oil spill contingency plans, etc.; in place and validated by drills.

Investigation of Incidents: procedures for investigating incidents, corrective action and follow-up.

Audits: rule strengthens RP 75 provisionsby requiring an initial audit within the first two yearsof implementation and additional audits in three year intervals.

Recordsand documentation: documentation required that describesall elementsof the SEMS program.

The Workplace Safety Rule became effective on November 15, 2010. Operators were required to implement a SEMS program by November 15, 2011 and must still

submit their first completed SEMS audit to BSEE by November 15, 2013. The SEMS II Rule became effective on June 4, 2013. Operators have until June 4, 2014 to

comply with the provisions of the SEMS II Rule, except for the auditing requirements. All SEMS audits must be in compliance with the SEMS II Rule by June 4, 2015.