- ISHN GLOBAL
- EHS RESEARCH
As domestic oil and gas development continues to expand on the U.S. Outer Continental Shelf (OCS), Secretary of the Interior Ken Salazar and Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE) Director Michael R. Bromwich recently announced a proposed rule that they say will reduce the likelihood of accidents, injuries and spills in connection with oil and natural gas exploration and development activities.
The proposed Safety and Environmental Management Systems (SEMS) rule is part of a series of safety and environmental reforms implemented by the Department of the Interior since the Deepwater Horizon oil spill. The proposed rule, which enhances the Workplace Safety Rule issued in October 2010, will add greater protection by supplementing operators’ SEMS programs with employee training, engaging personnel in safety management, and strengthening auditing procedures by requiring them to be completed by independent third parties.
“This proposed rule is the latest regulatory reform we have undertaken to enhance the safety of offshore energy operations,” said Director Bromwich. “The protection of human life and the environment are top priorities for BOEMRE. Implementing a comprehensive program with these additional features will further our goal of avoiding accidents that may result in injuries, fatalities and serious environmental damage.
A SEMS program is a comprehensive safety and environmental management program designed to reduce human and organizational errors that have been found to be the contributing or root cause of work-related accidents and offshore oil spills. SEMS programs apply to all oil and natural gas activities and facilities on the OCS including drilling, production, construction, well workover, well completion, well servicing, lifting activities and Department of the Interior (DOI) pipeline activities. In meetings with oil and gas operators, executives have expressed optimism regarding the implementation of the Workplace Safety Rule, which goes into effect in November 2011. These supplemental requirements, introduced today with an opportunity for significant public comment, enhance the rule with six additional items that operators should include in their comprehensive safety and environmental management programs:
• Additional requirements for conducting a Job Safety Analysis;
• Procedures to authorize any and all employees on the facility to implement a Stop Work Authority when witnessing an activity that creates a threat of danger to an individual, property and/or the environment;
• Clearly defined requirements establishing who has the ultimate work authority on the facility for operational safety and decision making at any given time;
• An employee participation program for SEMS implementation;
• Guidelines for reporting unsafe work conditions; and
• A requirement that safety audits be conducted by third part auditors.
The notice is available today for review in the Federal Register: http://www.archives.gov/federal-register/public-inspection/index.html. BOEMRE invites the public to comment on the proposed regulations by November 14, 2011 through any of the following methods. Please use the Regulation Identifier Number (RIN) 1010–AD73 as an identifier in your message.
• BOEMRE’s Public Engagement web page: http://www.boemre.gov/PublicComment.htm Follow the instructions to submit public comments and view supporting and related materials available for this rulemaking. BOEMRE will post all comments.
• Mail or hand-carry comments to the Bureau of Ocean Energy Management, Regulation and Enforcement; Attention: Regulations and Standards Branch (RSB); 381 Elden Street, MS-4024, Herndon, Virginia 20170-4817. Please reference “Revisions to Safety and Environmental Management Systems (SEMS), 1010–AD73” in your comments and include your name and return address.