GCEAG Meeting January 12, 2012
 NPR
Issued September 14, 2011
 Comments were due November 14, 2011
 Focuses on six new or expanded items
Stop work provision
Definition of authority
Employee participation
Reporting of unsafe work conditions
Use of independent third party auditors
Additional requirements of Job Safety Analyses

Stop Work Authority (SWA)
◦ Give responsibility and authority to stop any activity
that creates an imminent risk or danger to
individual, public or environment to all employees
and contractors for any BSEE regulated activity
 PIC of activity must ensure work is stopped (orderly
and safe manner)
 Person with ultimate work authority makes decision to
resume activities and documents his decision
◦ SWA Policy must be reviewed as part of all safety
meetings and JSAs
◦ Training and review records must be kept on the
facility for 30 days

Ultimate Work Authority (UWA)
◦ Identify one person on facility with final responsibility
for making decisions
◦ Everyone on facility must know this person by name
and be readily identifiable and accessible (post notice)
◦ Assumes key role in assuring SEMS program is
implemented
◦ In emergency, UWA is authorized to pursue action to
mitigate and abate conditions
Employee Participation
 Requires management to:
◦ Consult with employees (office and field) on the
development and implementation of company's SEMS
program
◦ Develop action plan outlining how employees will
participate in development and implementation of
program
 Each employee and contractor employee required to have
access to SEMS program and other API RP 75 info
Reporting Unsafe Work Conditions
 Procedures for all personnel to report unsafe
work conditions
◦ In writing or by telephone to a BSEE hotline
◦ Must contain sufficient credible information for
BSEE to determine that legal or regulatory violations
have occurred or that an unsafe working conditions
exist
◦ Include USCG unsafe working conditions reporting
requirements

Reporting Unsafe Work Conditions
◦ Post a notice explaining personnel rights and remedies
◦ Train personnel on the unsafe work conditions policy
 Within 30 days of employment
 Every 12 months thereafter
◦ Provide each person with the BSEE hotline number
Job Safety Analysis – Additional Requirements
◦ JSAs must be developed and implemented for each
BSEE-regulated activity identified in SEMS program
 Immediate supervisor:
 Prepares and signs JSA
 Ensures all personnel participating in job sign JSA
 Onsite PIC of facility:
 Approves, signs and documents results of JSA
 Conduct training for all personnel on how to recognize
and identify hazards
 w/n 30 days of employment
 Every 12 months thereafter


Auditing Requirements
Requires SEMS programs to be audited
◦ An independent third party must perform the audit
◦ Requires BSEE approval of the third party auditor
◦ Nominate the third party auditor in writing at least
30 days prior to the audit
 Identify the individual
 Describe specific qualifications
 Include a statement by the management that the
nominated auditor is "not owned or controlled by, or
otherwise affiliated with, the operator's company"
Training must address:
 Operating procedures
 Safe work practices
 Emergency response and control measures
You must document the qualifications of
your instructors
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Your SEMS program must address:
 (a) Initial training:
◦ For the basic well-being of personnel and
protection of the environment
◦ Ensure persons assigned to operate and maintain
the facility possess the required knowledge and
skills to carry out their duties and responsibilities,
including startup and shutdown

Periodic training to maintain understanding
of, and adherence to, the current operating
procedures, using periodic drills, to verify
adequate retention of the required knowledge
and skills.

Communication requirements to ensure that
whenever a change is made to operating
procedures, the safe work practices, or the
emergency response and control measures,
personnel will be trained in or otherwise
informed of the change before they are
expected to operate the facility

How you will verify that the contractors are
trained in the work practices necessary to
perform their jobs in a safe and
environmentally sound manner, including
training on operating procedures
(§250.1913), the safe work practices
(§250.1914), or the emergency response and
control measures (§250.1918).
Safety and Environmental Management Systems
Potential Incident of Noncompliance (PINC) List
63 New PINCs
From Warnings to Shut-ins

General Element
◦ Management’s General Responsibilities
◦ Three PINCs

Safety & Environmental Information
◦ Three PINCs

Environmental
◦ Twelve PINCs!

Hazards Analysis
◦ Four PINCs

Management of Change
◦ Four PINCs

Operating Procedures
◦ Two PINCs

Safe Work Practices
◦ Nine PINCs

Training
◦ Three PINCs

Assurance of Quality and Mechanical Integrity
of Critical Equipment
◦ Five PINCs

Pre-Startup Review
◦ One PINC

Emergency Response and Control
◦ Two PINCs

Investigation of Incidents
◦ Three PINCs

Audit of SEMS Elements
◦ Six PINCs

Records and Documentation
◦ Six PINCs

Contact us:
Jodie Connor, Ken Smith or Rebekka Milton
281.578.3388
Jodie.connor@jccteam.com
Ken.smith@jccteam.com
Rebekka.milton@jccteam.com