SEMS
1. Introduction – Scope
2. Operator Specific Safety Requirements
3. Training Course Examples
4. Contractor Selection Process
5. Work Performance
6. Management of Change
7. Evaluating Contractor HSE Performance
SEMS - Introduction
SEMS (Safety Environmental Management System) is derived from
an Industry Standard and Practice (API RP 75) and implemented as
regulation in 30 CFR 250 Subpart S.
Many oil and gas exploration and production companies contract
for equipment and personnel services for a wide range of
activities, including drilling, production, well servicing, equipment
repair, maintenance, and construction.
Certain activities of contractors have the potential to place either
the contractor and/or the operator personnel or equipment at
risk. As a result, it is important that operations are carried out in a
safe manner.
SEMS - Introduction
Commitment
Both operator and contractor management commitments are
essential in minimizing accidents/incidents and preventing injury
and illness. Management commitment begins with the operator
and contractor providing the resources necessary for
implementing and maintaining an effective safety program.
Operator and contractor commitments and continued support is
common to all successful safety programs. Effective programs will
require the operator and contractor to:
• Focus resources on safety, and
• Review how contractor safety is being addressed
SEMS - Introduction
Benefits
Operators and contractors benefit when they work together to
enhance the management of related safety programs. These
benefits may include:
• Safety expectations and capabilities are clearly understood
before the work begins
• Improved safety performance
• Better working relationships
• Improved safety training for everyone
• Improved productivity, reliability and efficiency
SEMS - Introduction
Third Parties, Subcontractors, and Vendors
Frequently, third party, subcontractors and vendors are utilized to
perform specialized portions of work projects. In addition, parts
and equipment may be used.
As a result, they are subject to applicable elements of the
operator SEMS Plan or contractor SEMS Policy.
Most SEMS Plans or Policies outline provisions for inspections and
audits of the relevant third party, subcontractor or vendor
services and equipment.
SEMS - Introduction
The Elements within SEMS
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General Provisions
Safety and Environmental Information
Hazards Analysis
Management of Change
Operating Procedures
Safe Work Practices
Training
Mechanical Integrity
Pre Startup Review
Emergency Response and Control
Investigation of Incidents
Audit of Safety and Environmental Systems
Records and Documentation
SEMS - Introduction
In addition, an update has been proposed to include the following
(SEMS II)
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A Stop Work provision
Definition of authority
Employee participation
Reporting unsafe conditions
The use of independent third party auditors
Additional requirements for Job Safety Analysis
It is anticipated that the new rule will come into effect in the fourth
quarter of 2012.
SEMS – Operator Safety Requirements
After determining the type of work to be performed by a contractor, the
operator should identify the safety requirements and communicate
them to the contractor. These requirements may be broad, or general in
certain cases, or very specific in others, depending on the work
assignment. Certain contractors (such as those specializing in leak repair
or working with radioactive sources) may have more experience and
knowledge relevant to the hazards involved and should be consulted in
order to establish mutually agreeable and relevant safety procedures.
Contractors should consider developing their own safety procedures or
programs. In many cases, contractors are used because of their
expertise, knowledge of anticipated hazards, and special safety
requirements associated with the work. In these instances, a
determination must be made as to which individual or company will
have primary responsibility for implementing additional safety
requirements applicable to their specialty. These must be consistent
with operational and regulatory requirements (SEMS).
SEMS – Operator Safety Requirements
Training
Contractors have the responsibility to provide appropriate information
and training to ensure that their employees have adequate knowledge
and skills to perform their job safely. The contractor is generally
responsible for providing safety and job-specific training for its
employees unless otherwise stated in a contract or other agreement.
Upon final review of the scope of work, operators and contractors may
identify any site or job-specific training that is necessary to perform the
work safely and agree on how this will be accomplished.
Additionally, other considerations include, but may not be limited to:
• Short Service Employee Programs
• Sample Training Matrix
SEMS – Operator Safety Requirements
Training Course Examples (as cited in API RP 76)
SafeGulf
Ergonomics
Housekeeping
Access to Medical Records
Excavation Safety
Incident Prevention
Bloodborne Pathogens
Fall Protection
Incident Reporting
Confined Space
Fire Prevention/Fire Fighting
JSA Training
Drug & Alcohol Awareness
First Aid/CPR
Lock Out/Tag Out
Electrical Safety
Hand Tools
Material Handling
Emergency Action Plan
Hazard Communication
New Employee Orientation
Environmental Awareness
Hearing Conservation
Water Survival
SEMS – Operator Safety Requirements
Verification of Training
It is important for the contractor to maintain records of training
and make them available to the operator upon request. The
contractor should consider periodically reviewing training
schedules and materials to verify that they are current. The
contractor should maintain training documentation in a way that
is easily retrievable. Additionally, contractor personnel may need
to carry certain training credentials as required by regulation or
the operator.
SEMS – Operator Safety Requirements
Communication
Operators and contractors are responsible for communicating the
appropriate information regarding workplace hazards and safety
requirements to their employees. The communication of this
information may include many formats such as an orientation
program, job safety analyses (JSA), safety meetings, pre-job
meetings, training, Material Safety Data Sheets (MSDS), safe work
permits, signs, posters, procedures, or other written materials.
SEMS – Operator Safety Requirements
JSA and Safety Meetings
Operators and contractors may consider conducting Job Safety Analyses
(JSA), safety observations, and regularly scheduled safety meetings to
provide on-going training and communication of safety issues.
Additionally, a safety awareness or behavior based program may be
beneficial. Subcontractors and other third party are usually required to
attend all applicable safety meetings.
Personnel New to Work Site
All personnel new to the work site will be made aware of the job and
specific site safety requirements, including emergency training, as
applicable
SEMS – Contractor Selection Process
A major step in achieving acceptable contractor safety performance is
selecting a qualified and responsible contractor. Therefore, it is necessary for
operators to request that contractors submit safety and training information
in their contract response proposals.
Such information might include:
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A review of the contractor’s written safety and environmental polices and
practices endorsed by the contractor’s top level management
A statement of commitment by the contractor to comply with all applicable
health, safety, and environmental regulations and provisions of SEMS.
Injury and illness experience for the previous three years
Outline of the initial employee safety orientation
Descriptions of various safety programs including substance abuse prevention
and testing
Training programs including refresher
Short Service Employee programs
Completion of the standard safety questionnaire
SEMS – Operator Safety Requirements
Bid Package (Bridging Document)
An operator should inform a contractor of its safety expectations by clearly
outlining its safety performance requirements in one or more ways. Several
methods used are Request for Proposals, Master Service Agreements (MSA),
or Bid Packages. In addition to these methods, SEMS requires a bridging
document that may be separate.
Safety Questionnaire
Operators and contractors may use a Standard Safety Questionnaire or a
portion of it to determine whether a contractor’s safety qualifications are
adequate for performing the involved scope of work. Major sections of the
safety questionnaire may include:
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General Information
Organization
Safety Performance
Safety Programs and Procedures
Training
Safety Coordination
SEMS – Work Performance
It’s important for the operator and contractor to understand their
individual responsibilities during the planning, performance, and
completion stages of work. As part of the process, the operator may
notify the contractor where safety requirements are not being met, but
it is usually the responsibility of the contractor, not the operator, to
communicate to contractor employees the steps that should be taken to
correct any deficiencies.
Before work is commenced, the operator should identify and present to
the contractor relevant safety rules required. All or part of this
information may be used in the safety orientation and safety meetings
by the operator or contractor.
SEMS – Management of Change
Managing change is critical to preventing incidents and controlling loss.
The operator and contractor should have a management of change
(MOC) process that establishes procedures to identify and control
hazards associated with change. The procedures should maintain the
consistency of safety processes related to the change. On occasion,
temporary repairs, connections, bypasses, or other modifications may
be made for operational necessity. (Work Around or Business Continuity)
Any of these changes can introduce new hazards or compromise the
safeguards built into the original design. Care must be taken to
understand the cause and effect of operational, personnel safety and
environmental implications of any changes. Although some changes may
be minor with the small chance of compromising safety or
environmental protection, many changes may have the potential for
disruption, injury, or business loss.
SEMS – Management of Change
Change in Facilities
Change at drilling, well servicing and production sites arise whenever
the operations or mechanical design is substantively altered. Change
may also occur as a result of changes in produced fluids, well servicing
fluids, drilling fluids, by-products or waste products, design inventories,
instrumentation and control systems, or materials of construction. In
many instances, these changes are deemed minor and do not require
specific procedures.
Typical instances where change would likely occur include:
• Construction of new production or process facilities
• New facility projects that involve production or process tie-ins to
existing facilities, equipment reconfiguration, or modification of
existing facilities or equipment
• Modification of existing facilities that result in changes to facility or
equipment design, structural support, layout or configuration
SEMS – Management of Change
Change in Facilities
Typical instances where change would likely occur – continued:
• Projects to increase facility throughput or accommodate different
produced fluids
• Significant changes in operating conditions, including pressures,
temperatures, flow rates, or process conditions different from those
in the original process or mechanical design
• Equipment changes, including the addition of new equipment or
modifications of existing equipment. These can include changes in
alarms, instrumentation, and control schemes
• Modifications of the process or equipment that cause changes in the
facility’s pressure relief instruments.
• Bypass connections around equipment that is normally in service
• Operations outside the scope of current written operating
procedures (start-up, normal & emergency shutdown)
SEMS – Management of Change
Change in Facilities
Typical instances where change would likely occur (continued):
• Changes made in the mechanical design or in operating procedures
that result from the completion of a hazards analysis
• Introduction of new or different chemicals, drilling muds or workover
completion fluids
• Change in facilities may include mechanical changes that would
necessarily appear on a instrument diagram, including drilling and
construction equipment, temporary connections, or replaced
components that are “not in –kind,” such as1. Replacement equipment or machinery that differs in specifications from
the original equipment or previously approved modification
2. Temporary piping, connections, pipe repairs, hoses
3. Alternate supply of materials, catalysts, or reactants
4. Temporary electrical equipment or utility connections, other than
emergency situations
SEMS – Management of Change
Change in Facilities
Typical instances where change would likely occur (continued):
• Change in facilities may include mechanical changes that would
necessarily appear on a instrument diagram, including drilling and
construction equipment, temporary connections, or replaced
components that are “not in –kind,” such as- (continued)
5. Substantial changes to drilling diverter system design
6. Substantial changes to blowout preventers (BOPs) configuration
7. Substantial changes to top drives or other drilling systems
SEMS – Management of Change
Change in Personnel
Change in personnel, including contractor personnel, occurs whenever
there is a change in the organization or in personnel that operate the
facility. Routine personnel replacements, rotation, and shift changes
should be addressed in operating procedures, safe work practices and
training, therefore should not require additional management of change
action.
Organizational changes, particularly those brought about by the
acquisition or sale of a facility, may necessitate a thorough review of the
HSE management system.
Change in Regulations or Industry Recommended Practices
Change in regulations or industry recommended practices can occur
when legislators, regulators, and industry groups create, adopt, or
modify rules governing activities or operations. Routine review of these
laws, rules or practices are warranted . When changes occur, an
assessment of the impact and implementation may be needed.
SEMS – Management of Change
Managing the Change
Management systems should establish and implement written
procedures to manage change. These procedures should be flexible to
accommodate both major and minor changes. Minor changes generally
do not require specific procedures. Written procedures should cover the
following:
• The operations and mechanical design basis for the proposed change
• Analysis of HSE considerations involved in the proposed change
• Necessary revisions of the operating procedures, safe work practices,
and training program
• Communication of change and consequences to the appropriate
personnel
• Necessary revisions of HSE practices and procedures
• Duration of change, if temporary
• Required authorizations to effect the change, if applicable
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SEMS – Evaluating Contractor HSE Performance
The operator and contractor each have roles in monitoring and
evaluating HSE performance.
Safety Performance Reporting
All injuries, illnesses and property damage incidents associated with the
on-site work should be reported to both contractor and operator as
soon as possible. Recording should be done in accordance with
applicable requirements for occupational injuries and illnesses. The
contractor and operator should identify the mechanism and personnel
to forward and receive reports as appropriate.
Operator Reviews
The operator will periodically review the contractor’s HSE programs,
polices and procedures, including questionnaire information, and
request that they be updated
Contractor Inspections/Audits
Contractors should conduct periodic internal reviews, consistent with
their procedures. Operators may also perform audits to verify
conformance.
SEMS
Safety Environmental Management System
References:
30 CFR 250 Subpart S
API RP 75
API RP 76
QUESTIONS?