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Safety and Environmental Management Systems (SEMS) Fact Sheet

The SEMS II final rule enhances the original SEMS rule, also known as the Workplace Safety Rule, that was issued in October 2010, providing greater protection by supplementing operators' SEMS programs with employee training, empowering field level personnel with safety management decisions and strengthening auditing procedures by requiring them to be completed by independent third parties.

The original Workplace Safety Rule covered all offshore oil and gas operations in federal waters and made mandatory the previously voluntary practices in the American Petroleum Institute's (API) Recommended Practice 75 (RP 75). Having a mandatory oil and gas SEMS program enhances the safety and environmental protection of offshore oil and gas drilling operations.

The SEMS II final rule expands, revises, and adds several new requirements to the existing 30 CFR part 250, subpart S, regulations for SEMS. These revisions were based on the comments received from the Notice of Proposed Rulemaking which published in the Federal Register on September 14, 2011. Operators will integrate these new requirements into their existing SEMS program, providing several key ways for personnel to help ensure safe performance of offshore oil and gas activities. The additional safety requirements contained in this final rule that were not covered in previous regulations include:

  • Developing and implementing a stop work authority that creates procedures and authorizes any and all offshore industry personnel who witness an imminent risk or dangerous activity to stop work.
  • Developing and implementing an ultimate work authority that requires offshore industry operators to clearly define who has the ultimate work authority on a facility for operational safety and decision-making at any given time.
  • Requiring an employee participation plan that provides an environment that promotes participation by offshore industry employees as well as their management to eliminate or mitigate safety hazards.
  • Establishing guidelines for reporting unsafe working conditions that enable offshore industry personnel to report possible violations of safety, environmental regulations requirements, and threats of danger directly to BSEE.
  • Establishing additional requirements for conducting a job safety analysis.
  • Requiring that the team lead for an audit be independent and represent an accredited audit service provider.

The elements of RP 75 that the Workplace Safety Rule originally made mandatory were as follows:

  • General provisions: for implementation, planning and management review and approval of the SEMS program.
  • 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.
  • Hazards analysis: a facility-level risk assessment.
  • Management of change: program for addressing any facility or operational changes including management changes, shift changes, contractor changes, etc.
  • Operating procedures: evaluation of operations and written procedures.
  • Safe work practices: manuals, standards, rules of conduct, etc.
  • Training: safe work practices, technical training - includes contractors.
  • Mechanical integrity: preventive maintenance programs, quality control.
  • Pre-startup review: review of all systems.
  • Emergency response and control: emergency evacuation plans, oil spill contingency plans, etc.; in place and validated by drills.
  • Investigation of Incidents: procedures for investigating incidents, corrective action and follow-up.
  • Audits: rule strengthens RP 75 provisions by requiring an initial audit within the first two years of implementation and additional audits in three year intervals.
  • Records and documentation: documentation required that describes all elements of the SEMS program.

The Workplace Safety Rule became effective on November 15, 2010. Operators were required to implement a SEMS program by November 15, 2011 and must still submit their first completed SEMS audit to BSEE by November 15, 2013. The SEMS II Rule became effective on June 4, 2013. Operators were given until June 4, 2014 to comply with the provisions of the SEMS II Rule, except for the auditing requirements. All SEMS audits were required to be in compliance with the SEMS II Rule by June 4, 2015.