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SEMS Final Rule

SEMS Final Rule. GOM Contractor Expectations Julia Swindle - IADC. OOC SEMS Subcommittee. Our focus is on the operator/contractor relationship and meeting the associated SEMS requirements. Our subcommittees are: Contractor Guidance – Troy Nugent – Baker Hughes

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SEMS Final Rule

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  1. SEMS Final Rule GOM Contractor Expectations Julia Swindle - IADC

  2. OOC SEMS Subcommittee • 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

  3. Documents • 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

  4. What is API RP 75 • 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

  5. SEMS vs API RP 75 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."

  6. API RP 75 Program Elements • “[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].”

  7. API RP 75 Program Elements • 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

  8. Contractor Selection • “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.

  9. SEMS Competency Subcommittee Brenda Kelly, Chair • Reviewed regulation for training and competency requirements • Determined personnel “competency” not stated as requirement

  10. SEMS Competency Subcommittee REQUIRES: • Training • Verification of knowledge and skills • Documentation of training, instructor qualifications, assessor qualifications, and individual assessments

  11. SEMS Guidance Tool

  12. “Owner” Column Legend • 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.

  13. SEMS Guidance Tool (cont’d.)

  14. SEMS Guidance Tool (cont’d.)

  15. Competence Subcommittee − Next Steps 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

  16. Competence Subcommittee − Tools Availability Anticipate available by end of July Obtain copy from operator or IADC website http://www.iadc.org

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