SEMS Element #1- Provide Resources (Policies and Procedures)

In this blog #6 of the series, I would like to discuss resources that your company through its management must provide to ensure that all personnel are complying with the policies and procedures of your SEMS. Blog #5, among other things, informed us that management must develop, implement, and maintain the SEMS. 30CFR 250.1900 states:

§ 250.1900 Must I have a SEMS program?

Your SEMS program must address the elements described in § 250.1902.

So if we follow the trail to that section, we see that 30CFR 250.1902(a) states:

§ 250.1902 What must I include in my SEMS program?

(a)     Your SEMS program must meet the minimum criteria outlined in this subpart, including the following SEMS program elements:

(1)     General

(2) Safety and Environmental Information

(3) Hazards Analysis

(4) Management of Change

(5) Operating Procedures

(6) Safe Work Practices

(7) Training

(8) Mechanical Integrity

(9) Pre-startup Review

(10) Emergency Response and Control

(11) Investigation of Incidents

(12) Auditing

(13) Recordkeeping

We are all aware of the 13 elements of SEMS. I will be concentrating on elements #5, #6 and #7. Let us backup at this point to 30CFR 250.1901 which states:

§ 250.1901 What is the goal of my SEMS program?

The goal of your SEMS program is to promote safety and environmental protection by ensuring all personnel aboard a facility are complying with the policies and procedures identified in your SEMS.

(a)     To accomplish this goal, you must ensure that your SEMS program identifies, addresses, and manages safety, environmental hazards, and  impacts

(b)     All personnel involved with your SEMS program must be trained to have the skills and knowledge to perform their assigned duties.

So, how does BSEE expect you to accomplish this daunting task? Well basically they require you to utilize personnel with expertise (training and competence) in the areas of identifying hazards, environmental impacts, optimizing operations, developing safe work practices, training and accident investigations as required in 30CFR 250.1909(f). And how must these personnel accomplish this? As per 30CFR 250.1902(b):

§ 250.1902 What must I include in my SEMS program?

(b)     You must also include a job safety analysis (JSA) for OCS activities identified or discussed in your SEMS program

All of this put together means that you must use competent qualified personnel to conduct a facility level hazard analysis (JSA of sorts). From that initial hazard analysis, management will discover what safety, environmental hazards and impacts the SEMS program will need to address. A hazard analysis will need to be conducted on each one of those resulting items. So forth and so on, till you get down to the task level hazard analysis. The results of all of these hazard analyses will be policies, operating procedures, safe work practices and training requirements for both company and contract personnel. Each hazard analysis will have its own industry standards, recommended practices and regulations that will need to be applied throughout the process. When the hazard analyses are done correctly, your management system will provide your employees and management the resources it needs to function efficiently at all levels.