Offshore - Workplace Safety Rule?

Picking up on our last post about the BSEE,

Are Offshore Service Contractors being impacted by the Workplace Safety Rule?

What's the rule?

The Workplace Safety Rule covers all offshore oil and gas operations in federal waters and
makes mandatory the previously voluntary practices in the American Petroleum Institute’s (API)
Recommended Practice 75 (RP 75). A mandatory oil and gas SEMS program will enhance the
safety and environmental protection of oil and gas drilling operations on the Outer Continental
Shelf (OCS), particularly in light of the Deepwater Horizon explosion.

BOEMRE finalized this Workplace Safety Rule because:

It will provide oversight and enforcement of SEMS provisions. Although many large operators on the OCS had a SEMS program, the voluntary nature of the programs limited their effectiveness.
It will impose the requirement for a SEMS program on all OCS operators.
It will address human factors behind accidents not reached by current regulations, and
It will provide a flexible approach to systematic safety that can keep up with evolving technologies.

The 13 elements of RP 75 that the Workplace Safety Rule makes mandatory are as follows:

1. General provisions: for implementation, planning and management review and approval of the  SEMS program.

2. Safety and environmental information: safety and environmental information needed for any facility, e.g. design data; facility process such as flow diagrams; mechanical components such as piping and instrument diagrams; etc.

3. Hazards analysis: a facility-level risk assessment.

4. Management of change: program for addressing any facility or operational changes including management changes, shift changes, contractor changes, etc.

5. Operating procedures: evaluation of operations and written procedures.

6. Safe work practices: manuals, standards, rules of conduct, etc.

7. Training: safe work practices, technical training – includes contractors.

8. Mechanical integrity: preventive maintenance programs, quality control.

9. Pre-startup review: review of all systems.

10. Emergency response and control: emergency evacuation plans, oil spill contingency
plans, etc.; in place and validated by drills.

11.  Investigation of Incidents: procedures for investigating incidents, corrective action and follow-up.

12.  Audits: rule strengthens RP 75 provisions by requiring an audit every 4 years, to an initial 2–year reevaluation; and then subsequent 3-year audit intervals.

13.  Records and documentation: documentation required that describes all elements of the SEMS program.

Are your Operators requesting more documentation on the jobs that your company performs?

How are you tracking this information?

I believe some of these requirements will be discussed at the upcoming Clean Gulf Conference.

p.s.  LiquidFrameworks will be exhibiting at Clean Gulf, Booth #449.  Stop by for a chat.

Share your ideas.

Work Smart, Stay Safe!

The FieldPro.