GOM Contractor Expectations
Julia Swindle - IADC

Our focus is on the operator/contractor
relationship and meeting the associated SEMS
requirements. Our subcommittees are:




Contractor Guidance – Troy Nugent – Baker Hughes
Competence/Knowledge and Skills – Brenda Kelly -IADC
Training and Certifications – Milton Bell – Exxon ,
and Achebe Hope - Chevron
Documents and Data – Bill Walker - Cobalt

SEMS Final Rule





Published Oct. 15, 2010
Effective Nov 15, 2010
Fully Implemented by
Nov. 15, 2011
API RP 75 – Third
Addition
30 CFR Part 250 Sub “S”
SEMS



Implemented in 1994 as a
voluntary program
Developed by the API at
the request of the MMS
and response to OSHA
1910.119
Developed in conjunction
with the OOC, IADC,
NOIA and the MMS
Per §250.1900( c ) "If there are conflicts
between the requirements of this subpart
and API RP 75 (incorporated by reference
as specified in §250.198), you must follow
the requirements of this subpart."

“[The regulation] does not
require contractors to develop
a [SEMS]. However,
contractors should be familiar
with the operator’s [SEMS]
and should have safety and
environmental policies and
practices that are consistent
with the Operator’s [SEMS].”






Safety & Environmental
Information
Hazard Analysis
Management of Change
Operating Procedures
Safe Work Practices
Training






Assurance of Quality
and Mechanical
Integrity of Critical
Equipment
Pre-Start Up Review
Emergency Response
Investigation of
Incidents
Audits
Recordkeeping




“When selecting a contractor [the operator] must obtain
and evaluate information regarding the contractor’s
safety and environmental performance.”
Contractor personnel must know and understand the
operator’s SEMS
The operator and contractor must document their
agreement on …[HSE]
The operator must document that contractors have the
“skills and knowledge” to perform their assigned duties.
Brenda Kelly, Chair


Reviewed regulation for training and
competency requirements
Determined personnel “competency” not
stated as requirement
REQUIRES:

Training

Verification of knowledge and skills

Documentation of training, instructor
qualifications, assessor qualifications, and
individual assessments
Part 250 - Oil & Gas & Sulphur Operations
in OCS - Subpart S (SEMS)
SEMS and API RP 75 Audit Checklist
Owner
Citation Ref #
Must I have a SEMS program? (§250.1900 / API RP 75
section 1)
§250.1900
RP 75 1
Has a safety and environmental management system (SEMS)
been developed, implemented and maintained?
O*


Operator – implied for all program elements.
C = Contractor
Per §250.1914(a), a Contractor is defined as “anyone
performing work for the Lessee.”
 Contractors may be expected to supply evidence of
compliance.

 Written policy/procedure, design information, records,
etc.

FO = Facility/Rig Owner

Owners of facility/rig may carry larger burden for
evidence for some requirements.
Documentation
Document Type
Examples
Where
Retained
Retention Period
Train Personnel
Personnel to be
Trained
What Training
Type/Level of
Training Req'd
Evidence of
Knowledge
Retained





Prepare cover page & instructions for documents
Review Tools by SEMS Committee members
Prepare reference materials for Skills Assessment and
Assessor Qualifications
Revise IADC KSAs
Expand KSAs to all rig positions

Anticipate available by end of July

Obtain copy from operator or IADC website
http://www.iadc.org