This blog topic is related to a previous blog named Demand Accountability.  However, I wanted to get a little more specific with this one as I am seeing issues with the industry adequately addressing this requirement. I hear all of the time how an individual has been assigned to be the SEMS “Person”. If your management is fully committed to SEMS compliance, you will not have a SEMS “Person”. You will more than likely have a SEMS manager. This SEMS manager will assign other qualified individuals throughout the various organization levels to accomplish task and report back to him on those performance measures we discussed in blog #5. It will be too much for one person to tackle while trying to accomplish their other day to day activities. I hope to explain the importance of this to you. They will not only have to perform these functions for the company employees, but will also have to manage the numerous contractors that your company employs.

We have already established in previous blogs that your management is responsible for development, support, continued improvement and overall success of your SEMS. We have also established that your SEMS must set goals, performance measures, demand accountability and provide resources. All of this is stated in 30CFR 250.1909. My question to the industry is this, how can you honestly state that you are abiding by these law requirements when all you have is a SEMS “Person”. Just the task in the below CFR requirements can take up an individual’s time over a year and then it will be time to do it again:

§ 250.1909 What are management’s general responsibilities for the SEMS program?

(d)     At intervals specified in the SEMS program and at least annually, review the SEMS program (by addressing the possible need for changes to policy, objectives, and other program elements in light of audit results, changing circumstances and the commitment to continual improvement) and document the observations, conclusions and recommendations of that review.

(j)   Ensure that the SEMS program is maintained and kept up to date by means of periodic audits to ensure effective     performance.

This isn’t stating that you have to conduct an audit every year, but you do have to conduct a management review (hence the title of SEMS manager).

Now let’s look at some other requirements as mentioned in API RP 75 Sect 1.2.3. By law, management must appoint designated personnel whom accept responsibility for achieving the objectives and goals at each relevant function and level of the organization. Management must provide the designated personnel the resources needed to meet these objectives and goals (Time is a Valuable Resource). The objectives and goals must specify the means and timeframe by which they are to be achieved. These objectives and goals must also be communicated both internally and externally.

And of course, as I mentioned in blog #3 related to job descriptions, the job descriptions of these qualified individuals should support the responsibilities and roles they perform as should the training they receive.